Adelman First Discovery Requests

CAUSE NO.
CC-10-08658-E
FERNANDO ROSALES AND § IN THE COUNTY COURT AT LAW

INITIATIVE PARTNERS, LLC, D/B/A §
LOST SOCIETY, §
§
Plaintiffs §
§
v. § NO. 5
§
§
AVI S. ADELMAN, BARKINGDOGS.ORG, §
AND DALLAS CREATIVE, INC., §
§
Defendants. § DALLAS COUNTY, TEXAS
DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION,

FIRST REQUESTS FOR ADMISSION, AND FIRST SET OF INTERROGATORIES
TO: Plaintiffs Fernando Rosales and Initiative Partners, LLC, d/b/a Lost Society, by and
through their attorney of record, Armando Miranda, 923 West Jefferson, Dallas, TX
75208
Pursuant to the Texas Rules of Civil Procedure, Defendants Avi S. Adelman,
BarkingDogs.org (erroneously sued as BarkingDog.org), and Dallas Creative (erroneously sued
as Dallas Creative, Inc.) hereby request that Plaintiffs Fernando Rosales and Initiative Partners,
LLC, d/b/a Lost Society respond fully to these Requests for Production, Requests for Admission,
and First Set of Interrogatories within 30 days. Plaintiffs shall serve their responses and all
responsive documents on Defendants’ counsel, Thomas S. Leatherbury, Vinson & Elkins L.L.P.,
2001 Ross Avenue, Suite 3700, Dallas, Texas 75201.
DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

FIRST REQUESTS FOR ADMISSION, AND FIRST SET OF INTERROGATORIES Page 1
I. DEFINITIONS AND INSTRUCTIONS
1. “Mr. Rosales” means “Fernando Rosales” and any agents, employees, attorneys, and
other persons acting on his behalf.
2. “Initiative Partners” means “Initiative Partners, LLC” and any agents, employees,
attorneys and other persons acting on its behalf, including “Lost Society.”
3. “Lost Society” means the establishment operated as “Initiative Partners, LLC, d/b/a Lost
Society.”
4. “You” or “Your” means “Fernando Rosales” and any agents, employees, attorneys, and
other persons acting on his behalf.
5. “Plaintiffs” means collectively “Fernando Rosales” and “Initiative Partners, LLC, d/b/a
Lost Society.”
6. “Defendants” means collectively “Avi S. Adelman,” “BarkingDogs.org,” and “Dallas

Creative.”
7. “Mr. Nwatu” means “Brightman Ohiagu Nwatu,” also known as “Brian Nwatu,” and any
agents, employees, attorneys, and other persons acting on his behalf.
8. “Mr. Miranda” means “Jesus Armando Miranda,” and/or “Armando Miranda,” Plaintiffs’
attorney of record.
9. “Mr. Adelman” means “Defendant Avi S. Adelman” and any agents, employees,
attorneys, and other persons acting on his behalf.
10. “Challenged weblog articles,” unless otherwise specified in the specific request, means the
June 3, 2010; June 6, 2010; June 10, 2010; June 23, 2010; June 28, 2010; June 30, 2010;
July 2, 2010; September 11, 2010; October 21, 2010; October 30, 2010; and December 4,
2010 weblog articles referenced in Plaintiffs’ Amended Petition.
11. “Petition” means Plaintiffs’ Amended Petition filed in this case on December 10, 2010.
12. “Communication” means any contact whatsoever or any transmission or exchange of

words, numbers, graphic material, or other information, either orally, electronically, or in
writing, whether made, received, or participated in, and includes, but is not limited to, any
conversation, correspondence, letter, notes, memorandum, inter-office or intra-office
correspondence, telephone call, telegraph, telegram, telex, telecopy, facsimile, e-mail,
Internet communication, telefax, cable, electronic message, tape recording, discussion,
face-to-face meeting, or conference of any kind (whether in person, by audio, video,
telephone, or in any other form).
13. “Document” means any document within the scope of Tex. R. Civ. P. 192, including but
not limited to, any writing in your custody, possession or control or known to
you—whether printed, recorded, reproduced by any process, or written or produced by

hand—including, but not limited to, papers, books, accounts, data, data compilations,
letters, reports, agreements, opinions, communications, calendars or day-timers,
correspondence, emails, telegrams, memoranda, summaries, records of personal
conversations, photographs, electronic, videotape or audiotape recordings, information or
data stored electronically, including that stored on computer or computer disk, graphs,
charts, drawings, exhibits, records, invoices, and receipts. The term “documents” also
includes all electronic documents, including emails that have been deleted. Any comment
or notation appearing on any document, and not a part of the original text, is to be
considered a separate “document.”
14. “Person” means any individual, entity, or association of individuals or entities of any kind,
and includes partnerships, limited partnerships, corporations, joint ventures, joint
enterprises, trade associations, regulatory bodies, government agencies, or government
entities of any kind.
15. “Representative” means any officer, director, owner, shareholder, partner, joint venturer,
associate, employee, servant, agent, representative, subsidiary, or affiliate of the Person;
and any other Persons or legal or business entities acting for, on behalf of, or in concert
with the Person, including consultants, advisors, lawyers, investment bankers,
accountants, and anyone else engaged, retained, or employed by the Person.
16. “Relating to,” “referring to,” and “concerning” are used in their broadest sense, and shall
mean anything that, directly or indirectly, generally or specifically, regards, relates to,
refers to, concerns, contains, constitutes, contradicts, evidences, embodies, comprises,
reflects, mentions, identifies, states, deals with, comments on, responds to, describes,
analyzes, or is in any way, directly or indirectly, relevant to the subject.
17. Any request or response to any request involving a corporation or other business entity or
any other entity shall also refer to and include any and all parents, subsidiaries, affiliates,
partners, joint venturers, agents, employees, representatives, accountants, investment
bankers, or attorneys acting on behalf of the corporation or other entity.
18. “Including” and “includes” shall mean “without limitation.”
19. “Any” and “all” shall mean “any and all” or “each and every.”
20. “And” and “or” shall mean “and/or.” The term “and/or” shall be construed so as to
require the broadest response.
21. The past tense shall include the present tense and vice versa.
22. Terms in the singular shall include the plural, and terms in the plural shall include the
singular.
23. Terms not defined in these discovery requests shall have the meanings used in the
pleadings or, if not used in the pleadings, the usual and ordinary meaning.

24. Any documents withheld on a claim of privilege must be preserved. If any documents are
so withheld, Defendants hereby request, pursuant to Rule 193.3 of the Texas Rules of
Civil Procedure, that you identify in a privilege list or log each such document and
provide the information set forth in Rule 193.3(b).
25. In producing documents and materials, you are requested to furnish all documents or
things in your possession, custody, or control, regardless of whether such documents or
materials are possessed directly by you or your directors, officers, partners, members,
agents, employees, representatives, subsidiaries, managing agents, affiliates, investigators,
or by your attorneys or their agents, employees, representatives, or investigators.
26. This request requires the originals to be produced for inspection and copying, if they exist
and are in your possession, custody, control, or access, including documents within the
possession, custody, or control of your officers, directors, employees, attorneys, agents,
representatives, and other persons or entities who have acted or purported to act on your
behalf.
27. Documents not otherwise responsive to the discovery requests shall be produced if such
documents mention, discuss, refer to, or explain the documents that are called for by the
discovery request, or if such documents are attached to documents called for by the
discovery request.
28. If any document was, but is no longer, in your possession or subject to your control, state
whether it: (a) is missing or is lost; (b) has been destroyed; (c) has been transferred,
voluntarily or involuntarily, to others; or (d) is otherwise disposed of. In each instance
explain the circumstances of such disposition, state the approximate date thereof, and
identify all persons having knowledge of the document’s contents.
29. Please produce all electronic or magnetic data or media in electronic or magnetic form on
compact discs (CDs) or DVDs pursuant to Rule 196.4.
30. These Requests are continuing in nature. If you become aware of or acquire in your
possession, custody, or control additional responsive documents or tangible things, you
are requested promptly to provide such additional documents.
31. Unless otherwise indicated, the relevant time period for these requests is January 1, 2008
to the present.

II. REQUESTS FOR PRODUCTION
GENERAL REQUESTS
REQUEST FOR PRODUCTION NO. 1: Produce all Documents reflecting the statements at
issue in this case that you claim are false and/or not substantially true. Your production should
include, but is not limited to documents, correspondence, and communication relating to the June
3, 2010; June 6, 2010; June 10, 2010; June 23, 2010; June 28, 2010; June 30, 2010; July 2, 2010;
September 11, 2010; October 21, 2010; October 30, 2010; and December 4, 2010 weblog articles
referenced in your Amended Petition.
REQUEST FOR PRODUCTION NO. 2: Produce all Documents mentioning, discussing, or

referencing: (a) this lawsuit; (b) the claims alleged by you in this lawsuit; (c) the articles that are
at issue in this lawsuit; and/or (d) the statements at issue in this lawsuit.
REQUEST FOR PRODUCTION NO. 3: Produce all Documents relating to Defendants’

alleged actual knowledge of any alleged false statement and/or false impression contained in the
challenged weblog articles. This request includes but is not limited to any documents relating to
the June 3, 2010; June 6, 2010; June 10, 2010; June 23, 2010; June 28, 2010; June 30, 2010; July
2, 2010; Sept. 11, 2010; October 21, 2010; October 30, 2010; and December 4, 2010 weblog
articles referenced in your Amended Petition.
REQUEST FOR PRODUCTION NO. 4: Produce all Documents and correspondence between
you and Mr. Adelman.
REQUEST FOR PRODUCTION NO. 5: Produce all Documents in your possession, custody,
or control relating to, referring to or mentioning Mr. Adelman or BarkingDogs.org.
REQUEST FOR PRODUCTION NO. 6: Produce all articles, broadcasts, reports,

publications, and/or other type of published materials that in any way mention Initiative Partners
and/or Lost Society.

publications, and/or other type of published materials that in any way mention you.

publications, and/or other type of published materials that in any way mention Mr. Nwatu.
REQUEST FOR PRODUCTION NO. 9: Produce all Documents relating to, showing, and/or
demonstrating any damages alleged by you in this lawsuit, including all actual, general,
presumed, special, exemplary, and/or other form of damages claimed by you in this lawsuit.
REQUEST FOR PRODUCTION NO. 10: Produce your most current resume and/or
curriculum vitae.

REQUEST FOR PRODUCTION NO. 11: Produce all Documents demonstrating any
emotional and/or mental distress allegedly suffered by you as a result of the statements at issue.
REQUEST FOR PRODUCTION NO. 12: Produce all Documents relating to, containing,
discussing, or mentioning any psychological evaluation and/or psychiatric evaluation of you.
REQUEST FOR PRODUCTION NO. 13: Produce all Documents relating to any
psychological, psychiatric, or mental health treatment you have received, including diagnoses,
treatment plans, and prescriptions.
REQUEST FOR PRODUCTION NO. 14: Produce all Documents sufficient to show all
income and revenue earned by you since 2007. These documents will include your tax returns
since 2007.
companies, partnerships, and/or other businesses in which you have served as an officer or
director.
REQUEST FOR PRODUCTION NO. 16: Produce all Documents relating to the creation of
Initiative Partners and the establishment of Lost Society bar in Dallas, Texas.
lawsuits, arbitrations, judicial proceedings, and administrative proceedings to which you have
been a party.
REQUEST FOR PRODUCTION NO. 18: Produce all Documents relating to Lost Society’s
license to serve alcohol in the City of Dallas and State of Texas during the following years: (a)
2008, (b) 2009, (c) 2010, and (d) 2011. This includes all Documents regarding licenses or
permits to serve alcohol that have been granted, refused, suspended, and/or revoked by the Texas
Alcoholic Beverage Commission during any of those years.
REQUEST FOR PRODUCTION NO. 19: Produce all Documents relating to any and all
licensing proceedings by the Texas Alcoholic Beverage Commission against you or your
establishment, Lost Society.
REQUEST FOR PRODUCTION NO. 20: Produce all Documents relating to Mr. Nwatu’s
current or former co-ownership of Lost Society and/or Mr. Nwatu’s partnership in Initiative
Partners. This request will include any current or former ownership, co-ownership, partnership
interest, investment interest, and/or any other economic interest that Mr. Nwatu has or has had in
Lost Society, Initiative Partners, and/or both entities. This request will include documents
relating to any current or former ownership, co-ownership, partnership interest, investment
interest, and/or any other economic interest by Mr. Nwatu in any predecessors-in-interest or
successors-in-interest of Lost Society and/or Initiative Partners.
REQUEST FOR PRODUCTION NO. 21: Produce all Documents relating to Mr. Nwatu’s
United States citizenship status for the years 2006 to 2011. This request will include documents,
communication, and correspondence from the U.S. Bureau of Citizenship and Immigration
Services.

REQUEST FOR PRODUCTION NO. 22: Produce all Documents relating to Mr. Rosales’s
current or former co-ownership of Lost Society and/or partnership in Initiative Partners. This
request will include any current or former ownership, co-ownership, partnership interest,
investment interest, and/or any other economic interest that Mr. Rosales has or has had in Lost
Society, Initiative Partners, and/or both entities. This request will include documents relating to
any current or former ownership, co-ownership, partnership interest, investment interest, and/or
any other economic interest by Mr. Rosales in any predecessors-in-interest or successors-in-
interest of Lost Society and/or Initiative Partners.
SPECIFIC DOCUMENTS RELATED TO UNDERLYING TRANSACTIONS
REQUEST FOR PRODUCTION NO. 23: Produce all Documents sufficient to show your
knowledge of Mr. Adelman’s weblog postings. This request includes Documents relating to your
access of the BarkingDogs.org website. Your production should include, but is not limited to
documents, communications, and correspondence relating to your knowledge of and access to
the June 3, 2010; June 6, 2010; June 10, 2010; June 23, 2010; June 28, 2010; June 30, 2010; July
2, 2010; Sept. 11, 2010; October 21, 2010; October 30, 2010; and/or December 4, 2010 weblog
articles referenced in your Amended Petition.
REQUEST FOR PRODUCTION NO. 24: Produce all Documents relating to “business
dealings” Mr. Rosales and/or Initiative Partners had in place at the time of the challenged weblog
articles referred to in paragraph 23 of your Amended Petition.
REQUEST FOR PRODUCTION NO. 25: Produce all Documents relating to, showing, and/or
demonstrating any lost business opportunities you allege are a result of, caused by, and/or
attributable to Defendants’ publication(s).
REQUEST FOR PRODUCTION NO. 26: Produce all Documents relating to any alleged
copyright infringement you contend Defendants’ committed on Paragraph 18 of your Amended
Complaint. This request includes, but is not limited to documentation, correspondence, and/or
communications relating to the challenged June 6, 2010 weblog article referenced in paragraphs
13 and 14 of your Amended Petition.
copyright held by Plaintiffs. This request includes, but is not limited to, any documentation,
correspondence, and/or communications from the U.S. Copyright Office.
trademark law violation you allege Defendants committed in paragraph 16 of your Amended
Petition. This request includes, but is not limited to documents relating to the challenged June 6,
2010 weblog article referenced in paragraphs 13 and 14 of your Amended Petition.
trademark held by Plaintiffs during the time of the challenged June 6, 2010 weblog article
referenced in paragraphs 13, 14, 15, and 16 of your Amended Petition. This request includes, but
is not limited to, documentation from the U.S. Patent and Trademark Office.

REQUEST FOR PRODUCTION NO. 30: Produce all Documents relating to Plaintiffs’
reputation in the community during the time period of the challenged weblog articles. This
request includes, but is not limited to documents, correspondence, and communication
evidencing (a) Dallas residents’ and/or Greenville Avenue area residents’ opinions of Lost
Society and/or Initiative Partners; (b) Dallas residents’ and/or Greenville Avenue area residents’
opinions of Mr. Rosales; or (c) Dallas residents’ and/or Greenville Avenue area residents’
opinions of Mr. Nwatu. This request includes documents, correspondence, or communication
from the following time periods: (a) from Lost Society’s opening to June 3, 2010—the date of
the first challenged weblog article; (b) between June 3, 2010 and December 4, 2010—the date
span from the first challenged weblog article to the last challenged article; and (c) during any
other relevant time period in which Lost Society’s reputation was formed, established, and/or
injured by any party or parties, including parties not named in this lawsuit.
REQUEST FOR PRODUCTION NO. 31: Produce all Documents relating to Plaintiffs’
knowledge of an alleged call by Mr. Adelman to the Dallas Sheriff’s Office on June 10, 2010
referenced in paragraphs 20 and 21 of your Amended Petition.
REQUEST FOR PRODUCTION NO. 32: Produce all Documents relating to alleged injury to
Plaintiffs’ reputation allegedly suffered as a result of the alleged June 10, 2010 call.
REQUEST FOR PRODUCTION NO. 33: Produce all Documents relating to the Plaintiffs’
knowledge of and access to the challenged weblog article on June 23, 2010 referenced in
paragraphs 24 and 25 of your Amended Petition.
REQUEST FOR PRODUCTION NO. 35: Produce all Documents relating to the Defendants’
alleged knowledge of falsity of statements allegedly made in the challenged weblog article on
June 23, 2010 referenced in paragraphs 24 and 25 of your Amended Petition.
infringement of a copyright allegedly held by Mr. Rosales in an alleged photograph. The alleged
photograph is referenced in paragraphs 26 and 27 of your Amended Petition. This request
includes, but is not limited to, any documentation, correspondence, and/or communications from
the U.S. Copyright Office.
issue in the challenged weblog article of June 28, 2010 referenced in paragraphs 28, 29, and 30
that you claim are false and/or not substantially true.

challenged weblog article of June 28, 2010 referenced in paragraphs 28, 29 and 30.
issue in the challenged weblog article of June 30, 2010 referenced in paragraphs 31 and 32 that
you claim are false and/or not substantially true.
challenged weblog article of June 30, 2010 referenced in paragraphs 31 and 32.
issue in the challenged weblog article of July 2, 2010 referenced in paragraphs 33, 34, and 35
challenged weblog article of July 2, 2010 referenced in paragraphs 33, 34, and 35.
issue in the challenged weblog article of Sept. 11, 2010 referenced in paragraphs 36, 37, and 38
challenged weblog article of Sept. 11, 2010 referenced in paragraphs 36, 37, and 38.
issue in the challenged weblog article of Oct. 21, 2010 referenced in paragraph 39 that you claim
are false and/or not substantially true.
challenged weblog article of Oct. 21, 2010 referenced in paragraph 39.
issue in the challenged weblog article of Oct. 30, 2010 referenced in paragraphs 40, 41, 42, 43,
and 44 that you claim are false and/or not substantially true.
challenged weblog article of Oct. 30, 2010 referenced in paragraphs 40, 41, 42, 43, and 44.
issue in the challenged weblog article of Dec. 4, 2010 referenced in paragraphs 45, 46, and 47

challenged weblog article of Dec. 4, 2010 referenced in paragraphs 45, 46, and 47.

III. REQUESTS FOR ADMISSION
REQUEST FOR ADMISSION NO. 1: Admit that you were indicted for making a false
statement in a public filing.
REQUEST FOR ADMISSION NO. 2: Admit that you are currently being charged with a
felony or misdemeanor.
REQUEST FOR ADMISSION NO. 3: Admit that you, Initiative Partners, and/or Lost Society
are being investigated or have been investigated by the Texas Alcoholic Beverage Commission
for possible violations of the Texas Alcoholic Beverage Code.
REQUEST FOR ADMISSION NO. 4: Admit that you have sold Initiative Partners and/or
Lost Society.
REQUEST FOR ADMISSION NO. 5: Admit that you are in the process of selling Initiative
Partners and/or Lost Society.
REQUEST FOR ADMISSION NO. 6: Admit that you have not reported the sale to the Texas
Alcoholic Beverage Commission.
REQUEST FOR ADMISSION NO. 7: Admit that Mr. Nwatu is or was a co-owner, partner, or
joint venturer of Initiative Partners and/or Lost Society.
REQUEST FOR ADMISSION NO. 8: Admit that Mr. Nwatu is or was employed by Initiative
Partners and/or Lost Society.
REQUEST FOR ADMISSION NO. 9: Admit that Mr. Nwatu was arrested for and/or charged
with the offense of subterfuge ownership in violation of the Texas Alcoholic Beverage Code.
REQUEST FOR ADMISSION NO. 10: Admit that Mr. Nwatu was arrested for and/or
charged with assault.
REQUEST FOR ADMISSION NO. 11: Admit that Mr. Nwatu was arrested for and/or
charged with assault in connection with an incident that occurred at Lost Society.
REQUEST FOR ADMISSION NO. 12: Admit that you, Initiative Partners, and/or Lost
Society were investigated by the Southern Methodist University Police Department.
REQUEST FOR ADMISSION NO. 13: Admit that you and/or Initiative Partners do not own a
registered trademark for the name “Lost Society.”
REQUEST FOR ADMISSION NO. 14: Admit that your landlord charged you with violating
your lease while operating Lost Society.
REQUEST FOR ADMISSION NO. 15: Admit that patrons of Lost Society were arrested on
October 21, 2010 in connection with a shooting incident.

REQUEST FOR ADMISSION NO. 16: Admit that patrons of Lost Society were arrested on
June 3, 2010 in connection with a shooting incident.

IV. INTERROGATORIES
INTERROGATORY NO. 1: Identify all persons with knowledge of any facts relevant to this
lawsuit. Briefly state (2-3 sentences) the substance of each person’s knowledge.
INTERROGATORY NO. 2: Identify with specificity the statements by the Defendants that
you are challenging in this lawsuit. Your response should include, but not be limited to, the
publication(s) in which each such statement appears, the applicable page number, and the precise
words of each such statement (in quotations).
INTERROGATORY NO. 3: For all statements identified in your response to Interrogatory No.
2, identify all persons with knowledge of facts that you believe support your contention that such
statements are false and defamatory.
INTERROGATORY NO. 4: Identify all articles, broadcasts, reports, publications, and/or other
type of published materials that in any way mention you since 2008. Your answer should
include any such references on any internet website and/or weblog.
INTERROGATORY NO. 5: Identify (by style, cause number, filing date, court, alleged causes
of action, attorneys involved, status, and outcome) every lawsuit, bankruptcy, judicial proceeding
(civil or criminal), arbitration, and/or administrative proceeding to which you have been a party.
INTERROGATORY NO. 6: Identify (by style, cause number, filing date, court, alleged causes
of action, attorneys involved, status, and outcome) every lawsuit, bankruptcy, judicial
proceeding, arbitration, and/or administrative proceeding to which Initiative Partners and/or Lost
Society have been a party.
INTERROGATORY NO. 7: Identify all criminal proceedings in which you have been
involved. Your response should include, but not be limited to, all arrests, traffic tickets,
indictments, criminal information or other charges, pleas, and trials.
INTERROGATORY NO. 8: Identify all government investigations in which Initiative Partners

and/or Lost Society have been involved. Your response should include, but not be limited to,
investigations by the Texas Alcoholic Beverage Commission, Dallas Police Department, Dallas
County Sheriff’s Office, City of Dallas, and any other national, state, or local government
agency.
INTERROGATORY NO. 9: Identify any crimes or alleged crimes that have taken place on the
premises owned by Initiative Partners and/or Lost Society. Your answer should identify the
victims and perpetrators, any law enforcement agency involved, and the result of any criminal
proceedings.
INTERROGATORY NO. 10: Identify all persons (other than your attorneys) with whom you
have discussed this lawsuit and/or the allegations in this lawsuit.
INTERROGATORY NO. 11: State fully, completely, and in detail by category, each and
every item of actual, general, presumed, special, exemplary, and/or other damages that you claim
against any of the defendants in this lawsuit, the dollar amount of each item of damage, and a

detailed description of how you calculated the dollar amount of such damages. Your description
should include each element of damage or component of recovery that you seek, the amount
sought for each element or component, the manner in which each element or component of the
calculation was determined, and the source of each number used in the calculation.
INTERROGATORY NO. 12: Identify all business and/or economic opportunities that you
contend were lost as a result of the publication of the statements at issue in this lawsuit. Your
answer should include the “business dealings” Mr. Rosales and/or Initiative Partners had in place
at the time of the challenged weblog articles referred to in paragraph 23 of Plaintiffs’ First
Amended Petition.
INTERROGATORY NO. 13: Itemize, by dollar amount, your income for each year since
2007 and your expected income for 2011.
INTERROGATORY NO. 14: Itemize, by dollar amount, Initiative Partners’ and/or Lost
Society’s income for each year since 2008 and its expected income for 2011.
INTERROGATORY NO. 15: Identify (by name, address, type of professional, and
approximate time frame you saw them) all physicians, psychologists, psychiatrists, therapists,
counselors, social workers, and any other medical, physical, or mental health related
professionals who have evaluated, interviewed, diagnosed, tested, assessed, treated, or counseled
you since 2007.
INTERROGATORY NO. 16: Identify any persons or businesses with which you have
discussed the sale of Initiative Partners and/or Lost Society, or to which you have sold Initiative
partners and/or Lost Society.

Respectfully submitted,
VINSON & ELKINS L.L.P.
____________________________________
Thomas S. Leatherbury
State Bar No. 12095275
Lisa R. Helem
Tyler J. Bexley
2001 Ross Avenue, Suite 3700
Dallas, Texas 75201-2975
Telephone: 214.220.7792
Facsimile: 214.999.7792
Counsel for Defendants Avi S. Adelman, BarkingDogs.org,

and Dallas Creative
CERTIFICATE OF SERVICE
I hereby certify that on February 7, 2011 a true and correct copy of Defendants’ First
Requests for Production, First Requests for Admission and First Set of Interrogatories were
served on the following counsel of record by certified mail, return receipt requested:
Armando Miranda
923 West Jefferson
Dallas, TX 75208
Attorney for Plaintiffs


Adelman First Discovery Requests

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CAUSE NO.

FERNANDO ROSALES AND § IN THE COUNTY COURT AT LAW

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION,

Pursuant to the Texas Rules of Civil Procedure, Defendants Avi S. Adelman,

BarkingDogs.org (erroneously sued as BarkingDog.org), and Dallas Creative (erroneously sued

2001 Ross Avenue, Suite 3700, Dallas, Texas 75201.

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

6. “Defendants” means collectively “Avi S. Adelman,” “BarkingDogs.org,” and “Dallas

12. “Communication” means any contact whatsoever or any transmission or exchange of

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

18. “Including” and “includes” shall mean “without limitation.”

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 2: Produce all Documents mentioning, discussing, or

REQUEST FOR PRODUCTION NO. 3: Produce all Documents relating to Defendants’

REQUEST FOR PRODUCTION NO. 6: Produce all articles, broadcasts, reports,

REQUEST FOR PRODUCTION NO. 7: Produce all articles, broadcasts, reports,

REQUEST FOR PRODUCTION NO. 8: Produce all articles, broadcasts, reports,

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

SPECIFIC DOCUMENTS RELATED TO UNDERLYING TRANSACTIONS

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

INTERROGATORY NO. 8: Identify all government investigations in which Initiative Partners

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

VINSON & ELKINS L.L.P.

Counsel for Defendants Avi S. Adelman, BarkingDogs.org,

Attorney for Plaintiffs

DEFENDANTS’ FIRST REQUESTS FOR PRODUCTION

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