NOTICE OF PRODUCTION

IN THE COUNTY COURT FOR THE NINTH JUDICIAL CIRCUIT

IN AND FOR ORANGE COUNTY

 

PERSONA 1,     §

Plaintiff,     §

  1.     § Case No.: 2018-CC-7680-O

PERSONA 1   §

Defendant.     §

 

NOTICE OF PRODUCTION

To: Certainteed Corporation

You are notified that, after 10 days from the date of service of this notice, the undersigned will apply to the clerk of this Court for issuance of the attached subpoena directed to you to produce the items listed at the time and place specified in the subpoena. Objections to the issuance of this subpoena must be filed with the clerk of the circuit court within 10 days.

 

I certify that a copy of this document was mailed and emailed to the persons listed below:

PERSONA 1

 

Attorneys for Defendant

 

Respectfully Submitted,

___________________________________

PERSONA 1

Plaintiff in pro per

IN THE COUNTY COURT FOR THE NINTH JUDICIAL CIRCUIT

IN AND FOR ORANGE COUNTY

 

PERSONA 1,     §

Plaintiff,     §

  1.     § Case No.: 

PERSONA 1   §

Defendant.     §

 

SUBPOENA FOR PRODUCTION OF DOCUMENTS

To: Certainteed Corporation

You must go to [INSERT ADDRESS] on [DATE] at [TIME], and bring with you at that place and time the following:

  1. Name and contact information for Defendant representatives that will provide manufacturing and coatings testimony;
  2. Name and contact information for NACE 1 (North American Coatings Engineer) certified Defendant representative that will provide testimony;
  3. Mr. David Keundig’s inspection report for Plaintiff’s residence;
  4. Copies of Defendant’s 2016 and 2017 written warranties for the product;
  5. Correspondence between Defendant’s warranty inspector David Keundig and Plaintiff;
  6. Correspondence between Plaintiff and Defendant;
  7. Defendant’s June 8 2018 product inspection report performed by Defendant’s inspector representative, Steve Radford;
  8. Defendant’s product packaging, or shingle wrapper from 2016 product, indicating warranty terms, claims, and conditions of use;
  9. Retailer in-store or point of sale merchandising, or advertising, for Defendant’s product;
  10. Defendant’s ASTM (American Standard Test Method) D2746/D2746 M 2016 test results for Defendant’s product;
  11. Product label warnings or warranty limitations for Defendant’s product;
  12. Notice to Plaintiff that Defendant’s product was installed improperly on Plaintiff’s residence, not in accordance with the terms or conditions of Defendant’s product warranty;
  13. MSDS (Manufacture Safety Data Sheets) for Defendant’s product;
  14. EDS (Environmental Data Sheets) for all chemicals used in the manufacture of Defendant’s product;
  15. Evidence that chemicals leaching from Defendant’s product are environmentally safe, not harmful to Plaintiff’s health, groundwater aquifer, or drinking water;
  16. TDS (Technical Data Sheets) for all chemicals and materials used in manufacturing Defendant’s product;
  17. VOC (Volatile Organic Compound) data for Defendant’s product;
  18. All claims of warranty against Defendant’s product for 2016-2017; and
  19. Defendant’s 2016 laboratory and field testing results for the product.

The above items will be inspected and may be copied at that time. You will not have to leave the original items.

You may obey this subpoena by providing readable copies of the items to be produced to PERSONA 1 on or before the scheduled date of production. You may condition the preparation of the copies upon payment in advance of the reasonable cost of preparation. If you mail or deliver the copies to PERSONA 1, you do not have to appear in person.

You may be in contempt of court if you fail to: (1) appear as specified; (2) furnish the records instead of appearing as provided above; or (3) object to this subpoena.

You can only be excused by PERSONA 1and, unless excused by that person of the  Court, you shall respond as directed.

 

Dated this ____ day of ________________, 2022.

 

___________________________________

Honorable 

Judge 

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