ABDUL-JALIL al-HAKIM
7633 Sunkist Drive
Oakland, CA 94605
Tel: (510) 394-4501
ajalil1234@gmail.com
Defendant
Alliance Credit/Bank One, T. Miller,
Plaintiff,
vs.
Abdul-Jalil al-Hakim,
Defendant,
SUPERIOR COURT OF CALIFORNIA COUNTY OF ALAMEDA
Case No.:OCV0574030
Judicial Council Assignment # 1050144-17
Hearing Date: November 8, 2017
Time:9:15AM
Location: Hayward Hall of Justice ) 24405 Amador Street
Hayward, CA 94544
Department 519
TO:
Vijaya Gadde
General Counsel
and Custodian of Records for Twitter, Inc.
c/o Trust and Safety
795 Folsom Street, Suite 600
San Francisco, CA 94107
Fax: 415-222-0922, 415-222-9958
Vijaya@twitter.com, lawenforcement@twitter.com
SeanEdgett@twitter.com, lawenforcement@twitter.com, LeslieBerland@twitter.com, GenelleNg@twitter.com, BenjaminLee@twitter.com, AmyKeating@twitter.com, RobertKaiden@twitter.com, AnthonyNoto@twitter.com, JackDorsey@twitter.com
Faxed and Emailed
FROM: Abdul-Jalil al-Hakim
DATE: August 28, 2017
NO PAGES: 2+ 89 page
RE: Twitter Civil Subpoena per Evidence Code sections 1560, 1561, 1562, and 1271 and Request for Production of Documents per Code of Civil Procedure Section 2031 Attachments in Matter of MILLER VS HAKIM, Case: #OCV0574030
Dear Ms. Gadde,
I am sending you this CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and Production of Documents, Electronically Stored Information, and Things and REQUESTS FOR PRODUCTION OF DOCUMENTS, SET NO. ONE Code of Civil Procedure Section 2031attached hereto. This is in the matter of MILLER VS HAKIM, Case#OCV0574030.
TWITTER is being served pursuant to Code of Civil Procedure Section 2031 (CCP 2031) on Responding Party: Custodian of Records for Twitter, Jack Dorsey, Anthony Noto, Vijaya Gadde, Leslie Berland, Robert Kaiden, Genelle Ng, Amy Keating, Benjamin Lee, and ALL their previous and current employees, agents, independent contractors, consultants, representatives, lobbyist, experts, professional organizations, social organizations, charitable organizations, and professional services organizations, et.at.
YOU are requested to produce for inspection and copying, pursuant to Evidence Code sections 1560, 1561, 1562, and 1271 and Code of Civil Procedure Section 2031 (CCP 2031), the DOCUMENTS in the numbered categories. The production shall take place on September 30, 2017, at 9:00 a.m., at 7633 Sunkist Drive, Oakland, California, 94605.
Ms. Gadde, YOU and the Custodian of Records are NOT required to appear in person if within thirty (30) days from the date of the serving of this request upon you on August 28, 2017, you produce (i) the records described in the “DEFINITIONS” Section as part of this attached affidavit and (ii) a completed declaration of custodian of records in compliance with Evidence Code sections 1560, 1561, 1562, and 1271 and Code of Civil Procedure Section 2031 (CCP 2031). (1) Place a copy of the records in an envelope (or other wrapper). Enclose the original declaration of the custodian with the records. Seal the envelope. (2) Attach a copy of this subpoena to the envelope or write on the envelope the case name and number; your name; and the date, time, and place. (3) Place this first envelope in an outer envelope, seal it, and mail it to me at the address herein or email address: ajalil1234@gmail.com. (4) The written response shall be served within thirty (30) days of the service of this request or by September 28, 2017.
As is YOUR custom, you may provide responsive records in electronic format (i.e., text files that can be opened with any word processing software such as Word or TextEdit) or a searchable portable document file (PDF).
If any DOCUMENT requested herein was, but no longer is, in YOUR possession, custody, or control, please state whether such DOCUMENT was lost, destroyed or otherwise disposed of, and describe the circumstances and date(s) of such disposition.
As per the Orders, I am requesting ANY and ALL information you have on this
settled account to provide to me in this matter ASAP.
Please call me when the court ordered documents are available so that we can proceed in earnest to a fair resolution of this heinous 20 year matter of Elder Abuse as there is NO place for this in modern society much less in a courtroom before the people!!
Respectfully,
Abdul-Jalil al-Hakim
ajalil1234@gmail.com
510 394-4501
Respond to the Motions for Production of Documents and Subpoena
TO: Vijaya Gadde
General Counsel
and Custodian of Records for Twitter, Inc.
c/o Trust and Safety
795 Folsom Street, Suite 600
San Francisco, CA 94107
Fax: 415-222-0922, 415-222-9958
Vijaya@twitter.com, lawenforcement@twitter.com, kengtaing@twitter.com
Amy@twitter.com, Benjamin@twitter.com, Genelle@twitter.com, ‘Twitter, Inc. Team’ via Litigation <litigation@twitter.com>
Faxed and Emailed
FROM: Abdul-Jalil al-Hakim
DATE: October 2, 2017
NO PAGES: 2
RE: Respond to the Motions for Production of Documents and Subpoena, etc., MILLER VS HAKIM, Case: #OCV0574030
Dear Ms. Gadde and Twitter Legal Team:
I am in receipt of an email from “Twitter, Inc. Team” via Litigation <litigation@twitter.com> wherein you wrote:
“Dear Mr. al-Hakim:
We are in receipt of your legal process, dated August 24, 2017, in this matter. Please provide us with a copy of the complaint by replying directly to this email.
Thank you.
—
Twitter Legal”
The complaint is NOT necessary to respond to the 89 page CIVIL SUBPOENA (DUCES TECUM) for Personal Appearance and Production of Documents, Electronically Stored Information, and Things and REQUESTS FOR PRODUCTION OF DOCUMENTS, SET NO. ONE served on you in this matter.
We expect your timely response.
“Thank you”.
Respectfully,
Abdul-Jalil al-Hakim
ajalil1234@gmail.com
510-394-4501
Meet and Confer
TO: Vijaya Gadde
General Counsel
and Custodian of Records for Twitter, Inc.
c/o Trust and Safety
795 Folsom Street, Suite 600
San Francisco, CA 94107
Fax: 415-222-0922, 415-222-9958
Vijaya@twitter.com, lawenforcement@twitter.com, kengtaing@twitter.com
Amy@twitter.com, Benjamin@twitter.com, Genelle@twitter.com, ‘Twitter, Inc. Team’ via Litigation <litigation@twitter.com>
Faxed and Emailed
FROM: Abdul-Jalil al-Hakim
DATE: October 4, 2017
NO PAGES: 2 pages
RE: Meet and Confer regarding Subpoena (Duces Tecum) and Request for Production of Documents in Matter of MILLER VS HAKIM, Case: #OCV0574030
Dear Ms. Gadde,
I am the defendant in the above-referenced case.
On August 28, 2017, I had served a CIVIL SUBPOENA (DUCES TECUM) in compliance with Evidence Code sections 1560, 1561, 1562, and 1271, for Personal Appearance and Production of Documents, Electronically Stored Information, and Things in addition to a formal Request for Production of Documents, Set One, per CCP 2031 via fax and email. You should have provided the documents to us by September 28, 2017. You have failed and refused to comply with the courts order.
This letter asks you to please fully comply with and respond to the Subpoena and Request for Production, Set One by October 6, 2017. If I do not receive these responses, I will file a motion in court to obtain compliance and compel the production of the documents, demand the related costs of the motion with all fees and sanctions, request a contempt order and order a bench warrant for the arrest of those responsible as provided by California Code of Civil Procedure § 2031.300 and others. We have secured a court date of November 8, 2017, at 9:15 AM, in Department 511 of the Alameda County Superior Court, in Hayward California.
If you have any objection, response or reply it should be made in the form of a properly noticed, served, and filed motion to the court.
Please call me when the court ordered documents are available so that we can proceed in earnest to a fair resolution of this heinous 20 year matter of Elder Abuse as there is NO place for this in modern society much less in a courtroom before the people!!
Respectfully,
Abdul-Jalil al-Hakim
ajalil1234@gmail.com
510-394-4501
Motion to Compel
TO: Vijaya Gadde
General Counsel
and Custodian of Records for Twitter, Inc.
c/o Trust and Safety
795 Folsom Street, Suite 600
San Francisco, CA 94107
Fax: 415-222-0922, 415-222-9958
Vijaya@twitter.com, lawenforcement@twitter.com, kengtaing@twitter.com
Amy@twitter.com, Benjamin@twitter.com, Genelle@twitter.com, ‘Twitter, Inc. Team’ via Litigation <litigation@twitter.com>
Faxed and Emailed
FROM: Abdul-Jalil al-Hakim
DATE: October 9, 2017
NO PAGES: 18 pages
RE: Defendants Motion to Compel Subpoena and Request for Production of Documents for Twitter in Matter of MILLER VS HAKIM, Case: #OCV0574030
Dear Ms. Gadde,
Attached please find Defendants Motion to Compel Subpoena and Request for Production of Documents for Twitter.
We have secured a court date of November 8, 2017, at 9:15 AM, in Department 511 of the Alameda County Superior Court, in Hayward California.
Abdul-Jalil al-Hakim
510-394-4501
Reply Motion to Compel
TO: Vijaya Gadde
General Counsel
and Custodian of Records for Twitter, Inc.
c/o Trust and Safety
795 Folsom Street, Suite 600
San Francisco, CA 94107
Fax: 415-222-0922, 415-222-9958
Vijaya@twitter.com, lawenforcement@twitter.com, kengtaing@twitter.com
Amy@twitter.com, Benjamin@twitter.com, Genelle@twitter.com, ‘Twitter, Inc. Team’ via Litigation <litigation@twitter.com>
Faxed and Emailed
FROM: Abdul-Jalil al-Hakim
DATE: October 23, 2017
NO PAGES: 18 pages
RE: Defendants Reply Motion to Compel Subpoena and Request for Production of Documents for Twitter in Matter of MILLER VS HAKIM, Case: #OCV0574030
Dear Ms. Gadde,
Attached please find Defendants Reply Motion to Compel Subpoena and Request for Production of Documents for Twitter.
We have secured a court date of November 8, 2017, at 9:15 AM, in Department 511 of the Alameda County Superior Court, in Hayward California.
Abdul-Jalil al-Hakim
510-394-4501
************
I electronically caused such document(s) to be transmitted and served on the parties listed herein by transmitting them via .pdf/email to the email address(es) set forth herein and in the email header above. My electronic proof of service email address for the purposes of legal process only is :processlegalserver@gmail.com. PLEASE NOTE YOU CAN NOT REPLY TO THIS EMAIL ADDRESS AS IT IS UNATTENDED. Please respond to the party at their email address.
You are All herewith officially served via email the foregoing and/or attached document(s) as described in the following:
Defendants Motion to Compel Subpoena and Request for Production of Documents for Twitter.
Respectfully,
Nanita Strong
(BY EMAIL)
cc: Abdul-Jalil
510-394-4501
ajalil1234@gmail.com