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Friday, October 24, 2014
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Court Orders Discovery for Julian Robertson  (continued)
    by URI DOWBENKO

Court Orders Discovery for Julian Robertson "

The discovery and interrogatories in this case (05 CV 7036) by the defendants follow:

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
________________________________________________________________

JULIAN H. ROBERTSON, Jr. ) No. 05-CV-7046 Judge Preska

Plaintiff,

v. )
)
)
JOHN DOE a/k/a/ AL MARTIN, )
URI DOWBENKO, NATIONAL LIBERTY )
PRESS L.L.C., CONSPIRACY DIGEST )
L.L.C. )
)
________________ Defendants. )

DEFENDANTSí FIRST REQUEST FOR PRODUCTION OF DOCUMENTS AND THINGS TO PLAINTIFF JULIAN ROBERTSON

Pursuant to Rule 34 of the Federal Rules of Civil Procedure and the Local Civil Rules of the Southern and Eastern Districts of New York as well as the Court order of March 17, 2006, defendants requests that plaintiff Julian H. Robertson Jr. produce the following documents and things for inspection and copying at the offices of National Liberty Press LLC, within 30 days of service hereof.


DEFINITIONS AND INSTRUCTIONS
The following Requests should be responded to in accordance with the following Definitions and Instructions:

DEFINITIONS

1. Any reference to any entity or individual herein shall be construed to include all present and former subsidiaries, parents, affiliates, predecessors, successors, divisions, joint ventures, partners, officers, directors, board of directors (and committees thereof), employees, agents, advisors, websites owned or controlled by the entity or individual, and other persons acting or purporting to act for, or on behalf of, or in the name of such entity, including without limitation, consultants, brokers, bankers, financial advisors, attorneys, accountants and any other person of any description retained or employed by such entity for business or financial reasons of any kind.
2. The definitions and rules of construction set forth in Rule 34 of the Federal Rules of Civil Procedure and Local Civil Rule 26.3 are incorporated by reference into this document request. Please note that, pursuant to Local Civil Rule 26.3(c)(2), the term "document" includes, but is not limited to, electronic communications (e.g., email, instant messages, internet postings, etc . . .) and computerized data compilations.
INSTRUCTIONS
3. In producing the requested documents, you are directed to furnish all documents in your possession, custody, or control including, without limitation, documents in the possession, custody, or control of your present or former attorneys or their consultants or investigators, or in the possession, custody or control of your consultant, experts, advisors, agents, employees or associates.
4. For each document requested herein, which is sought to be withheld under a claim of privilege, or other objection, provide the following information:
(a) the nature of the privilege, e.g., work product, which is being claimed;
(b) the place, approximate date, and manner of recordation or preparation of the document;
(c) the name and title of the sender, and the name and title of each recipient of the document;
(d) the name of each person or persons (other than stenographic or clerical assistants) who participated in the preparation or creation of the document;
(e) the name and corporate position of each person to whom the contents of the document have heretofore been disclosed or communicated by copy, exhibition, reading or substantial summarization;
(f) the basis upon which the claim of privilege is asserted and whether or not the subject matter of the contents of the document is limited to legal advice or information provided for the purpose of securing legal advice;
(g) the number of the Document Request herein to which the document is responsive; and
(h) a brief description of the subject matter of the contents of the document.
6. If any document requested herein was formerly in your possession, custody, or control and has been lost or destroyed, or otherwise disposed of, you are requested to submit in lieu of any such document a written statement:
(a) describing in detail the nature of the document and its contents;
(b) identifying the person(s) who prepared or authored the document and, if applicable, the persons(s) to whom the document was sent, whether indicated thereon or by blind copies; and
(c) specifying the date(s) on which the document was prepared and transmitted; and specifying, if possible, the date on which the document was lost or destroyed and, if destroyed, the conditions of and reasons for such destruction and the persons requesting and performing the destruction.
7. This Request is a continuing one and any document obtained subsequent to production which would have been produced had it been available or its existence been known at the time of production specified herein is to be supplied forthwith.
8. You shall produce such documents either as they are kept in the usual course of business or shall organize and label them to correspond with the numbered
9. Unless specified otherwise, this document request applies for the time period January 1, 2000 to the present.

DOCUMENTS TO BE PRODUCED DOCUMENT REQUEST NO. 1

All documents sufficient to show affirmative proof of residency, citizenship and other information asserting the true residence of Julian H. Robertson including, but not limited to, documents reflecting Julian Robertsonís birth certificate, home address, place of employment, bank accounts, ownership of real property and social security number, as well as certified photocopies of driverís license(s) and all pages of last issued passport(s), voter registration card, tax returns from any and all countries wherein he pays taxes, including applicable employment forms and documents authenticating plaintiffís residence.

DOCUMENT REQUEST NO. 2

All documents showing real estate property taxes from 2000 till present in the United States and New Zealand.

DOCUMENT REQUEST NO. 3

All documents authenticating Julian Robertsonís most recent medical/ physical exam records, as well as mental health exam (mental component) certifying his ability to understand the lawsuit undertaken against defendants, as well as a list of all prescribed medications attributable to plaintiff during the last 3 years.

DOCUMENT REQUEST NO. 4

All email and other correspondence between Julian Robertson and his investors in which they ridiculed him or threatened to pull their investments out of his investment scheme(s) and hedge funds because of Al Martinís satirical column, as well as a list of all investors who removed their investments from Robertsonís management due to the Al Martin parody interview column of May 30, 2005, in which said investors reference Al Martinís column as a reason for removing their investments from Robertsonís management.

DOCUMENT REQUEST NO. 5

All pay stubs, IRS 1099 forms for the years 2000, 2001, 2002, 2003, 2004, and 2005 and other documents relating to subscribers and/or investors to Julian Robertsonís hedge funds and other investments managed by Julian Robertson, to show decrease in income due to Al Martinís satirical column of May 30, 2005.

DOCUMENT REQUEST NO. 6

All corporate filings, including annual reports, articles of incorporation, secretary of state filings financial statements and financial information relating to Julian Robertson, Tiger Management, Morgan Creek Management and any other companies that plaintiff controlled, including, but not limited to, documents reflecting the revenues, expenses, assets, liabilities, and capital structure of the plaintiff, as well as other investment corporations plaintiff has a position of director, corporate officer, senior management and or advisor in companies inside and/or outside of the United States.

DOCUMENT REQUEST NO. 7

Subscription and/or customer lists showing the identities and residences of investors of Tiger Management, Morgan Creek Asset Management and any other companies plaintiff has controlled, who pulled their assets out of Julian Robertson managed asset pools, investment companies and/or hedge funds.

DOCUMENT REQUEST NO. 8

Photocopies in your possession of all articles and interviews of and by plaintiff Julian Robertson, as published by newspapers, financial business journals, etc., as well as copies of all speeches, lectures, seminars given by plaintiff.



IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
________________________________________________________________

JULIAN H. ROBERTSON, Jr. ) No. 05-CV-7046 Judge Preska
)
Plaintiff, )
)
v. )
)
)
JOHN DOE a/k/a/ AL MARTIN, )
URI DOWBENKO, NATIONAL LIBERTY )
PRESS L.L.C., CONSPIRACY DIGEST )
L.L.C. )
)
________________ Defendants. )

DEFENDANTSí FIRST SET OF INTERROGATORIES
TO PLAINTIFF JULIAN ROBERTSON
Pursuant to Rule 33 of the Federal Rules of Civil Procedure and the Local Civil Rules of the Southern of New York as well as the Courtís order of March 17, 2006, defendants Conspiracy Digest L.L.C., National Liberty Press L.L.C. (the "Corporate Defendants"), and Uri Dowbenko hereby request that plaintiff Julian Robertson serve upon Defendant sworn Answers to the Interrogatories set forth below by or before thirty (30) days after service hereof.

DEFINITIONS AND INSTRUCTIONS
The Interrogatories should be responded to in accordance with the following Definitions and Instructions:

DEFINITIONS
1. Any reference to any entity or individual herein shall be construed to include all present and former subsidiaries, parents, affiliates, predecessors, successors, divisions, joint
ventures, partners, officers, directors, board of directors (and committees thereof), employees, agents, advisors, websites owned or controlled by the entity or individual, and other persons acting or purporting to act for, or on behalf of, or in the name of such entity, including without limitation, consultants, brokers, bankers, financial advisors, attorneys, accountants and any other person of any description retained or employed by such entity for business or financial reasons of any kind.
2. The definitions and rules of construction set forth in Rule 34 of the Federal Rules of Civil Procedure and Local Civil Rule 26.3 are incorporated by reference herein. Please note that, pursuant to Local Civil Rule 26.3(c)(2), the term "document" includes, but is not limited to, electronic communications (e.g., email, instant messages, internet postings, etc.) and computerized data compilations.
3. Unless specified otherwise, these interrogatories apply for the time period January 1, 2000 to the present.

INSTRUCTIONS
1. In each instance where an Interrogatory is answered on information and belief, you are requested to set forth the basis for such information and belief.
2. In each instance where you deny knowledge or information sufficient to answer the Interrogatory, it is requested that you set forth the name and address of each person, if any, known to have such knowledge.
3. In each instance where the existence of a document is disclosed, you are requested to attach a copy of such document to your answer. If such document is not in your possession, custody or control, it is requested that you state the name and address of each person known to you to have possession, custody, or control of such document, and identify which documents are in such person's possession, custody, or control.

INTERROGATORIES INTERROGATORY NO. 1

How and when did plaintiff Julian Robertson become aware of the subscriber-only satirical column written by Al Martin and published on Al Martin Raw.com subscriber-only website on May 30, 2005? Who or what was the source for plaintiffís receipt of Al Martinís column parodying plaintiffís CNBC interview with Ron Insana?

INTERROGATORY NO. 2

How many lawsuits has plaintiff Julian Robertson filed against other publications for alleged ďdefamationĒ and/ or other reasons? Please state case number and court order and /or resolutions of case(s).

NTERROGATORY NO. 3

Regarding the years 2000-2005, what sources of income did plaintiff Julian Robertson have and where were they derived from?

INTERROGATORY NO. 4

Please identify the investors of Tiger Management, Morgan Creek Asset Management, Julian Robertson and any other companies controlled by plaintiff, and state the amount of revenue or income received by the plaintiff from such investments. Also please include the time when investors entered into plaintiffís investment program and when the investors left the program.

INTERROGATORY NO. 5

Please identify the total revenues and income derived by plaintiff from Tiger Management and Morgan Creek Management, as well as his business in New Zealand, but not limited to wineries, golf courses, real estate development as well as other investments, showing income allegedly lost due to Al Martinís satirical column of May 30, 2005.

INTERROGATORY NO. 6

Over the past 2 years, how much time has plaintiff devoted to financial management and how much time was devoted to other endeavors?

INTERROGATORY NO. 7

Please list all real properties owned by plaintiff Julian Robertson, singularly and by entirety (wife and children) inside and outside of the United States, as well as all real properties held in trust by plaintiff as donor, grantor, trustee and / or beneficiary.

INTERROGATORY NO. 8

Please list plaintiffís fee management structure with Tiger Management and Morgan Creek Management, and any and all fee structure changes for plaintiffís management of Tiger, Morgan Creek, et al, including the dates of the changes.

INTERROGATORY NO. 9

With respect to each and every one of the forgoing Interrogatories and the subparts thereof, please (a) identify each person from whom information was obtained to answer each Interrogatory;
(b) identify the person(s) who gathered the information used in preparing your answers to these Interrogatories;
(c) identify the person who prepared and/ or participated in the preparation of the answer to each Interrogatory;(d) identify the person(s) having responsibility for verifying the accuracy of your answers to these Interrogatories; (e) identify the documents and records consulted to obtain such information; and (f)where no information or only partial information is given in such an answer, a description of the efforts made to locate information needed for such an answer.

* URI DOWBENKO is the author of "Bushwhacked: Inside Stories of True Conspiracy" and "Hoodwinked: Watching Movies with Eyes Wide Open." His new DVD is called "One Nation Under Fraud" He can be reached at u.dowbenko@lycos.com His website is UriDowbenko.Com

For more information on Dowbenko's articles and samples of chapters from his books Bushwhacked & Hoodwinked"


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