Subpoena

it) (Rev, 04/07) Subpoena to Testify Before Grand Jury UNITED STATES DISTRICT COURT Northern DISTRICT OF Ohio TO: Summii County I SUBPOENA TO TESTIFY Custodian of Records - BEFORE GRAND JURY SUBPOENA FOR: Cl PERSON El DOCUMENTKS) OR YOU ARE HEREBY COMMANDED to appear and testify before the Greed ury of the United States District Court at the place, date, and time speci?ed beiow. PLACE COURTROOM Grand Jury Suite, Lower Levei 1 Carl B. Stokes U.S. Courthouee ?80? W. Superior Avenue DATE AND TIME Cievetand, Ohio 44113 11/18/2034 9:99 am YOU ARE ALSO COMMANDED to bring with you the following documen?s) or Please see attachment, DO NOT SEND RECORDS TO THE US. ATTORNEYS OFFICE YOU MAY SEND THE REQUESTED RECORDS, PREFERABLY IN ELECTRONIC FORMAT ON CD, VIA EXPRESS MAIL, OR OVERNIGHT DELIVERY SERVICE DIRECTLY TO SPECIAL AGENT CHRISTOPHER FASSLER, FEDERAL BUREAU OF INVESTIGATION, 222 SOUTH MAIN STREET, SUITE 210, AKRON, OHIO 44303, OR IN ELECTRONIC FORMAT VIA TO AND THEREBY AUTHORIZE THE SPECIAL AGENT TO THE DOCUMENTS TO THE GRAND JURY ON YOUR BEHALF. Ci Please see additional information on reverse. This subpoena shall remain in effect until you are granted leave to depart by the court or by an of?cer acting on behaif of the court. I 9.155 9? CLERK DATE M. SMETH 10/28/2014 (By) Deputy Clerk T. Jeffrey Miller I NAME, ADDRESS AND PHONE NUMBER OF ASSISTANT Us. ATTORNEY T311: Slgp,?egasist135ugfd?n aEPhC'mon Antoinette T. Bacon, Assistant U.S. Attorney 0 6 mm 3 es 0 mama 400 United States Courthouse, 801 West Superior Avenue Cleveland, Ohio 44113 - Telephone: (216) 622-43956 Special Agent Christopher Fassler Telephone: (330) 258-4107 If not appiicabie: enter 2013mm 124 Subpoena Attachment Summit County Unless otherwise noted, the time period is January 1, 2013 to present. 1. All documents re?ecting Tamela Lee?s schedule. This includes, but is not limited to, calendars, invitations, event agendas, emails discussing Lee?s whereabouts, and travel reimbursement requests. All personnel records for Tarnela Lee. This includes, but is not limited to, payroll information. All documents related to any character reference made by or on behalf of Tarnela Lee. This includes, but is not limited to, communications between Lee and Kent Starks related to the character reference. All documents re?ecting communications between Tamela Lee and a constituent. This includes, but is not limited to, email, notes, letters, and communications made related to the constituent request. This includes all communications between Lee and Kent Starks related to constituent communications. All documents relating to Tamela Lee?s effort to in?uence any judicial proceeding. This includes, but is not limited to, documents re?ecting case numbers, parties to a lawsuit or criminal case, notes regarding the nature of the case, any document that re?ects communication with court staff, such as a bailiff, judge, or judicial clerk. This does not include any matter to which Summit County was a party and on which Lee participated in her role as a member of County Council. All documents relating to Tamela Lee?s effort to in?uence any law enforcement deCision. This includes, but is not limited to, documents re?ecting communications with law enforcement and prosecutors, notes regarding the nature of any matter, and reports and documents created in relation to such matter. All documents related to Tamela Lee?s effort to in?uence any administrative agency, such as Summit County Children Services or a state licensing agency. This includes, but is not limited to, documents re?ecting case numbers, parties to an action, notes regarding the nature of the issue, and any document that re?ects a communication with agency staff. 1 All documents related to things of value offered to, provided to, or solicited by Tamela Lee. This includes, but is not limited to, loans, gifts, employment agreements, and campaign contributions. All documents related to the following family names: A. Abdelqader B. Albanna C. Hamed D. Alha} Mohd DEFINITIONS A. ?Communication? means any disclosure, transfer, or exchange of information, however made, including oral, electronic, or written. ?Document? means the original of any written, recorded, or graphic material, whether prepared by You or by any other person, that is in Your possession, custody, or control, including but not limited to: memoranda, reports, letters, telegrams, electronic mail, Personal Digital Assistants (PDAs), other electronic correspondence, and other communications recorded in any form or medium; notes, minutes, and transcripts of conferences, meetings and telephone or other communications; contracts and other agreements; checks, check registers, statements, ledgers, and other records of ?nancial matters or commercial transactions; appointment books, calendars, notebooks, and diaries; maps, diagrams, graphs, charts, and other drawings; plans and speci?cations; publications; photographs; photocopies, micro?lm, and other copies or reproductions; tapes, disks, and other electronic recordings; computer printouts; tallies, tabulations, and summaries of sales or bids; and all file folders, ?le tabs, folder tabs, mailing envelopes, facsimile transmission cover sheets, and any other proof or indicia of mailing (if applicable) associated with each original. The term "document" includes all drafts of a document, including all copies that differ in any way from the original (including any notations, underlining, or other markings). he term "document" includes all information stored in machine-readable form or accessible through computer or other information retrievai systems, together With instructions and all other materials necessary to use or interpret such information. "Person" means any natural person, association, cooperative, public or private corporation, joint venture, partnership, sole proprietorship, governmental entity, or other form of business or legal entity. ?Relate to? or "relating to? means directly or indirectly refer or pertain to, discuss, describe, re?ect, contain, examine, analyze, study, report on, comment on, evidence, constitute, Show, consider, recommend, concern, record, or set forth, in whole or in part. ?You? or "Your Company" means the person to whom this subpoena is addressed; any parent, predecessor, successor, division, af?liate, or subsidiary (whether wholly owned or not) of that person; any joint venture to which any such person is or was a party; and each officer, director, manager, partner, employee, attorney, agent, representative, consultant, af?liated person, or other person acting on behalf of any of them. All documents produced must be originals, unless otherwise indicated. Photocopies will be accepted only after demonstrating that the originals are unavailable. Use of the singular or the plural in this subpoena should not be deemed a limitation, and the use of the singular should be construed to include, where appropriate, the plural. The conjunctive form ?and? and the disjunctive form ?or? are mutually interchangeable and encompass each other. The terms "any" and ?all? are mutually interchangeable and encompass each other. For each document or portion thereof withheld under a claim of privilege, You must submit a sworn or certi?ed statement containing a statement of the basis on which the privilege is claimed and identifying: the paragraph in this schedule of documents to which the document is responsive; the author, date, number of pages and subject matter of the withheld document; each person to whom the withheld material was sent; and each person to whom the withheld material or its contents, or any part thereof, was disclosed. Any document or part of a document withheld under a claim of privilege must be preserved. if any portion of any document is responsive to any paragraph, then the entire document must be produced, including all supporting, underlying, or explanatory documents and all attached, annexed, or appended documents. If a document contains privileged material, the entire document must be produced, with the privileged material redacted and documented as set forth above. Documents that in their original condition were stapled, clipped, or otherwise fastened together should be produced in such form. Documents should not be shuf?ed or otherwise rearranged, but should be produced in the order in which they appear in Your files. You should identify with your initials each document produced, and consecutively number each document produced. Your initials and numbers should appear in the lower right?hand corner of each page, in a location that does not obscure any information on the document. The definition of "document," as used in this Schedule, includes data stored in any electronic form. You should immediately take the following steps to ensure that it preserves all types of electronic data inany location within the computer systems that may be responsive to the subpoena: All data that are stored electronically must be produced in an electronic format. You must contact the attorneys for the government to determine, with the assistance of the appropriate government technical of?cials, whether the proposed data formats and choice of media will be compatible with government equipment and resources that are available to the grand jury. NOTICE: Any person who withholds, alters or destroys documents demanded by this subpoena may be subject to criminal prosecution for obstruction ofjostice, contempt of court or other federal crimes. Conviction of any of these offenses is punishable by substantial fines, imprisonment, or both. CERTTETCATE OF AUTHENTICITY OF BUSINESS RECORDS l, declare, pursuant to Title 28, U.S.C. 1746; (Name) that I am employed by and that (Name of Business) my of?cial title or position is . I further (Of?cial Title or Position) declare that I am a custodian of records of said business and that each of the records attached hereto is the original or a duplicate (exact photocopy) of an original record in the custody of (Name of Business) I further state that: A) such records were made, at or near the time of the occurrence of the matters set forth, by (or from information transmitted by) a person with knowledge of those matters; B) such records were kept in the course of a regularly conducted business activity; C) the business activity made such records as a regular practice; and D) if such record is not the original, such record is a duplicate of the original. I declare under penalty of perjury that the foregoing is true and correct. (Signature) (Date of Execution) (Place of Execution)