Hi Folks,
Here is a list of the types of questions and answers that a person anticipating a " pro se" defence would request of DTV by way of discovery, long beore reaching any court.
This information and much other information that can be very useful is posted on my legal-rights site at:
http://www.legal-rights.org/dtv/DTVDone/DTVINFOETC.html
and I am sure that people will find much of the info posted there, very useful to your defence.
When you get down to the short curlies and the real details like this on discovery requests, Interrogatory's, requests for admissions and requests for production of evidence, it becomes clear just how little of these critically important questions DTV cannot answer. Right from the "git-go" it becomes quite apparent that they DO NOT have the goods on you and were relying on the "mere possession" argument for their entire prosecution. This is what was scaring end users into making settlements. But now that many courts have ruled AGAINST the "mere possession " argument, DTV are not in very good shape when it comes down to the detailed facts. Look at the questions here and remember that you will also want to make requests of other important things that pertain to YOUR actual case. That could even make them look worse.
Ïolks its time to STOP being bamboozled into making a settlement and find that you can defend against this for MUCH less than a settlement would cost you. Seriously its time to consider a different course of action than the settlements.http://www.legal-rights.org/images/ttrk.gif
DISCOVERY REQUESTS
INTERROGATORY NO. 1:
State the names of each person answer or assisting in answering each of the following discovery requests, their position with you, and the discovery requests they assisted in answering.
RESPONSE:
INTERROGATORY NO. 2:
State the “other information” you relied upon, as referenced in Paragraph 7 of Plaintiff’s Original Complaint, that you contend forms evidentiary support for your allegations that [NAME] accessed Direct TV’s programming without permission and/or payment to Direct TV.
RESPONSE:
INTERROGATORY NO. 3:
State the factual basis for your contention that [NAME] used the items described in Paragraph 24 of Plaintiff’s Original Complaint to access Direct TV’s programming without permission and/or payment to Direct TV.
RESPONSE:
INTERROGATORY NO. 4:
State the factual basis for your contention in Paragraph 28 of Plaintiff’s Original Complaint that [NAME] “may have been engaged in an enterprise to distribute and/or resell the devices” identified in Paragraph 24 of the Compliant.
RESPONSE:
INTERROGATORY NO. 5:
If you contend that [NAME] acted in concert with any other person to carry one or more of the actions alleged in Plaintiff’s Original Complaint: (1) identify such person(s); and, (2) state the factual basis for such contention(s).
RESPONSE:
INTERROGATORY NO. 6:
Identify the satellite reception equipment that you contend [NAME] used to intercept or otherwise view or display your satellite signals.
RESPONSE:
INTERROGATORY NO. 7:
If you have identified any satellite reception equipment in response to the preceding interrogatory, state the factual basis for your contention that such equipment was used by [NAME] used improperly or illegally to intercept or otherwise view or display your satellite signals.
RESPONSE:
INTERROGATORY NO. 8:
Identify all software, including but not limited to “SU2 Code,” that you contend [NAME] used improperly or illegally to intercept or otherwise view or display your satellite signals.
RESPONSE:
INTERROGATORY NO. 9:
Identify all computer or electronic data processing equipment, other than the items identified in Paragraph 24 of Plaintiff’s Original Complaint, that you contend [NAME] used improperly or illegally to intercept or otherwise view or display your satellite signals.
RESPONSE:
INTERROGATORY NO. 10:
Identify all other electronic equipment, other than that identified in response to the preceding three (3) interrogatories that you contend [NAME] used to intercept or otherwise view or display your satellite signals.
RESPONSE:
REQUEST FOR ADMISSION NO. 1:
Admit that [NAME] would be unable to use the items described in Paragraph 24 of Plaintiff’s Original Complaint to decrypt or otherwise intercept or otherwise view or display your satellite signals without satellite reception equipment.
RESPONSE:
REQUEST FOR ADMISSION NO. 2:
Admit that [NAME] would be unable to use the items described in Paragraph 24 of Plaintiff’s Original Complaint to decrypt or otherwise intercept or otherwise view or display your satellite signals without additional software to program such items and to program a Direct TV access card.
RESPONSE:
REQUEST FOR ADMISSION NO. 3:
Admit that [NAME] would be unable to use the items described in Paragraph 24 of Plaintiff’s Original Complaint to decrypt or otherwise intercept Direct TV’s satellite programming without additional computer or electronic data processing equipment.
RESPONSE:
INTERROGATORY NO. 11:
State the factual basis for your allegation in Paragraph 31 of Plaintiff’s Original Complaint that [NAME] “use[d] illegal satellite decoding devices, or by manipulation of the satellite system authorized to carry the Satellite Programming where Defendant [is] located.”
RESPONSE:
INTERROGATORY NO. 12:
Identify each Direct TV program that you contend [NAME] viewed or displayed without payment to Direct TV.
RESPONSE:
INTERROGATORY NO. 13:
State the factual basis for your contention that [NAME] viewed or displayed the programs identified in response to the preceding interrogatory.
RESPONSE:
INTERROGATORY NO. 14:
State the factual basis for your contention that the devices described in Paragraph 2 of Plaintiff’s Original Complaint were “primarily designed to gain unauthorized access to [Direct TV’s] satellite communication signals.”
RESPONSE:
REQUEST FOR ADMISSION NO. 4:
Admit that the items described in Paragraph 24 of Plaintiff’s Original Complaint are ISO-7816 compliant programmers and/or programmable programmers.
RESPONSE:
INTERROGATORY NO. 15:
If your response to the preceding interrogatory is other than an unqualified admission, state the factual basis for your contention that the items described in Paragraph 24 of Plaintiff’s Original Complaint are not ISO-7816 compliant programmers and/or programmable programmers.
RESPONSE:
REQUEST FOR ADMISSION NO. 5:
Admit that the items described in Paragraph 24 of Plaintiff’s Original Complaint can be used to program ISO-7816 “smart card” devices other than Direct TV access cards.
RESPONSE:
INTERROGATORY NO. 16:
If your response to the preceding interrogatory is other than an unqualified admission, state the factual basis for your contention that the items described in Paragraph 24 of Plaintiff’s Original Complaint cannot by used to program ISO-7816 “smart card” devices other than Direct TV access cards.
RESPONSE:
INTERROGATORY NO. 17:
Identify, by cause number, court and first named defendant, all civil actions in which you have alleged a civil cause of action exists in your favor under 18 U.S.C. § 2512.
RESPONSE:
REQUEST FOR PRODUCTION NO. 1:
For the civil actions listed in response to the preceding interrogatory, produce copies of all orders and
memoranda of each court denying the existence of a civil cause of action under 18 U.S.C. § 2512, without regard to whether such orders were final, interlocutory or on appeal.
RESPONSE:
REQUEST FOR PRODUCTION NO. 2:
Produce all “shipping records, email communications, credit card receipts and other records” referred to in Paragraph 7 of Plaintiff’s Original Complaint that you contend demonstrate or tend to demonstrate that [NAME] purchased the items described in Paragraph 24 of Plaintiff’s Original Complaint.
RESPONSE:
REQUEST FOR PRODUCTION NO. 3:
Produce the technical specifications for the items described in Paragraph 24 of Plaintiff’s Original Complaint.
RESPONSE:
REQUEST FOR PRODUCTION NO. 4:
Produce all photographs or other images of the items described in Paragraph 24 of Plaintiff’s Original Complaint.
RESPONSE:
REQUEST FOR PRODUCTION NO. 5:
Produce the “SU2 Code” described in Paragraph 24 of Plaintiff’s Original Complaint.
RESPONSE:
REQUEST FOR PRODUCTION NO. 6:
Produce all software that you contend [NAME] used to program Direct TV access cards or other access devices.
RESPONSE:
REQUEST FOR PRODUCTION NO. 7:
Produce all correspondence between yourself and [NAME]
RESPONSE:
REQUEST FOR PRODUCTION NO. 8:
Produce all correspondence between yourself and any other defendant in this civil action.
RESPONSE:
[END OF DOCUMENT]
In the actual document that you send them BE SURE to leave about 20 times the space you used in the question for their answer. Later when this document looks empty because they have few if any answers, it will look even better for you. Go get em guys.
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Thanks & Good Luck ,
<a href="mailto:ttrk@legal-rights.org"><font color="#FF0000" size="5"><strong><u>To </u></strong></font><font color="#FF4800" size="5"><strong><u>Th</u></strong></font><font color="#FF6200" size="5"><strong><u>e </u></strong></font><font color="#FF7002" size="5"><strong><u>RE</u></strong></font><font color="#FF9006" size="5"><strong><u>AL </u></strong></font><font color="#FFB508" size="5"><strong><u>Ki</u></strong></font><font color="#FFD014" size="5"><strong><u>ng!!</u></strong></font></a>
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