REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: All contracts and agreements between GSA and Jevin, Inc.
RESPONSE:
REQUEST NO. 2: All financial records showing all payments by Jevin, Inc. to GSA.
RESPONSE:
REQUEST NO. 3: All financial records that reflect slow payments, missed or missing
payments, and overcharges by Jevin, Inc. to GSA.
RESPONSE:
REQUEST NO. 4: With respect to any slow payments, missed or missing payments and
overcharges to GSA by Jevin, Inc, all correspondence, including email between (a) GSA, David
Arciniega, Paula Tiffin, or Sam Perry on one hand, and (b) Jevin, Inc. or its owner Daniel Ptak
on the other hand.
RESPONSE:
REQUEST NO. 5: All documents, materials, correspondence and emails that were made
available to GSA member coaches related to slow payments, missed or missing payments, and
overcharges to GSA by J evin, Inc.
RESPONSE:
REQUEST NO. 6: All documents, materials, correspondence and emails that were provided to
the GSA Board by GSA's Executive Committee, office manager, President, or Treasurer related
to slow payments, missed or missing payments, and overcharges by Jevin, Inc. to GSA.
RESPONSE:
REQUEST NO. 7: All documents, materials, correspondence and emails reflecting all the
financial records that were made available to North Texas State Soccer Association concerning
any slow payments, missed or missing payments, and overcharges by Jevin, Inc. to GSA.
RESPONSE:
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REQUEST NO. 8: All correspondence, including email, between or among (a) David
Arciniega, Sam Perry, Paula Tiffin, Heather Dobrott or any other member of GSA on one hand
and (b) North Texas State Soccer Association on the other hand concerning the slow payments,
missed or missing payments and overcharges by Jevin, Inc. to GSA.
RESPONSE:
REQUEST NO. 9: All documents reflecting reports or complaints made to law enforcement
concerning missing money from the GSA spring 2013 soccer season as discussed in the June 30,
2013 GSA Executive Committee Meeting minutes.
RESPONSE:
REQUEST NO. 10: All documents and correspondence, including email, that reflect that the
payment processor Corduro, Inc. was responsible for any missing funds owed by Jevin, Inc. to
GSA.
RESPONSE:
REQUEST NO. 11: All documents and correspondence, including email, that reflect Jevin, Inc.
sought and was not approved for a loan to cover the missing funds owed by Jevin, Inc. to GSA.
RESPONSE:
REQUEST NO. 12: All documents and correspondence that reflect that a lawsuit had been
filed by Jevin, Inc. and/or Daniel Ptak against Corduro, Inc. as David Arciniega told the GSA
members verbally in September 2013 and in the minutes published in the November 2013
coaches' letter.
RESPONSE:
REQUEST NO. 13: All documents that pertain to the $50,000.00 in total losses that David
Arciniega claimed during a GSA Board Meeting that Jevin, Inc. suffered due to Corduro, Inc.
handling the payments for various entities, including but not limited to GSA, which entities
used/use the Jevin, Inc. software.
RESPONSE:
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REQUEST NO. 14: All correspondence, including email between (a) GSA or North Texas
State Soccer Association on one hand and (b) Corduro, Inc. on the other hand.
RESPONSE:
REQUEST NO. 15: All documents and correspondence, including email, that reflect any work
David Arciniega performed for Jevin, Inc.
RESPONSE:
REQUEST NO. 16: All documents and correspondence, including email, related to any
contract or agreement between Jevin, Inc. and GSA.
RESPONSE:
REQUEST NO. 17: All contracts or agreements between Jevin, Inc. and David Arciniega.
RESPONSE:
REQUEST NO. 18: All documents and correspondence, including email, related to any
contracts between Jevin, Inc. and David Arciniega.
RESPONSE:
REQUEST NO. 19: All correspondence, including email, between David Arciniega and the
NTSSA lawyer(s) concerning any slow payments, missed or missing payments or overcharges
by Jevin, Inc. to GSA.
RESPONSE:
REQUEST NO. 20: All correspondence, documents, and evidence that reflect that Heather
Dobrott instructed in the placement of Coach Dan Medina and his son on the same GSA team as
stated in the charges filed against her by David Arciniega.
RESPONSE:
REQUEST NO. 21: All documents that reflect the A & D (Appeals & Discipline) process as it
is carried out by GSA.
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RESPONSE:
REQUEST NO. 22: All documents that reflect the A & D (Appeals & Discipline) process as it
is carried out by NTSSA.
RESPONSE:
REQUEST NO. 23: All documents and correspondence, including email, between or among
David Arciniega and/or Kimberley Lawrence Verity and NTSSA related to the charges that
Plaintiff and her fellow GSA Director instructed in the placement of a coach and his son on the
same GSA team.
RESPONSE:
REQUEST NO. 24: All communications, including email, between GSA and Coach Dan
Medina regarding his son's placement on the same GSA team coached by Dan Medina.
RESPONSE:
REQUEST NO. 25: All GSA policies and procedures related to GSA "board hearings,"
including but not limited to the proper channels of appeal for this alleged procedure.
RESPONSE:
REQUEST NO. 26: All GSA policies and procedures regarding a No Confidence Vote.
RESPONSE:
REQUEST NO. 27: All No Confidence petitions filed against David Arciniega and Heather
Dobrott.
RESPONSE:
REQUEST NO. 28: All correspondence, including email, between (a) Kimberly Lawrence
Verity or David Arciniega on one hand and (b) NTSSA on the other hand concerning the No
Confidence petitions filed against Mr. Arciniega and Heather Dobrott.
RESPONSE:
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REQUEST NO. 29: All other correspondence, including email, regarding the No Confidence
petitions filed against David Arciniega and Heather Dobrott.
RESPONSE:
REQUEST NO. 30: All documents which reflect that contacting NTSSA for an appeal,
grievance, question, or help is an appropriate grounds for a GSA No Confidence vote.
RESPONSE:
REQUEST NO. 31: All documents reflecting that a GSA Board Member's vote at a regularly
scheduled meeting is appropriate grounds for a GSA No Confidence vote.
RESPONSE:
REQUEST NO. 32: All documents reflecting that a GSA member coach or GSA Director's
vote for a candidate not currently in office for a GSA board position is appropriate grounds for a
GSA No Confidence vote.
RESPONSE:
REQUEST NO. 33: All documents related to the training and orientation of new Board
Members of GSA during the last three years.
RESPONSE:
REQUEST NO. 34: All documents reflecting the GSA protocol, policies, and procedures for the
use of proxies at GSA meetings and elections.
RESPONSE:
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