Cause No. 2017-50825
EcoHub, LLC (for itself and as an assignee
of EcoHub-Houston, LLC); Dolcefino
Communications, LLC d/b/a Dolcefino
Consulting; and Wayne Dolcefino, in his
individual capacity,
Petitioners,
v.
City of Houston, Texas,
Respondent.

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In the District Court

of Harris County, Texas

11th Judicial District

Exhibit A to Subpoena for Documents to Maya Ford and Ford Momentum!
TO:

Maya Ford, individually and as the registered agent of Ford Momentum, LLC, 405 Main
St. Suite 701, Houston, Texas 77002 or 2620 Oakdale Street, Houston, TX 77004
DEFINITIONS AND INSTRUCTIONS
Petitioner Wayne Dolcefino (“Dolcefino”) sets forth the following definitions or

abbreviations of various words and phrases upon Maya Ford (hereinafter “the Deponent”) for the
purpose of clarifying the meaning of various words and phrases contained in this document so as to
expedite discovery, i.e., to help the Deponent fully and accurately understand the objectives of
Dolcefino’s discovery efforts while assisting the Deponent’s efforts to locate and furnish the
relevant information. Dolcefino incorporates the attached definitions into these Requests and relies
on these definitions to clarify the language contained herein.
1.

“EcoHub” means EcoHub – Houston, LLC, EcoHub, Inc. and EcoHub, LLC, and its
agents and employees.

2.

“Ford”, “Deponent,” “You,” or “Your” means Maya Ford, as well as the agents and
employees of her company Ford Momentum!

3.

The “City” means the City of Houston, as well as its agents and employees.

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 4.

The “Mayor” means Mayor Annise Parker or Mayor Sylvester Turner of the City of
Houston, as well as all agents or employees who worked in the Mayor’s office at the time
of the events described below, including, but not limited to, Sylvester Turner, Andy Icken,
Christon Butler, Alison Brock, Harry Hayes, or Keith Edgar.

5.

The “Petition” means the legal proceeding that is identified at the top of page 1 of this
Exhibit A.

6.

The term “document” means and includes each and every medium upon which
information is or can be printed, recorded, or reproduced by mechanical means, by hand
or by any other method, that is within Your possession, custody, control, including,
without limitation, agreements; brochures; computer records or printouts;
communications; contracts; correspondence; diaries; drafts; ELECTRONIC MAIL
MESSAGES AND TEXT MESSAGES [WHETHER ACTIVE, ARCHIVED, OR
DELETED]; files; magnetic tapes, cards, or discs or other products of any device for
recording sound or electronic data; memoranda; minutes or other records of meetings or
conferences; stenographic or handwritten notes; stenographic or wire or magnetic
recordings; summaries or records of conversations of interviews or telephone
conversations; summaries or reports of investigations or negotiations; text, SMS or MMS
messages, Instant Messages, videotapes; or voice recordings in any form. The term
“document” also includes the original and every copy which is not identical to the
original, specifically including every copy which contains any commentary or notation
whatsoever that does not appear on the original. The term “document” also includes all
drafts of each of the above. The term does NOT include any document protected by
applicable privileges from discovery.

7.

The term “computer data” means and includes any “electronic or magnetic” data as that
term is used in TEX. R. CIV. P. 196.4.

8.

The term “all documents” does not include multiple, identical copies of the same
document.

9.

“Communication” means any oral or written utterance, notation, or statement of any
nature whatsoever, by and to whomsoever made including, but not limited to,
correspondence, conversations, dialogues, discussions, interviews, consultations,
agreements, and other understandings between or among two or more persons.

10.

“Person” or “persons” means not only natural persons, but also corporations,
partnerships, organizations, associations, industry groups, entities, joint venturers, or any
government or governmental entity, commission, or agency and any divisions or
departments or other units of any of the entities defined herein.

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 ADDITIONAL INSTRUCTIONS
1.

Ambiguity. To avoid ambiguity, significant effort has been spent to define a number of
terms used in the following discovery requests. If the Deponent or the Deponent’s
attorney claim that the Deponent does not understand the meaning of a term, please refer
to the list of definitions or contact the counsel for Dolcefino for clarification.

2.

Rule 196.4 – Electronic or Magnetic Data. Consistent with TEX. R. CIV. P. 196.4,
whenever Dolcefino requests production of “computer data,” or any documents or
computer data or data responsive to these Requests are in electronic or magnetic form,
Dolcefino would like the data produced in hard copy form, as well as in its “native”
electronic or magnetic form.

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 EXHIBIT A TO SUBPOENA DUCES TECUM
DOCUMENTS REQUESTED
PLEASE PRODUCE THE FOLLOWING DOCUMENTS OR COMPUTER DATA:
1.

A copy of any documents, communications or computer data that comprise
communications or correspondence (including email communications or
text/SMS/MMS messages communications) that any agent or employee of the
Deponent sent to or received from the Mayor, or any officer, director or employee of
the Mayor, from January 1, 2013 to November 3, 2017, to the extent that such
communications relate to or mention recycling of trash in the City of Houston, or any
entity which offers waste management or garbage collection services

2.

A copy of any documents, communications or computer data that comprise
communications or correspondence (including email communications or
text/SMS/MMS messages communications) that any agent or employee of the
Deponent sent to or received from the Mayor, or any officer, director or employee of
the Mayor, from January 1, 2013 to November 3, 2017, to the extent that such
communications relate to or mention Harry Hayes.

3.

A copy of any documents, communications or computer data that comprise
communications or correspondence (including email communications or
text/SMS/MMS messages communications) that any agent or employee of the
Deponent sent to or received from the Mayor, or any officer, director or employee of
the Mayor, from January 1, 2013 to November 3, 2017, to the extent that such
communications relate to or mention EcoHub, George Gitschel or Wayne Dolcefino.

4.

A copy of any documents, communications or computer data that comprise
communications or correspondence (including email communications or
text/SMS/MMS messages communications) that any agent or employee of the
Deponent sent to or received from the Mayor, or any officer, director or employee of
the Mayor, from January 1, 2013 to November 3, 2017, to the extent that such
communications relate to or mention the Petition or the Texas Public Information Act.

5.

A copy of any documents, communications or computer data that comprise
communications or correspondence (including email communications or
text/SMS/MMS messages communications) that any agent or employee of the
Deponent sent to or received from the Mayor or the email address of
sturner@barnesturner from January 1, 2013 to November 3, 2017, to the extent that
such communications relate to or mention (a) recycling of trash in the City of
Houston or any entity which offers waste management or garbage collection services;
(b) Harry Hayes; (c) EcoHub, George Gitschel or Wayne Dolcefino; (d) the Petition
or the Texas Public Information Act.

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