Discovery questions for Tom Heysek (penny stock junk faxes)
From Steve Kirsch’s site:
“1) Documents prior to July 15 showing contact with Worldwide Picks, LTD or Winning Stock Picks including bank statements showing deposits, e-mails, phone calls, letters, and employment or consulting agreements.
2) Any and all documents that identify the fax broadcaster or broadcasters used to send faxes mentioning any company featured on the Winning Stock Picks web site (see attached for additional requests).
3) Any document showing the date that Defendant was first contacted by any individual associated with Worldwide Picks, LTD or Winning Stock Picks.
4) Any and all brokerage statements in May, June or July 2004 showing trading activity in any stock promoted on winningstockpicks.net (including TWTN, BDYS, AHFI, GBEB aka APNJ, CNDD, SGNJ) in any brokerage or trading account of which Defendant has a beneficial interest
...”
There are 24 questions and I doubt that Heysek will want to provide many of the requested documents.
Of course I have many of Heyseks faxes and I named him and several of the companies involved. Just don’t have time to pursue everybody ...
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