STEVEN T. ADAMS (SBN 130846)
JAMES D. HEPWORTH (SBN 132910)
ADAMS, HALL & HEPWORTH
1299 Ocean Avenue, Suite 900
Santa Monica, CA 90401
Telephone: (310) 260-8801
Facsimile: (310) 260-8802

Attorneys for Plaintiff Gold &
Silver Reserve, Inc.

SUPERIOR COURT FOR THE STATE OF CALIFORNIA

FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT

TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:

PLEASE TAKE NOTICE that beginning on September 13, 2001 at 9:00 a.m. and continuing on September 14, 2001 at 9:00 a.m., and continuing day to day thereafter until completed, weekends and holidays excepted, at the offices of Adams, Hall & Hepworth, 1299 Ocean Avenue, Suite 900, Santa Monica, CA 90401 (310) 260-8801, Plaintiff will take the deposition of defendant Charles Evans.

The deposition will be taken upon oral examination before a Notary Public and Shorthand Reporter in accordance with and pursuant to California Code of Civil Procedure ¤¤ 2019, 2021, and 2025, and ÿ California Evidence Code ¤ 776. Pursuant to California Code of Civil Procedure ¤ 2025 (d) (5), Plaintiffs intend to record the testimony of the witness by stenographic method, through the instant visual display of the testimony.

DEFINITIONS

1. The term "'DOCUMENT" includes all "writings" as that term is defined in California Evidence Code ¤ 250. ""DOCUMENT" shall include, without limitation, all written, typed or otherwise preserved materials or COMMUNICATIONS including any letter, correspondence, email, note, book, pamphlet, article, bulletin, directive, review, publication, memorandum, diary, log, test analysis, study, projection, check, invoice, receipt, bill, purchase order, shipping order, contract, agreement, work paper, calendar, envelope, paper, telephone message, tape, computer tape, computer disc, computer card, recording, videotape, film, microfilm., microfiche, drawing, account, ledger, statement, financial data, and all other writings and COMMUNICATIONS. It is intended to include all non-identical copies, and drafts and all documents in DEFENDANT'S actual or constructive possession, custody or control, whether prepared, published or released by DEFENDANT or by any other person or entity.

2. The term "COMMUNICATION(S)" means any oral, written or electronic transmission of information without limitation, including meetings, discussions, conversations, telephone calls, memoranda, letters, telecopies, telexes, email messages, conferences, seminars, or notes.

3. The terms "YOU", "YOUR", AND "DEFENDANT" refer to and mean defendant Charles Evans.

4. "ALL" includes the word "ANY," and vice versa.

5. "PERSON(S)" is defined by California Evidence Code ¤ 175, and means and includes, without limitation, any natural person, firm, association, organization, partnership, business trust, corporation, limited liability company, or public entity.

6. ""G&SR" and "G&SR/JTC" mean plaintiff Gold & Silver Reserve, Inc. including its sister company Jackson Trading Company.

7. The term "TRANSMITTED" includes copied (cc'd), forwarded or sent, regardless of the mode of such transmission.

8. The term "TRAVEL RECEIPTS" includes receipts for transportation (air, train, taxi, car rental, fuel), lodging, meal entertainment, telephone, facsimile, or other expenses associated with business travel.

DOCUMENTS AND OTHER THINGS TO BE PRODUCED

1. ALL DOCUMENTS that constitute, memorialize, refer to or reflect any COMMUNICATION(S) between you and Ian Grigg, occurring during the period of YOUR employment with G&SR/JTC, that to your knowledge were not also TRANSMITTED to at least one of the directors of G&SR/JTC.

2. ALL DOCUMENTS that constitute, memorialize, refer to or reflect COMMUNICATION(S) between you and James Turk, occurring during the period of YOUR employment with G&SR/JTC, that to your knowledge were not also TRANSMITTED to at least one of the directors of G&SR/JTC.

3. ALL DOCUMENTS that constitute, memorialize, refer to or reflect COMMUNICATION(S) between you and Geoffrey Turk, occurring during the period of YOUR employment with G&SR/JTC, that to your knowledge were not also TRANSMITTED to at least one of the directors of G&SR/JTC.

4. ALL DOCUMENTS that constitute, memorialize, refer to or reflect COMMUNICATION(S) between you and Clifford Press, occurring during the period of YOUR employment with G&SR/JTC, that to your knowledge were not also TRANSMITTED to at least one of the directors of G&SR/JTC.

5. ALL DOCUMENTS that constitute, memorialize, refer to or reflect COMMUNICATION(S) occurring during the period of YOUR employment with G&SR/JTC, that to your knowledge were not also TRANSMITTED to at least one of the directors of G&SR, between you and any one or more of the following PERSONS:

   1. Nizam Ahmad

   2. Jim Fayed

   3. Graham Kelly

   4. Vinay Gupta

   5. Eric Hollander

   6. Erick Gaither

   7. Elwyn Jenkins

   8. George Matajewicz

   9. Bob Nugent

   10. Thab Shahawi

   11. Stefan Spicer

   12. Wayne Dawson

   13. Peter Thiel

   14. Any officer or employee of PayPal

   15. Declan McCullagh

   16. Damien Cave

   17. Any representative or agent of the Secret Service

   18. Any representative or agent of the FBI

   19. Branch manager or other officer or employee of AmSouth

6. ALL DOCUMENTS that constitute, memorialize, refer to or reflect COMMUNICATION(S) between you and Ian Grigg, occurring on or after October 23, 2000.

7. ALL DOCUMENTS that constitute, memorialize, refer to or reflect COMMUNICATION(S) between you and James Turk, occurring on or after October 23, 2000.

8. ALL DOCUMENTS that constitute, memorialize, refer to or reflect COMMUNICATION(S) between you and Geoffrey Turk, occurring on or after October 23, 2000.

9. ALL DOCUMENTS that constitute, memorialize, refer to or reflect COMMUNICATION(S) between you and Clifford Press, occurring on or after October 23, 2000.

10. ALL DOCUMENTS that constitute, memorialize, refer to or reflect COMMUNICATION(S) occurring on or after October 23, 2000, between you and any one or more of the following PERSONS:

    1. Nizam Ahmad

    2. Jim Fayed

    3. Graham Kelly

    4. Vinay Gupta

    5. Eric Hollander

    6. Erick Gaither

    7. Elwyn Jenkins

    8. George Matajewicz

    9. Bob Nugent

    10. Thab Shahawi

    11. Stefan Spicer

    12. Wayne Dawson

    13. Peter Thiel

    14. Any officer or employee of PayPal

    15. Declan McCullagh

    16. Damien Cave

    17. Any representative or agent of the Secret Service

    18. Any representative or agent of the FBI

    19. Branch manager or other officer or employee of AmSouth

11. All email and other correspondence, sent or received by you (under your own name or under any alias, including any email name used by you) during the period of your employment with G&SR/JTC, that to your knowledge were not also TRANSMITTED to at least one of the directors of G&SR/JTC, that reference one or more of the following electronic currency systems:

    1. e-gold

    2. DigiGold

    3. GoldMoney

    4. GoldGrams

    5. eBullion

    6. Pecunix

    7. 3Pgold

12. All email and other correspondence, sent or received by you (under your own name or under any alias, including any email name used by you) on or after October 23, 2000, that reference one or more of the following electronic currency systems:

    1. e-gold

    2. DigiGold

    3. GoldMoney

    4. GoldGrams

    5. eBullion

    6. Pecunix

    7. 3Pgold

13. All email and other correspondence, sent or received by you (under your own name or under any alias, including any email names used by you) during the period of your employment with G&SR/JTC, that to your knowledge were not also TRANSMITTED to at least one of the directors of G&SR/JTC, that reference one or more of the following systems for transfer and settlement of electronic rights, including but not limited to:

    1. Ricardo

    2. sox

    3. WebFunds

    4. Trader

    5. Systemics Market Server or other software that Systemics Inc. is developing or has developed in the past

14. All email and other correspondence, sent or received by you (under your own name or under any alias, including any email names used by you) on or after October 23, 2000, that reference one or more of the following systems for transfer and settlement of electronic rights, including but not limited to:

    1. Ricardo

    2. sox

    3. WebFunds

    4. Trader

    5. Systemics Market Server or other software that Systemics Inc. is developing or has developed in the past

15. All email and other correspondence, sent or received by you (under your own name or under any alias, including any email names used by you) during the period of your employment with G&SR/JTC, that to your knowledge were not also TRANSMITTED to at least one of the directors of G&SR/JTC, that reference one or more of the following companies:

    1. e-gold ltd.

    2. Gold & Silver Reserve, Inc.

    3. Jackson Trading Company

    4. DigiGold.net

    5. digitalbearer.com

    6. Gold-Age

16. All email and other correspondence, sent or received by you (under you'r own name or under any alias, including any email names used by you) on or after October 23, 2000, that reference one or more of the following companies:

    1. e-gold ltd.

    2. Gold & Silver Reserve, Inc.

    3. Jackson Trading Company

    4. DigiGold.net

    5. digitalbearer.com

    6. Gold-Age

17. All email and other correspondence, sent or received by you (under your own name or under any alias, including any email names used by you) during the period of your employment with G&SR/JTC, that to your knowledge were not also TRANSMITTED to at least one of the directors of G&SR/JTC, that reference one or more of the following individuals:

    1. Douglas Jackson

    2. Barry Downey

    3. Reid Jackson

18. All email and other correspondence, sent or received by you (under your own name or under any alias, including any email names used by you) on or after October 23, 2000, that reference one or more of the following individuals:

    1. Douglas Jackson

    2. Barry Downey

    3. Reid Jackson

19. ALL DOCUMENTS that identify the password(s) for the Apple LAPTOP computer that you contributed to G&SR (in lieu of cash, and in exchange for G&SR stock) and which G&SR retained when you left its employ, including passwords for any encrypted files on the computer.

20. The computer you contributed to G&SR (in lieu of cash, and in exchange for G&SR stock) that you took with you upon leaving your employment with G&SR, including passwords for any encrypted files on said computer.

21. ALL DOCUMENTS, including itinerary and TRAVEL RECEIPTS that evidence any business trip you took in October 2000, in the days immediately prior to the IRS 2000 conference.