STATE OF NEW MEXICO SECOND JUDICIAL DISTRICT COURT. COUNTY OF BERNALILLO DIEGO ESPINOZA, Plaintiff-Counter Defendant, v No.D-202-CV-2014-01829 DAVID CLEMENTS, et al, Defendants-Counter Plaintiffs. Defendants. RESPONSE TO DEFENDANT-COUNTER PLAINTIFF DAVID CLEMENTS’S SECOND SET OF DISCOVERY, TO: David Clements, Pro Se 2251 La Paloma Dr. Las Cruces, NM 88001 (575) 202-8001 dkclements@li com Request for Production No. 6, Please provide an intemet service report from the intemet service provider identified in your response to Interrogatory No. 10 concerning the “Fraudulent Convention Delegates — a must read” email sent to subscriber diego@allenweh.com for the dates February 17, 2014 through March 6, 2014, Information responsive to this request includes, but is not limited to, any document revealing the number of “forwards,” “opens,” “clicks,” “views,” or information associated with the “share with a friend” email function. Response: If such a report existed at some point, it no longer does. Mr, Espinoza never possessed, or had the ability to obtain, a report that would reveal the number of “forwards,” “opens,” “clicks,” or “views” assaciated with diego@allenweh.com. Also, the email account diego@allenweh.com no longer exists.Respectfully submitted by: Attort€ys for Diego Espinoza 1905 Wyoming NE Albuquerque, NM 87112 Tel: (505) 275-3200 : (505) 275-3837 itheblf.com IHEREBY CERTIFY that a copy of the foregoing Certificate of Notice was served via electronic mail on this 28"" day of October, 2015, to David Clements, Pro Se