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This kind of subpoena is boilerplate. No one actually expects SimulaVR to provide all this information or to show up for a deposition.

This is actually how it will go down:

SimulaVR-Lawyer: Hey Meta-lawyer, I got your subpoena. We're a tiny company and this is overbroad. What do you guys actually want?

Meta-lawyer: Totally understand. Can we get a declaration from your founder about what your company is trying to do, who their competitors are, and few info about your financials? If you have pitch decks for investors, we'd love to get that as well.

SimulaVR-Lawyer: That seems doable but can the financials be filed under seal and attorney-eyes-only?

Meta-lawyer: Yeah that makes sense.

SimulaVR-Lawyer: Lemme talk to the founders and follow up with you. Let's talk later about what the declaration will look like.

Meta-lawyer: Thank you - appreciate it, and looking forward to hearing back soon.




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