INSTRUCTIONS TO THE RECIPIENT OF THIS SUBPOENA:

Amway Corporation believes that you are in the possession, custody and control of documents and other tangible things, including recordings, disks, tapes and other electronic data compilations from which evidence can be obtained, which is relevant to the civil action pursuant to which this subpoena has been issued. ALL DOCUMENT DESTRUCTION OR RETENTION POLICIES AND PRACTICES AND ELECTRONIC FILE DELETION OR DISK MANAGEMENT PRACTICES, POLICIES OR PROTOCOLS (INCLUDING BUT NOT LIMITED TO REFORMATTING OR DEFRAGMENTING PRACTICES) WHICH COULD HAVE THE EFFECT OF ALTERING OR DESTROYING INFORMATION REQUESTED BY THIS SUBPOENA WHICH IS ELECTRONICALLY STORED SHOULD BE SUSPENDED UNTIL YOU ARE EXCUSED FROM THIS SUBPOENA.

Failure without adequate excuse to obey this subpoena may be punished as a contempt of the United States District Court from which this subpoena is issued.

DEFINITIONS:

1. "Documents" includes, but is not limited to, the following materials: any and all papers, documents, correspondence, letters, manuals, computer disks (including floppy diskettes, zip disks, CD-ROMs, and hard drives), backup tapes, data otherwise electronically stored (including archival and backup copies of files containing data, as well as files or parts of files which may have been deleted by the user but which are nevertheless recoverable by any means), other data, photographs, videos, surveys, drawings, films, schematics, other computer generated information, handwritten or typewritten notes, charts, graphs, publications, diagrams, journals, calendars, diaries, logs, log books, messages, reports, or any other papers or writings or communications or summaries thereof.
2. "Amway" refers to Amway Corporation and any of its affiliates.
3. "P&G" refers to The Procter & Gamble Company and The Procter & Gamble Distributing Company and any of their affiliates.
4. "P&G Attorneys" refers to Robert Heuck; Fred Hamilton; any other partners, associates or employees of Dinsmore & Shohl; Stanley Chesley, Faye Chesley, LPA; any attorney who is an employee of P&G; and any other person or firm retained by P&G to prosecute or assist in any litigation between P&G and Amway, including non-lawyer consultants or experts.
5. "Amway--The Untold Story" refers to materials posted electronically on the "Amway--The Untold Story" web page formerly located at URL: http://www.teleport.com/~schwartz/ and linked pages, including archival or backup copies thereof.
6. "BLC" refers to the listserve or listserves maintained under one or more names which include the formative "blc" (as, for example, [email protected]) used to facilitate the exchange of electronic mail messages among Sidney Schwartz and other persons regarding Amway.
7. "STC" refers to the listserve or listserves maintained under one or more names which include the formative "stc" (as, for example, [email protected]) used to facilitate the exchange of electronic mail messages among Sidney Schwartz and other persons regarding Amway.

DOCUMENTS REQUESTED:

1. All documents, including electronically stored information and documents in whatever form, received by you from P&G or any P&G Attorneys regarding Amway or any Amway distributor;
2. All documents, including electronically stored information and documents in whatever form, sent by you to P&G or any P&G Attorneys regarding Amway or any Amway distributor;
3. All documents containing, referring or relating to any discussions or communications between you and P&G or any P&G Attorneys regarding Amway or any Amway distributor, including telephone records, for the past four years;
4. All documents pertaining to the Amway--The Untold Story Web Page;
5. All documents reflecting your source of the materials posted on the Amway--The Untold Story Web Page regarding Amway;
6. All documents referring or relating to discussions or communications between you and any person subscribing to BLC for the past four years, including Sidney Schwartz;
7. All documents referring or relating to discussions or communications between you and any persons subscribing to STC for the past four years, including Sidney Schwartz;
8. All documents containing electronic mail communications (or any excerpts thereof) authored or received by you during the last four years in which the word "Amway" is mentioned;
9. Checks, check copies, deposit slips and other records reflecting the receipt of money or other funds or credits from P&G or any P&G Attorneys;
10. Records of meetings, telephone conferences and memoranda reflecting meetings or discussions with P&G or any P&G Attorneys;
11. Records of meetings, telephone conferences and memoranda reflecting meetings or discussions with any person subscribing to BLC or STC;
12. All other documents authored or received by you during the last four years regarding Amway or any Amway distributor.
13. All electronically stored files or parts of files containing any of the information requested in any of the preceding items which have been "deleted" by you but which may nevertheless be recoverable by any means;
14. A complete "mirror" copy of each of your disks, tapes or other electronic storage media which contains any of the information requested in the preceding items. Amway will enter into a reasonable protective order to preserve the confidentiality of your information not relevant to this litigation.