In re Carvana Co Securities Litigation

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
WO
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
United Association National Pension Fund, et
al.,
Plaintiffs,
v.
Carvana Company, et al.,
Respondents.
No. CV-22-02126-PHX-MTL
ORDER
Pending before the Court is Carvana Defendants’ “Motion for Issuance of Letters
of Request for International Judicial Assistance” (“Motion for Issuance of Letters of
Request”).1 (Doc. 559.) In the Instant Motion, Defendants request the issuance of two
letters of request to the appropriate judicial authority of the United Kingdom of Great
Britain and Northern Ireland (“U.K.”) “to procure documents from Legal & General
Investment Management LTD (“LGIM”) and Pelham Capital Ltd. (“Pelham”) and
deposition testimony from Kavyan Larizadeh (“Larizadeh”), an employee of Pelham.” (Id.
at 2.) Plaintiffs have filed a Response in opposition to Defendants’ request, see (doc. 575),
and Defendants have filed a Reply in support of their Motion. See (doc. 579.) Because the
letters of request comply with the Hague Convention of 18 March 1970 on the Taking of
Evidence Abroad in Civil or Commercial Matters (“Hague Convention”), are not unduly
burdensome, and do not clearly misstate the law, the Court shall grant the Motion with
modifications. Namely, the Court shall modify the requesting authority and reduce the
1 Discovery matters in this action have been referred to this Court by the presiding
United States District Judge. (Doc. 125.)
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 1 of 64

- 2 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
requested deposition time from 14 hours to 10 hours.
I. BACKGROUND.
As the Court previously noted:
This action, in which Plaintiffs aver that Defendants violated the
Securities Exchange Act of 1934, is based on an alleged “pumping” and
“dumping” of stock. (Doc. 105 at 2–3.) Part of Defendants’ alleged misdeeds
was the sale of vehicles before Defendants possessed the titles to such
vehicles. (Id. at 2–3, 45.) Such acts, Plaintiffs have alleged, relates to
Defendants’ scienter—an element of a security fraud claim. (Id. at 41–42,
45–48.) Grounding Plaintiffs’ T&R allegations were confidential witness
accounts from a number of CWs, including CW-4. (Id. at 45–48.)
While the Presiding Judge dismissed portions of Plaintiffs’ Amended
Complaint [(“AC”)], the T&R allegations that Defendants sold cars before
they possessed those cars’ titles remained. (Id. at 69–73.) This decision was
based, at least in part, upon a finding that the CWs’ accounts were “probative
of Defendants’ scienter by suggesting precisely what Plaintiffs allege—that
Carvana’s noncompliance with title and registration requirements was
widespread and persistent, and Defendants were well aware of the issue.” (Id.
at 48.)
(Doc. 394 at 2.)
At issue today are two proposed letters of request directed at allocants LGIM and
Pelham—which, regarding the latter, contains both a request for production of documents
and a request to depose Larizadeh, an employee of Pelham. (Doc. 559 at 2.) The instant
discovery Motion is one of a growing list of discovery motions regarding allocants. See
(doc. 522); see also (doc. 594.) The “allocants” in question are putative—i.e., absent—
class members, some of whom have voluntarily communicated and provided declarations
supporting Defendants’ defense in the instant action. See (doc. 568 at 11.)
Concerning allocants LGIM and Pelham, these are capital management companies
located within the U.K. who had participated in Defendant Carvana’s April 2022 secondary
offering. (Doc. 559 at 3.) Defendants seek to procure documents from these companies
because they “possess unique information regarding their respective knowledge of the
allegedly omitted information that is directly relevant to the claims and defenses in this
action.” (Id.) Additionally, Defendants seek to depose Larizadeh, an employee of Pelham,
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 2 of 64

- 3 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
because he was involved in Pelham’s decision to participate in the April 2022 secondary
offering. (Id.)
II. LEGAL STANDARDS.
The Hague Convention is a multilateral treaty that “prescribes certain procedures
by which a judicial authority in one contracting state may request evidence located in
another contracting state.”2 Société Nationale Industrielle Aérospatiale v. U.S. Dist. Court
for S. Dist., 482 U.S. 522, 524 (1987). Among the procedures established in the Hague
Convention “is the issuance of a formal written request sent by a domestic court to a foreign
court for the purpose of obtaining evidence in a pending action.” Champion v. Feld Entm’t,
Inc., No. 20-cv-2400-JO-KSC, 2022 U.S. Dist. LEXIS 99151, at *5 (S.D. Cal. June 2,
2022) (cleaned up). In other words, “Signatory States to the Hague Convention agree that
in civil or commercial matters a judicial authority of a Contracting State may, . . . request
the competent authority of another Contracting State, by means of a Letter of Request,3, 4
to obtain evidence, or to perform some other judicial act.” Multimedia Patent Tr. v. Apple
Inc., No. 10-CV-2618-H, 2012 U.S. Dist. LEXIS 192123, at *8 (S.D. Cal. July 27, 2012)
(citations omitted).
The use of the Hague Convention to seek evidence and conduct depositions abroad
is neither the sole nor obligatory statutory vehicle a party may employ. See Société
Nationale, 482 U.S. at 542. Rather, the Hague Convention “is an optional supplement to
the Federal Rules to facilitate the taking of evidence abroad.” Multimedia Patent Tr., 2012
2 The Hague Convention “is the law of the United States with the same effect and
force of a federal statute.” T.R.P. Co. v. Similasan AG, No. 2:17-cv-02197-JCM-CWH,
2019 U.S. Dist. LEXIS 56188, at *3 (D. Nev. Mar. 27, 2019) (citations omitted); El Al Isr.
Airlines v. Tsui Yuan Tseng, 525 U.S. 155, 167 (1999) (noting that “a treaty ratified by the
United States is . . . the law of the land”) (citing U.S. Const. art. II, § 2).
3 “A letter of request or letter rogatory ‘is the request by a domestic court to a foreign
court to take evidence from a certain witness.’” Simon & Simon, PC v. Align Tech., Inc.,
No. 20-cv-03754-VC (TSH), 2022 U.S. Dist. LEXIS 196762, at *12 (N.D. Cal. Oct. 28,
2022) (citing Intel Corp. v. Advanced Micro Devices, Inc., 542 U.S. 241, 247 n.1 (2004)).
4 It should be noted that a letter rogatory “is synonymous with a letter of request[.]”
Desirous Parties Unlimited Inc. v. Right Connection Inc., No. 2:21-cv-01838-GMN-BNW,
2023 U.S. Dist. LEXIS 8437, at *2 (D. Nev. Jan. 18, 2023); Viasat, Inc. v. Space Sys., No.
12-CV-0260-H (WVG), 2013 U.S. Dist. LEXIS 196700, at *35 n.1 (S.D. Cal. Jan. 14,
2013) (“The term letters rogatory is synonymous with the term letters of request.”)
(citations omitted).
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 3 of 64

- 4 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
U.S. Dist. LEXIS 192123, at *9.
“The issuance of an evidence request is a matter within both the authority and the
discretion of the federal court.” Champion, 2022 U.S. Dist. LEXIS 99151, at *6 (citing
Scalia v. Int’l Longshore & Warehouse Union, 337 F.R.D. 281, 288 (N.D. Cal. 2020));
Crocs, Inc. v. La Modish Boutique, No. CV 21-5641-SVW (KKx), 2021 U.S. Dist. LEXIS
245444, at *4 (C.D. Cal. Nov. 12, 2021) (“Whether to issue such a letter is a matter of
discretion for the court.”) (citation omitted). “Before issuing a letter of request, the Court
must analyze the specific facts and consider the foreign jurisdiction’s interests to determine
if the Hague Convention procedures are appropriate and will be effective.”5 Champion,
2022 U.S. Dist. LEXIS 99151, at *6–7 (citing Société Nationale, 482 U.S. at 546 (noting
that U.S. courts must “exercise special vigilance to protect foreign litigants from . . .
unnecessary[] or unduly burdensome[] discovery”)).
However, this review is not overly onerous, considering that “courts in the Ninth
Circuit ‘have held that motions requesting issuance of a letter of request or letter rogatory
should generally be granted and that the opposing party must show good reason for a court
to deny an application for a letter rogatory.’” Webpros Int’l, LLC v. Asli, No. 3:22-cv-
01963-IM, 2024 U.S. Dist. LEXIS 108922, at *4–5 (D. Or. June 20, 2024) (quoting Zoho
Corp. PVT. Ltd v. Freshworks, Inc., No. 20-cv-01869-VC (TSH), 2021 U.S. Dist. LEXIS
124432, at *7 (N.D. Cal. July 2, 2021)). “That is because discovery by letters rogatory and
requests ‘is consistent with the liberal discovery provisions of Rule 26,’ . . . which in turn
permits discovery regarding ‘any nonprivileged matter that is relevant to any party’s claim
5 As a preliminary matter, the Court notes that, because Defendants seek discovery
from foreign non-parties, the circumstances of this case do not require an analysis of the
five-factor comity analysis. See Nike, Inc. v. Sketchers U.S.A., Inc., No. CV 23-9346 AB
(PVC), 2025 U.S. Dist. LEXIS 280152, at *8 (C.D. Cal. Dec. 22, 2025) (noting that the
Société Nationale comity factors were inapplicable where the plaintiff sought discovery
from foreign nonparties—not a foreign defendant whom the court has personal jurisdiction
over—so it was not a case where the “application of American law would directly affect
the sovereignty of a foreign nation”) (quoting Miss. Poultry Ass’n v. Madigan, 992 F.2d
1359, 1367 (5th Cir. 1993)); see also Desirous Parties Unlimited Inc. v. Right Connection
Inc., No. 2:21-cv-01838-GMN-BNW, 2023 U.S. Dist. LEXIS 8437, at *5 n.3 (D. Nev. Jan.
18, 2023) (setting out the five-factor comity analysis employed by courts within the Ninth
Circuit); Dalrada Fin. Corp. v. Bonar, No. 24-cv-2166-BTM-BLM, 2026 U.S. Dist.
LEXIS 52684, at *8 (S.D. Cal. Mar. 12, 2026) (“Consideration of the comity factors is not
required.”).
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 4 of 64

- 5 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
or defense and proportional to the needs of the case.’” Webpros Int’l, LLC, 2024 U.S. Dist.
LEXIS 108922, at *5 (first citing Viasat, Inc. v. Space Sys., No. 12-CV-0260-H (WVG),
2013 U.S. Dist. LEXIS 196700, at *36 (S.D. Cal. Jan. 14, 2013); then citing Fed. R. Civ.
P. 26(b)(1)).
At a minimum, a letter of request shall identify:
(a) the authority requesting its execution and the authority requested to
execute it, if known to the requesting authority;
(b) the names and addresses of the parties to the proceedings and their
representatives, if any;
(c) the nature of the proceedings for which the evidence is required, giving
all necessary information in regard thereto;
(d) the evidence to be obtained or other judicial act to be performed.
Hague Convention, art. 3, 23 U.S.T. 2555 (Oct. 7, 1972).
And, in the appropriate situation, the letter of request shall identify:
(e) the names and addresses of the persons to be examined;
(f) the questions to be put to the persons to be examined or a statement of the
subject-matter about which they are to be examined;
(g) the documents or other property, real or personal, to be inspected;
(h) any requirement that the evidence is to be given on oath or affirmation,
and any special form to be used;
(i) any special method or procedure to be followed under Article 9.
Id.
Because a letter of requests “constitutes a request from the Court for assistance, not
from a party, care should be taken to ensure that the synopsis of the case is not unduly
argumentative, or state or suggest that the Court has reached factual conclusions at this
stage of the proceedings.” Anstalt v. Bacardi & Co., No. CV 16-6411 CAS (FFMx), 2018
U.S. Dist. LEXIS 227414, at *10 (C.D. Cal. June 25, 2018).
III. DISCUSSION.
The parties disagree on whether Defendants should be permitted to conduct allocant
discovery via letters of request. Specifically, Plaintiffs raise four arguments in opposition
to Defendants’ Motion for Issuance of Letters of Request. First, Plaintiffs aver that the
instant request amounts to disfavored absent class-member discovery. (Doc. 575 at 4–7.)
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 5 of 64

- 6 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Second, Plaintiffs assert that the instant discovery request would unduly burden foreign
allocants and would be disproportionate to Defendants’ needs in this action. (Id. at 7–9.)
Third, Plaintiffs challenge the proposed two-day deposition of Larizadeh, asserting that it
violates this Court’s February 17, 2026 Order (doc. 326) and would be unduly burdensome.
(Id. at 9–10.) Fourth, Plaintiffs assert that the proposed letters of request misstate the
applicable law in this action. (Id. at 10–12.)
The Court shall address the instant discovery dispute as follows. First, the Court
shall analyze whether the instant discovery request permissibly seeks materials from the
allocants, who are absent class members. Second, the Court shall address Plaintiffs’ undue
burden and proportionality arguments. Third, the Court shall address whether Defendants
request to conduct 14 hours of deposition is or is not permissible. Finally, the Court shall
address whether the letters of request are proper.
A. Absent Class Member Discovery.
Plaintiffs assert that Defendants are attempting to embark upon impermissible
absent class-member discovery. For the following reasons, the Court disagrees.
As a general matter, “[d]iscovery from absent class members is ordinarily not
permitted.” McPhail v. First Command Fin. Planning, Inc., 251 F.R.D. 514, 517 (S.D. Cal.
2008). This is because “an absent class-action plaintiff is not required to do anything” in a
class action suit. Phillips Petroleum Co. v. Shutts, 472 U.S. 797, 810 (1985) (noting that
an absent class member “may sit back and allow the litigation to run its course, content in
knowing that there are safeguards provided for his protection”). “Another, perhaps more
compelling, reason for not subjecting absent class members to discovery is the fear that
defendants will use burdensome discovery requests as a method of unfairly reducing the
number of class members.” On the House Syndication, Inc. v. Fed. Express Corp., 203
F.R.D. 452, 456 (S.D. Cal. 2001) (citations omitted).
“Although courts do not usually allow discovery from absent class members, the
rules pertaining to such discovery are flexible, especially where the proposed deponents
have been identified as potential witnesses or have otherwise injected themselves into the
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 6 of 64

- 7 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
litigation.” Brown v. Wal-Mart Store, Inc., No. 09-cv-03339-EJD (SVK), 2018 U.S. Dist.
LEXIS 4027, at *3 (N.D. Cal. Jan. 9, 2018) (citations omitted). Given these flexible
discovery rules, “District courts . . . have discretion to allow limited discovery from absent
class members if the particular circumstances of a specific case justify it.” Briseno v.
ConAgra Foods, Inc., 844 F.3d 1121, 1131 n.10 (9th Cir. 2017) (citing WILLIAM B.
RUBENSTEIN, Newberg on Class Actions § 9:13 (5th ed. 2013) (“[C]ertain forms of limited
discovery from absent class members may be permitted in certain circumstances.”)).
Notwithstanding the Ninth Circuit’s aforementioned finding, “[n]either the
Supreme Court nor the Ninth Circuit have provided guidance as to when discovery on
absent class members is permitted.” Johnston v. Hertz Local Edition Corp., 331 F.R.D.
140, 141 (E.D. Cal. 2019). In the absence of appellate guidance, courts throughout the
district have adopted several tests to determine whether absent class member discovery
should be permitted in a given case. See id. (applying a four-factor test based upon the
standards articulated by the Seventh Circuit in Clark v. Universal Builders, Inc., 501 F.2d
324 (7th Cir. 1974)); see also Tierno v. Rite Aid Corp., No. C 05-02520 TEH, 2008 U.S.
Dist. LEXIS 112461, at *17 (N.D. Cal. July 8, 2008) (“[D]iscovery has been permitted in
certain circumstances, [(1)] where the information sought is relevant, [(2)] not readily
obtainable from the representative parties or other sources, and [(3)] the request is not
unduly burdensome and made in good faith.”); Arredondo v. Delano Farms Co., No. 1:09-
cv-01247 MJS, 2014 U.S. Dist. LEXIS 145562, at *12–13 (E.D. Cal. Oct. 10, 2014)
(“[T]he Court concludes that as a general rule, discovery from absent class members may
be permitted [(1)] when reasonably necessary, [(2)] not conducted for an improper purpose,
and [(3)] not unduly burdensome in the context of the case and its issues.”).
Out of the aforementioned tests, the Court finds—as several of its sister districts
have found—“that the most useful test . . . is the Arredondo test due to its ability to ‘easily
encompass the more specific Clark factors,’ as well as those of other courts.” Sun Gon
Kang v. Credit Bureau Connection, Inc., No. 1:18-cv-01359-AWI-SKO, 2022 U.S. Dist.
LEXIS 201837, at *8 (E.D. Cal. Nov. 4, 2022) (quoting Aldapa v. Fowler Packing Co.,
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 7 of 64

- 8 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
No. 1:15-cv-00420-DAD-SAB, 2019 U.S. Dist. LEXIS 35284, at *14 (E.D. Cal. Mar. 5,
2019)). And, in applying the Arredondo factors, the Court finds that Defendants’ instant
discovery request is permissible.
First, the Court finds that the proposed absent class member discovery is reasonably
necessary. As Defendants note in their Motion, “LGIM and Pelham possess unique
information regarding their respective knowledge of the allegedly omitted information that
is directly relevant to the claims and defenses in this action.” (Doc. 559 at 3); (doc. 579 at
6–7.) Similarly, Larizadeh appears to possess “unique information relevant to
[Defendants’] defenses.” (Doc. 559 at 3); (doc. 579 at 6–7.) Given that a class members
actual knowledge may, based upon the circumstances of the case, be of consequence to
either a section 11 and 12 claim or class certification, cf. Vignola v. Fat Brands, No. CV
18-7469 PSG (PLAx), 2020 U.S. Dist. LEXIS 73577, at *13 (C.D. Cal. Mar. 13, 2020),
the Court finds the instant request relevant. Hence, the first Arredondo factor is satisfied.
Second, The Court does not find that Defendants are attempting to conduct the
instant discovery for an improper purpose. The instant discovery request does not appear
to be an attempt by Defendants to harass or take advantage of absent class members. See
Vignola v. Fat Brands, 2020 U.S. Dist. LEXIS 73577, at *13–14. Nor does the instant
discovery request appear to pose “a chilling effect on [absent class members’] willingness
to be part of the class.” Antoninetti v. Chipotle, Inc., No. 06cv2671-BTM (WMc), 2011
U.S. Dist. LEXIS 54854, at *5 (S.D. Cal. May 23, 2011). Additionally, it is “[a]lso
persuasive . . . that Defendant[s] seeks one deposition, not thousands,” Hall v. Marriott
Int’l, Inc., No. 3:21-cv-1370-JLS-AHG, 2021 U.S. Dist. LEXIS 160965, at *22 (S.D. Cal.
Aug. 25, 2021), and only documents from only two absent class members.
Third, considering that Defendants seek the production of documents from two
allocants and only a single deposition, the Court does not find that the instant discovery
request is unduly burdensome in the context of this case. While it is true that the instant
discovery request is unique in that it seeks to obtain discovery abroad, the request’s
uniqueness does not render it so unduly burdensome to preclude discovery here.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 8 of 64

- 9 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Given the foregoing, the Court finds that Defendants’ instant request to conduct
absent class-member discovery is permissible.
B. Undue Burden and Proportionality.
Plaintiff next asserts that the instant letter of request “will unduly burden foreign
nonparties and is not proportional to the needs of th[is] case.” (Doc. 575 at 7.) This
argument is unavailing because Plaintiffs lacks standing to assert either an undue burden
or proportionality argument on the behalf of nonparties LGIM, Pelham, and Larizadeh.
“Like all discovery, motions for letters of request are subject to the standards of
Rule 26(b), which provides that parties may obtain discovery regarding any nonprivileged
matter that is relevant to any party’s claim or defense,” Successor Agency to the Former
Emeryville Redevelopment Agency v. Swagelok Co., No. 17-cv-00308-WHO, 2020 U.S.
Dist. LEXIS 224963, at *5 (N.D. Cal. Dec. 1, 2020) (citation omitted), and is “proportional
to the needs of the case[.]” Fed. R. Civ. P. 26(b)(1). Although the scope of discovery “is
broad,” it is “not unlimited.” Champion, 2022 U.S. Dist. LEXIS 99151, at *10 (citation
omitted).
Here, Plaintiffs challenge the proposed letters of request on undue burden and
proportionality grounds. See (doc. 575 at 7–9.) But, Plaintiffs are neither required to
produce documents nor sit for a deposition. Rather, foreign nonparties are the targets of
Defendants’ letters of request. The Court notes that other courts have found that a party has
no standing to challenge a letter of request issued to a foreign nonparty on the ground that
such discovery would inflict an undue burden.6 See Orient Plus Int’l Ltd. v. Baosheng
Media Grp. Holdings Ltd., No. 1:24-cv-00744 (JLR), 2026 U.S. Dist. LEXIS 87621, at *12
(S.D.N.Y. Apr. 21, 2026); see also Sahu v. Union Carbide Corp., 2006 U.S. Dist. LEXIS
944, at *1 (S.D.N.Y. Jan. 10, 2006) (“Plaintiffs request international assistance in the form
of a Letter Rogatory to obtain documents from a third party. Defendants make several
objections to the request. Absent special circumstances, however, a party may not seek a
6 Because this is not a § 1782 matter, Plaintiffs cannot avail themselves of In re
Request for Judicial Assistance from Seoul Dist. Criminal Court’s finding that “[t]he party
against whom requested . . . records are to be used has standing to challenge the validity of
the order to . . . produce the records.” 555 F.2d 720, 723 (9th Cir. 1977).
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 9 of 64

- 10 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
protective order where discovery is sought from a third party.”); PkFinans Int’l Corp. v.
IBJ Schroder Leasing Corp., 93 Civ. 5375 (SAS)(HBP), 96 Civ. 1816 (SAS)(HBP), 1996
U.S. Dist. LEXIS 15183, at *7 (S.D.N.Y. Oct. 10, 1996) (“[I]n the absence of a claim of
privilege, we fail to see how PKFinans has standing to object to discovery sought from a
non-party.”). And, regarding proportionality, other courts within this district have found
that—in the context of subpoenas—“a non-recipient party cannot move to quash or modify
a subpoena on relevance, cost, or proportionality grounds.” Fed. Trade Comm’n v. Grand
Canyon Educ. Inc., No. CV-23-02711-PHX-DWL, 2025 U.S. Dist. LEXIS 40240, at *30
(D. Ariz. Mar. 6, 2025) (citations omitted). Hence, it does not appear that Plaintiffs have
standing to challenge the letters of request on undue burden and proportionality grounds.
Regardless, the “Court concludes that resolving the question of [Plaintiffs’] standing
to object is not necessary for a resolution of the question of whether to issue . . . letter[s]
of request.” See Brown v. State St. Corp., No. 05-11178-NG, 2006 U.S. Dist. LEXIS
106235, at *10 (D. Mass. Mar. 20, 2006). First, as the Court noted in supra section III.A,
the instant requests would not impose an undue burden on nonparties. Second, the Court
finds the instant discovery eminently proportional in light of the issues at stake, the parties’
resources, and the importance of the instant discovery in resolving issues in this action.7
Cf. Assuredpartners of Cal. Ins. Servs. LLC v. Pahl, No. CV-25-00693-TUC-RM, 2026
U.S. Dist. LEXIS 52049, at *5 (D. Ariz. Mar. 13, 2026) (“In considering whether discovery
is proportional to the needs of the case, the court must consider ‘the importance of the
issues at stake in the action, the amount in controversy, the parties’ relative access to
relevant information, the parties’ resources, the importance of the discovery in resolving
7 And, in any event, questions on whether to execute the instant letters of request are
for the receiving nation’s court to make, not this Court. See Orient Plus Int’l Ltd., 2026
U.S. Dist. LEXIS 87621, at *13 (“letters of request do not require: They request.”); see
also Perceptix Techs. LLC v. Meta Platforms, Inc., No. 8:25-cv-01404 DOC (ADSx), 2026
U.S. Dist. LEXIS 31137, at *7 (C.D. Cal. Feb. 10, 2026) (“As such, the Republic of Korea
will apply its own law to the letters of request to determine the extent to which the sought
discovery is allowed[.] The Court will not attempt to predict whether that discovery will
actually be obtained.”) (citing Scalia, 337 F.R.D. at 288); Webpros Int’l, LLC, 2024 U.S.
Dist. LEXIS 108922, at *7 (“Finally, this Court notes that, pursuant to the Convention, the
German authorities ultimately will determine whether Plaintiff’s requests comply with
German law.”).
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 10 of 64

- 11 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
the issues, and whether the burden or expense of the proposed discovery outweighs its
likely benefit.’”) (citing Fed. R. Civ. P. 26(b)(1)).
For the foregoing reasons, the Court does not find that the instant letters of request
are disproportionate or would impose an undue burden upon the foreign nonparties.
C. Deposition Time.
The next matter the Court will address is whether the to permit the parties to depose
Larizadeh for 14 hours over the course of two days. For the following reasons, the Court
will allot 10 hours of time for the deposition of Larizadeh, wherein Defendants shall be
allotted seven hours and Plaintiffs three.
Rule 30 governs the procedures for conducting depositions via oral examination.
Loop AI Labs, Inc. v. Gatti, No. 15-cv-00798-HSG (DMR), 2015 U.S. Dist. LEXIS
126078, at *11 (N.D. Cal. Sep. 18, 2015). Under the rule, “[a]ctions are presumptively
limited to a single deposition of a part . . . lasting one day of seven hours of examination[.]”
Playup, Inc. v. Mintas, 344 F.R.D. 429, 433 (D. Nev. 2023) (citations omitted). Hence, a
hard cap of seven hours is the norm. See Fed. R. Civ. P. 30(d)(1).
“The Federal Rules give district courts broad discretion to manage the manner in
which discovery proceeds, including the manner in which examination time is allocated
among competing parties at a time-limited deposition.” United States v. Glob. Bus. Travel
Grp., Inc., 2025 U.S. Dist. LEXIS 34030, at *4 (S.D.N.Y. Feb. 24, 2025) (cleaned up).
“The Committee Notes to the 2000 Amendments to Rule 30 explain that the presumptive
duration may be extended, or otherwise altered, by agreement. Absent agreement, a court
order is needed.” Syncora Guarantee, Inc. v. EMC Mortg. Corp., No. C 12-80028 SI, 2012
U.S. Dist. LEXIS 30877, at *4–5 (N.D. Cal. Mar. 8, 2012) (cleaned up). The party seeking
a court-ordered extension “is expected to show good cause to justify such an order.” Id.;
Athwal v. Cnty. of Stanislaus, No. 1:15-cv-00311-TLN-BAM, 2021 U.S. Dist. LEXIS
49269, at *5 (E.D. Cal. Mar. 15, 2021) (“A party seeking a court order for additional time
must show good cause for the extension.”); accord Pierre v. City of N.Y., No. 1:20-cv-
05116 (ALC) (VF), 2022 U.S. Dist. LEXIS 116889, at *4 (S.D.N.Y. July 1, 2022) (“In
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 11 of 64

- 12 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
multi-party cases, the need for each party to examine the witness may warrant additional
time, although duplicative questioning is discouraged[.] Whether good cause exists to
extend a deposition beyond the presumptive time limit of seven hours is a fact-specific
determination.”) (cleaned up and emphasis added).
“The examination and cross-examination of a deponent proceed as they would at
trial under the Federal Rules of Evidence[.]” Fed. R. Civ. P. 30(c)(1). “As the Committee
Notes on Rules for the 2000 Amendment explain, it is expected that in most instances the
parties and the witness will make reasonable accommodations to avoid the need for resort
to the court[.] Preoccupation with timing is to be avoided.” Syncora Guarantee, Inc., 2012
U.S. Dist. LEXIS 30877, at *3–4 (cleaned up and emphasis added); Sexton v. Exxon Mobil
Corp., No. 17-482-JWD-RLB, 2020 U.S. Dist. LEXIS 19505, at *8 (M.D. La. Jan. 31,
2020) (“It is expected that in most instances the parties and the witness will make
reasonable accommodations to avoid the need for resort to the court.”) (citation omitted).
Here, the parties dispute whether the deposition of Larizedah should be permitted
to exceed one seven-hour day. Compare (doc. 575 at 9–10) with (doc. 579 at 10–12).
Plaintiffs specifically cite to this Court’s February 17, 2026, Order—which states that the
parties may make requests for additional time “as a last resort,” (doc. 326 at 8) (emphasis
omitted)—to support their argument that extra time is unwarranted here. See (doc. 575 at
9–10.)
The Court finds that Defendants have established sufficient good cause to permit
three additional hours of deposition time, with two hours going to Defendants and one hour
going to Plaintiffs. The reason for this finding is twofold. First, the Court finds that as
Larizadeh is a foreign national, extra time for questioning is because of the parties’ inability
to compel his testimony at trial. Second, this Court’s prior Order is not so rigid as to
preclude any extension of the presumptive seven-hour limit. Hence, additional time is
warranted here. While additional time is warranted, the Court does not find good cause to
permit seven additional hours. Specifically, the Court expresses concern that permitting
seven additional hours would result in duplicative questioning. Instead, the Court finds
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 12 of 64

- 13 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
three additional hours warranted here. These three additional hours will be split as follows:
(a) two additional hours shall be allotted to Defendants; and (b) one additional hour shall
be allotted to Plaintiffs. Dividing the ten total hours of depositions seven–three preserves
the 70%–30% split established in this Court’s February 17, 2026, Order, and mitigates the
risk of duplicative questioning.
D. Adequacy of Letters of Request.
Finally, the Court shall analyze whether Defendants have met their burden of
showing the letters of request should be issued. “Given the liberal standard for issuance of
letters of request,” Simon & Simon, PC v. Align Tech., Inc., No. 20-cv-03754-VC (TSH),
2022 U.S. Dist. LEXIS 196762, at *13 (N.D. Cal. Oct. 28, 2022), and for the reasons stated
below, the Court finds that Defendants have met their burden of showing that the letters
should be issued.
“Courts have uniformly recognized that it is appropriate for a party to invoke the
Hague Evidence Convention when evidence is requested from a non-party located abroad
that is not subject to the court’s jurisdiction.” Webpros Int’l, LLC, 2024 U.S. Dist. LEXIS
108922, at *5 (citations omitted). Usually, when a party requests issuance of a letter of
request under the Hague Convention, a court will grant the request “absent a showing by
the opposing party demonstrating good cause to deny the motion.” Parsons Xtreme Golf
LLC v. Taylor Made Golf Co., No. CV-17-03125-PHX-JJT, 2018 U.S. Dist. LEXIS
139555, at *4 (D. Ariz. Aug. 17, 2018).
Under this liberal standard, Plaintiffs has failed to demonstrate good cause to deny
the instant Motion. As an initial matter, the Court finds that Defendants’ letters of request
satisfy the requirements of the Hague Convention art. 3 because the letters contain: (a) “the
authority requesting its execution and the authority requested to execute it”; (b) “the names
and addresses of the parties to the proceedings and their representatives”; (c) “the nature
of the proceedings for which the evidence is required, giving all necessary information in
regard thereto”; and (d) “the evidence to be obtained or other judicial act to be performed.”
See Hague Convention, art. 3, 23 U.S.T. 2555 (Oct. 7, 1972); see also (doc. 559-1.) Thus,
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 13 of 64

- 14 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Defendants’ proposed letters satisfy the requirements of the Hague Convention.
Next, turning to Plaintiffs’ main challenge to the instant letters—that they “misstate
the applicable law,” (doc. 575 at 10–11)—the Court does not find the instant argument
persuasive. Plaintiffs, in their response, specifically argue that the instant letters misstate
the elements of claim under § 12(a)(2), 15 U.S.C. § 77l(a)(2), in that the instant letters state
that lack of knowledge is an element of a § 12(a)(2) claim, not an affirmative defense. (Id.
at 11.) Given this, Plaintiffs aver that the letters of request, in their instant form, should not
be issued as they misstate the applicable law to the degree that it would confuse the foreign
tribunal. (Id.) Plaintiffs rely on Walther-Meade v. Leidos, Inc., No. 22cv1777-JAH(BLM),
2023 U.S. Dist. LEXIS 77591 (S.D. Cal. May 3, 2023) and MSK Covertech, Inc. v. Fevisa
Indus., S.A. de C.V., No. 23cv741-DMS (MSB), 2023 U.S. Dist. LEXIS 110117 (S.D. Cal.
June 26, 2023) to support their position. (Id.) Defendants, in turn, argue that they relied
upon the statutory text in drafting the letters’ statements of the case, which “imposes
liability only where ‘the purchaser [did] not know[] of such untruth or omission’ at the time
they purchased the stock.” (Doc. 579 at 12) (quoting 15 U.S.C. § 77l(a)(2)).
The Court does not find Plaintiffs’ argument availing. Regarding the statutory text
of § 12(a)(2)—and as Defendants correctly note—it does note that liability may be had
only where “the purchaser [did] not know[] of such untruth or omission” at the time of
purchase. See 15 U.S.C. § 77l(a)(2). So, it does appear that a purchaser’s knowledge would
play a part in Plaintiffs’ case-in-chief. See 15 U.S.C. § 77l(a)(2); see also Casella v. Webb,
883 F.2d 805, 809 (9th Cir. 1989) (“[P]urchasers may recover unless they have actual
knowledge of the untruth or omission.”). But see Bos. Ret. Sys. v. Uber Techs., Inc., No.
19-cv-06361-RS, 2022 U.S. Dist. LEXIS 132641, at *9 (N.D. Cal. July 26, 2022) (“Actual
knowledge is a defense to claims under Sections 11 and 12.”).
In any event, even if actual knowledge was an affirmative defense as opposed to an
element of a § 12(a)(2) claim, the distinction is not dispositive here. First, the Court does
not find that the statement of the case, as currently written, would mislead the foreign
tribunal. Although letters of request must comply with the dictates of the Hague
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 14 of 64

- 15 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Convention, neither the Convention nor federal caselaw requires the statement of facts to
be a law review article. Cf. Webpros Int’l, LLC, 2024 U.S. Dist. LEXIS 108922, at *6–7
(“The letter contains all of the relevant addresses and discusses the nature of the
proceedings, as well as the nature of the evidence sought[.] Further, the letter is in English,
which the Convention permits under Article 4. This is all sufficient under the
Convention.”). Regardless of whether actual knowledge is an element of a claim or an
affirmative defense, it may nonetheless be “a dispositive issue as to [Plaintiffs’] Securities
Act claims[.]” Doc. 559-1 at 10.) Consequently, Defendants’ statement of the case does
not misstate the governing law to the point it would mislead or confuse the receiving
sovereign’s courts.
Second, the Court does not find Plaintiffs’ reliance on Walther-Meade or MSK
Covertech availing here. Beginning with the latter, while the court in MSK Covertech
refused to issue the plaintiff’s letter of request as currently written, it did not due so based
on concern that it would confuse a foreign tribunal. 2023 U.S. Dist. LEXIS 110117, at *3.
No, it did so because the plaintiff patently failed to correctly cite documents in the record.
Id. Thus, the MSK Covertech court was not called upon to interpret an unclear statutory
provision, nor was its decision based upon a concern that the statement of the case would
confuse a foreign tribunal. And regarding Walther-Meade, where the court likewise refused
to issue a letter of request, the court there was not required to interpret an unclear statutory
provision as this Court is required to do. See 2023 U.S. Dist. LEXIS 77591, at *13–14.
Rather, the Walther-Meade court refused to issue the letters of request because the letter
cited “Federal Rule of Evidence 34,” a non-existent rule. Id. at *14. In short, neither
Walther-Meade nor MSK Covertech aid Plaintiffs’ argument here.
For the foregoing reasons, the Court does not find that the instant letters of request
threaten to confuse tribunals in the U.K.8
//
8 As a final note, the Court’s instant finding regarding the interpretation of § 12(a)(2)
does not govern how the Presiding Judge will interpret § 12(a)(2) on class certification or
at trial. The Court’s instant finding solely applies to the instant discovery request.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 15 of 64

- 16 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
IV. CONCLUSION.
Because Defendants’ proposed letters of request the comply with the Hague
Convention, are not unduly burdensome, and does not clearly misstate the law, the Court
shall grant the instant Motion. However, because the Court finds that three additional
deposition hours, not seven, are warranted here, the Court shall modify the instant letters
accordingly. Finally, the Court shall modify the instant letters to reflect that undersigned is
the sending authority.
Accordingly,
IT IS ORDERED that Defendants’ Motion for Issuance of Letters of Request (doc.
559) are GRANTED AS MODIFIED. The Clerk of Court is kindly directed to provide
the signed Letters of Request to Defendants’ counsel Meryn C.N. Grant at:
meryn.grant@lw.com. It shall be the responsibility of Defendants to deliver the letters of
request and all relevant materials to the appropriate authorities in the U.K.
IT IS FURTHER ORDERED that Defendants’ deposition of Larizedah is limited
to TEN (10) HOURS over two days, whereby Defendants shall have SEVEN (7) HOURS
to examine the Larizedah, and Plaintiffs shall have THREE (3) HOURS to cross-examine.
IT IS FURTHER ORDERED that the parties shall meet and confer within FIVE
(5) DAYS to determine how the parties will divide the collective 10 deposition hours over
the course of two days. AS A LAST RESORT, the parties may request Court assistance on
how to divide the collective 10 deposition hours over the course of two days.
Dated this 12th day of August, 2026.
Honorable John Z. Boyle
United States Magistrate Judge
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 16 of 64

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
LETTER OF REQUEST NO. 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
United Association National Pension Fund, et
al.,
Plaintiffs,
v.
Carvana Company, et al.,
Respondents.
No. CV-22-02126-PHX-MTL
REQUEST FOR INTERNATIONAL
JUDICIAL ASSISTANCE PURSUANT
TO THE HAGUE CONVENTION OF
18 MARCH 1970 ON THE TAKING OF
EVIDENCE ABROAD IN CIVIL OR
COMMERCIAL MATTERS
TO THE SENIOR MASTER OF THE KING’S BENCH DIVISION OF THE HIGH
COURT OF JUSTICE OF ENGLAND AND WALES:
The United States District Court for the District of Arizona respectfully requests
judicial assistance pursuant to the Hague Convention of 18 March 1970 on the Taking of
Evidence Abroad in Civil or Commercial Matters (the “Hague Evidence Convention”), to
which both the United States and the United Kingdom are parties, to obtain documentary
evidence to be used at the trial of pending civil proceeding before this Court in the above-
captioned matter. The United States District Court for the District of Arizona is a competent
court of law and equity which properly has jurisdiction over this proceeding and has the
power to compel the production of documents and the attendance of witnesses both within
and outside its jurisdiction.
This Court respectfully asks that this Letter of Request be executed, and that
Defendants be permitted to obtain documentary evidence sought from Legal & General
Investment Management Ltd. (“LGIM”).
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 17 of 64

- 2 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
This Court considers that the evidence sought herein is directly relevant to the issues
in dispute for determination at trial, is evidence intended for use at trial, and without which
the ends of justice could not be properly met. This Court also believes that this evidence is
available to LGIM and not available from any other source. This request is made with the
understanding that it will in no way require any person to commit any offense, or to
undergo a broader form of inquiry than he or she would if the litigation were conducted in
England and Wales. In the proper exercise of its authority, this Court has determined that
the documentary evidence is highly relevant to the determination of these proceedings and
cannot be secured except by the intervention of the Senior Master of the King’s Bench
Division of the High Court of Justice of England and Wales.
1. Sender:
Honorable John Z. Boyle
United States Magistrate Judge
United States District Court, District of Arizona
Sandra Day O’Connor U.S. Courthouse, Suite 322
401 West Washington Street, SPC 75
Phoenix, AZ 85003-2160
United States of America
2. Central authority of the requested state:
The Senior Master of the King’s Bench Division of the High Court
Foreign Process Section
Room E16
Royal Courts of Justice
Strand
London WC2A 2LL
United Kingdom
Tel: +44 207 947 7772
E-mail: foreignprocess.rcj@justice.gov.uk
3. Person(s) to whom the executed request is to be returned:
Meryn C.N. Grant
Latham & Watkins LLP
10250 Constellation Blvd., Suite 1100
Los Angeles, CA 90067
Telephone: +1.424.653.5500
Email: meryn.grant@lw.com
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 18 of 64

- 3 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4. Specification of the date by which the requesting authority requires receipt of
the response to the letter request:
Date: As soon as reasonably practical consistent with the receiving Court’s calendar.
Reason for Urgency: The deadline for Defendants Carvana Co. (“Carvana”), Ernest
Garcia III, Mark Jenkins, Stephen Palmer, Michael Maroone, Neha Parikh, Ira Platt, and
Greg Sullivan (collectively, the “Carvana Defendants”), to collect all non-expert evidence
for trial has been set for October 2, 2026, and Carvana Defendants have been otherwise
unable to obtain the requested documentary evidence. A trial date for this litigation has not
yet been set.
5. In conformity with Article 3 of the Convention, the undersigned applicant has
the honor to submit the following request:
a. Requesting Authority:
Honorable John Z. Boyle
United States Magistrate Judge
United States District Court, District of Arizona
Sandra Day O’Connor U.S. Courthouse, Suite 322
401 West Washington Street, SPC 75
Phoenix, AZ 85003-2160
United States of America
b. To the Competent Authority of:
The United Kingdom
The Senior Master of the King’s Bench Division of the High Court
Foreign Process Section
Room E16
Royal Courts of Justice
Strand
London WC2A 2LL
United Kingdom
c. Name of the Case and Identifying Number:
In re Carvana Co. Securities Litigation
Case No. 2:22-cv-02126-PHX-MTL, pending before U.S. District Judge
Michael T. Liburdi (presiding) and U.S. Magistrate Judge John Z. Boyle
(referred for discovery matters) in the United States District Court for the
District of Arizona
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 19 of 64

- 4 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
6. Names and addresses of the parties and their representatives:
a. Plaintiffs:
Saskatchewan Healthcare Employees’ Pension Plan (“SHEPP”) and United
Association National Pension Fund (“UANPF”)
ROBBINS GELLER RUDMAN & DOWD LLP
DANIEL S. DROSMAN
TOR GRONBORG
ERIKA L. OLIVER
RACHEL A. COCALIS
SARAH A. FALLON
DANIEL S. DROSMAN
655 West Broadway, Suite 1900
San Diego, CA 92101
Telephone: 619/231-1058
619/231-7423 (fax)
ddrosman@rgrdlaw.com
torg@rgrdlaw.com
eoliver@rgrdlaw.com
rcocalis@rgrdlaw.com
sfallon@rgrdlaw.com
ROBBINS GELLER RUDMAN & DOWD LLP
ROBERT M. ROTHMAN
DAVID A. ROSENFELD
BRENT E. MITCHELL
58 South Service Road, Suite 200
Melville, NY 11747
Telephone: 631/367-7100
631/367-1173 (fax)
rrothman@rgrdlaw.com
drosenfeld@rgrdlaw.com
bmitchell@rgrdlaw.com
ROBBINS GELLER RUDMAN & DOWD LLP
JACOB G. GELMAN
Post Montgomery Center
One Montgomery Street, Suite 1800
San Francisco, CA 94104
Telephone: 415/288-4545
415/288-4534 (fax)
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 20 of 64

- 5 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
jgelman@rgrdlaw.com
O’DONOGHUE & O’DONOGHUE LLP
DINAH S. LEVENTHAL
5301 Wisconsin Avenue, N.W., Suite 800
Washington, D.C. 20015
Telephone: 202/362-0041
202/362-2640 (fax)
dleventhal@odonoghuelaw.com
BONNETT FAIRBOURN FRIEDMAN & BALINT PC
ANDREW FRIEDMAN
7301 N. 16th Street, Suite 102
Phoenix, AZ 85020
Telephone: 602/274-1100
602/274-1199 (fax)
afriedman@bffb.com
b. Carvana Defendants:
Carvana Co., Ernest Garcia III, Mark Jenkins, Stephen Palmer, Michael
Maroone, Neha Parikh, Ira Platt, and Greg Sullivan
LATHAM & WATKINS LLP
Meryn C.N. Grant
10250 Constellation Blvd., Suite 1100
Los Angeles, CA 90067
Telephone: +1.424.653.5500
Email: meryn.grant@lw.com
LATHAM & WATKINS LLP
Andrew B. Clubok
Susan E. Engel
J. Christian Word
Matthew J. Peters
555 Eleventh Street, N.W., Suite 1000
Washington, D.C. 20004
Telephone: +1.202.637.2200
Email: aclubok@lw.com
Email: susan.engel@lw.com
Email: christian.word@lw.com
Email: matthew.peters@lw.com
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 21 of 64

- 6 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Jeff G. Hammel
Kalana Kariyawasam
1271 Avenue of the Americas
New York, NY 10020
Telephone: +1.212.906.1200
Email: jeff.hammel@lw.com
Email: kalana.kariyawasam@lw.com
Robin Spedding
99 Bishopsgate, EC2M 3XF
London
Telephone: +44.20.7710.1193
Email: robin.spedding@lw.com
Anna Kullmann
99 Bishopsgate, EC2M 3XF
London
Telephone: +44.20.7710.1135
Email: anna.kullmann@lw.com
FENNEMORE CRAIG, P.C.
Douglas C. Northup (No. 013987)
Andrea L. Marconi (No. 022577)
2394 E. Camelback Road, Suite 600
Phoenix, AZ 85016
Telephone: +1.602.916.5000
Email: dnorthup@fennemorelaw.com
Email: amarconi@fennemorelaw.com
c. Other Parties:
Defendant Ernest Garcia II
DLA PIPER LLP (US)
Madeline A. Cordray
madeline.cordray@us.dlapiper.com
2525 East Camelback Road, Suite 1000
Phoenix, Arizona 85016
Tel: 480.606.5100
DLA PIPER LLP (US)
Melanie Walker
melanie.walker@us.dlapiper.com
2000 Avenue of the Stars #400,
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 22 of 64

- 7 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Los Angeles, California 90067
Tel: 310.595.3000
DLA PIPER LLP (US)
Yan Grinblat
yan.grinblat@us.dlapiper.com
444 West Lake Street, Suite 900
Chicago, Illinois 60606
Tel: 312.368.4000
Defendants Citigroup Global Markets Inc. and J.P. Morgan Securities LLC
PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
Susanna M. Buergel
David P. Friedman
1285 Avenue of the Americas
New York, New York 10019
Telephone: (212) 373-3000
Email: sbuergel@paulweiss.com
Email: dfriedman@paulweiss.com
FENNEMORE CRAIG, P.C.
Douglas C. Northup
Andrea L. Marconi
2394 E. Camelback Road, Suite 600
Phoenix, Arizona 85016
Telephone: (602) 916-5000
Email: dnorthup@fennemorelaw.com
Email: amarconi@fennemorelaw.com
7. Nature of the proceedings:
This is a putative class action lawsuit in which Lead Plaintiffs UANPF and SHEPP
(“Plaintiffs”) allege that Carvana, a U.S. publicly-traded online used-car retailer, and other
Carvana Defendants, who are officers and directors of Carvana, made materially
misleading statements and omissions in violation of U.S. federal securities laws.
Specifically, Plaintiffs allege Carvana Defendants concealed from investors that Carvana
was systematically violating laws governing vehicle title and registration requirements, a
practice which was allegedly driving Carvana’s retail sales, and also concealed that other
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 23 of 64

- 8 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
business practices—including certain car-buying practices, nationwide expansion, and
related-party transactions—were driving Carvana’s growth. Plaintiffs seek to represent
individuals and entities who purchased Carvana’s common stock between May 6, 2020 and
October 7, 2022 and were damaged by the purported misleading statements and omissions.
Plaintiffs also seek to represent individuals and entities who received Carvana stock
directly through Carvana’s April 22, 2022 secondary offering (the “Offering”). Plaintiffs
assert claims individually and on behalf of class members pursuant to Section 10(b) and
Section 20(a) of the Securities and Exchange Act of 1934 (15 U.S.C. §§78j(b) and 78t(a)),
and Sections 11, 12(a)(2), and 15 of the Securities Act of 1933 (15 U.S.C. §§77k, 77l(a)(2),
and 77o) (“Securities Act claims”). Plaintiffs bring this action to recover damages caused
by the Defendants’ alleged wrongdoings. Defendants dispute the allegations and intend to
argue at trial, among other things, that any allegedly omitted information was already
public and indeed known by many of the investors comprising the putative class, including
LGIM.
LGIM is one of thirty-four non-Carvana-affiliated investors (“allocants”) who
received stock directly in the Offering. As such, LGIM is a putative class member for
Plaintiffs’ Securities Act claims, meaning, if the class is certified and LGIM does not opt
out, that LGIM will technically be a party to the litigation and certain aspects of Carvana
Defendants’ liability to LGIM and other putative class members will be determined at trial.
An investor’s absence of knowledge of the allegedly omitted information is an element of
Plaintiffs’ Securities Act claim under Section 12(a)(2), 15 U.S.C. § 77l(a)(2), and such
knowledge is an affirmative defense to Plaintiffs’ Section 11 claim,15 U.S.C. § 77k(a).
Accordingly, LGIM’s actual knowledge of the allegedly omitted information is a
dispositive issue as to their Securities Act claims that Carvana Defendants will test at trial,
and LGIM’s diligence prior to participating in the Offering, including what documents and
sources they reviewed, and what information was material to their decision, is also relevant
to matters to be determined at trial.
Further, LGIM’s knowledge regarding the allegedly omitted information, bases for
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 24 of 64

- 9 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
LGIM’s participation in the Offering, and what sources they consulted, are also relevant to
whether class-wide claims may be decided at trial at all. In this action, the U.S. court may
certify a class for Plaintiffs’ Securities Act claims only if it determines that common
questions predominate over individual inquiries. Because investor knowledge of the
allegedly-omitted information defeats the Securities Act claims, if individual inquiries into
investor knowledge are necessary, they foreclose a finding of predominance and preclude
class certification. See Vignola v. Fat Brands, 2020 WL 1934976, at *5 (C.D. Cal. Mar.
13, 2020); In re Kosmos Energy Ltd. Sec. Litig., 299 F.R.D. 133, 152-54 (N.D. Tex. 2014).
Accordingly, investor knowledge—including LGIM’s knowledge—is determinative of
what claims may be adjudicated at trial.
LGIM’s transactions in Carvana securities (including its common stock) in the
relevant period in and around the 2022 Offering, including any gains or losses on such
purchases, are relevant to the determination of the quantum of damages LGIM may receive.
See 15 U.S.C. § 77k(e) (setting forth a statutory formula for calculation of damages for
Securities Act claims that takes into account, among other things, “the price at which such
security shall have been disposed of in the market before [the] suit” was brought). LGIM’s
transactions in Carvana stock are also relevant to other defenses Carvana Defendants may
assert to LGIM’s Securities Act claims at trial, including that the claims are barred, in
whole or in part, because LGIM did not lose money or property that is traceable to any
wrongful act by any Carvana Defendant and/or traceable to stock purchased in Carvana’s
April 2022 Offering, and any of LGIM’s alleged injuries, damages, or losses were caused
by acts of third parties or superseding and intervening events unconnected to and outside
the control of the Carvana Defendants.
8. Evidence to be obtained:
a. Evidence to be obtained or other judicial act to be performed:
Carvana Defendants seek documentary evidence from LGIM concerning LGIM’s
diligence and decision to participate in the Offering, and LGIM’s transactions in Carvana
securities in the relevant period around the 2022 Offering. In particular, LGIM researched
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 25 of 64

- 10 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
and considered information in connection with LGIM’s decision to participate in the
Offering. And LGIM’s transactions in Carvana securities are information uniquely in
LGIM’s possession that are directly relevant to the trial determination of any damages for
LGIM’s Securities Act claims. As such, LGIM possesses evidence that is relevant and
material to the outcome of Plaintiffs’ claims for the reasons given in Section 7 above.
Carvana Defendants have attempted to request the documents and information they now
seek directly from LGIM but were unsuccessful.
In particular, Carvana seeks production of the documents described in the attached
Schedule A below. Each of the categories of documents described in Schedule A is directly
relevant to the dispute before this Court.
b. Purpose of the evidence of judicial act sought:
Each of the categories of documents described in Schedule A is directly relevant to
the claims Plaintiffs assert against Carvana Defendants in this litigation and to Carvana
Defendants’ responses and defenses to those claims. Accordingly, the evidence Carvana
Defendants seek is needed to evaluate the merits of Plaintiffs’ claims. Further, the evidence
sought is or is likely to be, in the possession, custody, or power of LGIM. Carvana
Defendants have been unable to obtain the requested evidence from other sources,
notwithstanding its efforts. The Court considers that it is necessary for the purposes of
justice and the determination of the matters in dispute that the documents described at
Schedule A below are produced in these proceedings.
9. Identity and address of entity and deponents to provide evidence:
a) Legal General Investment Management Limited
One Coleman Street London, EC2R 5AA
United Kingdom
10. Questions to be put to the persons to be examined or statement of the subject-
matter about which they are to be examined:
None
11. Documents or other property to be inspected:
The documents described in the attached Schedule A below.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 26 of 64

- 11 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
It is requested that LGIM produce the documents requested in the attached Schedule
A no later than fourteen (14) days after service of the order of the High Court giving effect
to the Letter of Request.
12. Any requirement that the evidence be given on oath or affirmation and any
special form to be used:
None
13. Special Methods or Procedure to be Followed:
It is respectfully requested that the documents listed in Schedule A that are within
the possession, custody, or control of LGIM be produced electronically to Carvana’s
counsel at the following e-mail addresses no later than forty-five (45) days after receipt of
the Request: meryn.grant@lw.com, ashley.gebicke@lw.com, anna.kullmann@lw.com and
robin.spedding@lw.com. If electronic production to Carvana’s counsel via e-mail is not
possible, LGIM shall produce documents responsive to the Request through another
method of production to be agreed between the Defendants and LGIM.
14. Request for Notification of the Time and Place for the Execution of the Request
and Identity and Address of any Person to be Notified:
The following counsel shall be notified regarding the time and place for the
execution of the Request:
LATHAM & WATKINS LLP
Meryn C.N. Grant
10250 Constellation Blvd., Suite 1100
Los Angeles, CA 90067
Telephone: +1.424.653.5500
Email: meryn.grant@lw.com
LATHAM & WATKINS LLP
Andrew B. Clubok
Susan E. Engel
J. Christian Word
Matthew J. Peters
555 Eleventh Street, N.W., Suite 1000
Washington, D.C. 20004
Telephone: +1.202.637.2200
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 27 of 64

- 12 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Email: aclubok@lw.com
Email: susan.engel@lw.com
Email: christian.word@lw.com
Email: matthew.peters@lw.com
Jeff G. Hammel
Kalana Kariyawasam
1271 Avenue of the Americas
New York, NY 10020
Telephone: +1.212.906.1200
Email: jeff.hammel@lw.com
Email: kalana.kariyawasam@lw.com
Robin Spedding
99 Bishopsgate, EC2M 3XF
London
Telephone: +44.20.7710.1193
Email: robin.spedding@lw.com
Anna Kullmann
99 Bishopsgate, EC2M 3XF
London
Telephone: +44.20.7710.1135
Email: anna.kullmann@lw.com
15. Request for Attendance or Participation of Judicial Personnel of the
Requesting Authority at the Execution of the Letter of Request:
None
16. Specification of Privilege or Duty to Refuse to Give Evidence Under the Law
of the State of Origin:
Under the laws of the United States, a witness has a privilege to refuse to give
evidence if to do so would disclose a confidential communication between the witness and
his or her attorney that was communicated specifically for the purpose of obtaining legal
advice and which privilege has not been waived. United States law also recognizes a
privilege against criminal self-incrimination. Other limited privileges on grounds not
applicable here also exist, such as certain communications between doctors and patients,
husband and wife, and clergy and penitent. Certain limited immunities are also recognized
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 28 of 64

- 13 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
outside the strict definition of privilege, such as the limited protection of work product
created by attorneys during or in anticipation of litigation. Neither this Letter of Request,
nor the transmission or provision of any evidence pursuant hereto, shall waive, or be
deemed to have waived, any of the foregoing privileges, protections, or immunities, nor
any other privileges, protections, or immunities that may apply to such evidence under the
laws of England and Wales, the laws of the United States, the laws of Arizona, or of any
applicable State.
17. Fees and Costs:
Any fees and costs incurred which are reimbursable under the second paragraph of
article 14 or under article 26 of the Hague Evidence Convention will be borne by Carvana,
through its counsel of record: Meryn C.N. Grant, Latham & Watkins LLP, 10250
Constellation Blvd., Suite 1100 Los Angeles, CA 90067. Carvana’s payment of such fees
and costs (if any) is without prejudice to its making a subsequent request to be reimbursed
for these costs by other parties in this proceeding.
18. Date of Request:
August 12th, 2026
19. Signature of Requesting Authority:
Honorable John Z. Boyle
United States Magistrate Judge
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 29 of 64

- 14 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
SCHEDULE A: DOCUMENT REQUESTS
I. DEFINITIONS
1. “Action” shall mean the legal action In re Carvana Co. Securities Litigation, No.
2:22-cv-02126-PHX-MTL, United States District Court, District of Arizona, filed on
August 3, 2022.
2. “Amended Complaint” shall refer to the operative Amended Consolidated
Complaint filed in this Action on March 29, 2024, Dkt. No. 71.
3. “All,” “any,” and “each” shall mean and each be construed as encompassing any
and all.
4. “And” and “or” shall mean and be construed either disjunctively or conjunctively,
as necessary by the context, to bring within the scope of the topic for examination all
responses that might otherwise be construed to be outside of its scope by any other
construction.
5. “Carvana” shall refer to Defendant Carvana Co.
6. “Communication(s)” shall mean and refers to all evidence of the transmission of
information (in the form of facts, ideas, inquiries, or otherwise), record in LGIM’s
possession, custody, or control, transmitted between any Person or Persons and any other
Person or Persons, by or through any mode or medium, including but not limited to the
spoken word, written or electronic correspondence, electronic mail (e-mail), instant
messaging, telephone, facsimile, face-to-face meetings, through third Persons, and/or via
electronic recordings.
7. Concern,” “concerning,” “reflect,” “reflecting,” “related,” “relating,” “relate(s),”
“refer,” or “referring,” and other variations thereof, as used herein shall be construed in
their broadest possible sense, and shall mean without limitation and whether in whole or in
part: referring to, constituting, bearing upon, commenting upon, reflecting, evidencing,
pertaining to, describing, depicting, consisting of, containing, comprising, embodying,
identifying, stating, discussing, analyzing, studying, summarizing, dealing with, relating
to, or having any logical or factual connection whatsoever with the subject addressed,
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 30 of 64

- 15 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
regardless of whether the factual connection is favorable to or adverse to You.
8. “Document(s)” shall have the full meaning ascribed in Federal Rule of Civil
Procedure 34 and shall include every writing or record in LGIM’s possession, custody, or
control (including Electronically Stored Information) of every type and description such as
communications, correspondence, speech, writings, memoranda, stenographic or
handwritten notes, language (machine, foreign, or otherwise), studies, publications, books,
pamphlets, reports, financial statements, calculations, analyses, films, video tape,
photographs, graphs, symbols, signs, voice recordings, sound, radio and/or video signal,
telephone, teletype, telecommunication, photographic film of any type, e-mail, computer
electronics of any kind, computer files or all other data, compilations from which
information can be obtained, including electromagnetically sensitive stored media such as
hard discs, magnetic disks, and magnetic tapes, any preliminary versions, drafts or
revisions of any of the foregoing, and all copies of every such writing or record (or a draft
thereof) whenever a copy of a Document is not an identical copy of the original or where
such copy contains any commentary, notes or markings whatsoever that do not appear on
the original. The term Document(s) specifically includes Electronically Stored
Information.
9. “DriveTime” shall mean DriveTime Automotive Group Inc. and all of its
predecessors, affiliates, parents, and subsidiaries, including but not limited to DriveTime
Automotive Group Inc., as well as all agents, attorneys, consultants, directors, employees,
investors, members, managers, officers, principals, representatives, trustees, and all other
persons acting or purporting to act on behalf or under the control of the foregoing.
10. “Electronically Stored Information” or “ESI” shall mean and refers to information
that is stored electronically, regardless of the media or whether it is in the original format
in which it was created, as opposed to stored in hard copy (i.e., on paper). ESI carries the
broadest possible meaning consistent with Fed. R. Civ. P. 34(a) and Fed. R. Evid. 1001.
For the avoidance of doubt, any electronic Documents or data shall include their associated
metadata.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 31 of 64

- 16 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
11. “Expansions and Growth Strategies” shall refer to business strategies employed by
Carvana, such as: (1) prioritization of growth over profitability; (2) expansion nationwide,
including into new markets; (3) selling cars awaiting title and/or registration; (4) increases
in inventory, including by purchasing or permitting trade-ins of lower quality cars; and (5)
pass-through sales agreements with DriveTime.
12. “Including” shall mean “including, but not limited to” and shall not limit the scope
of any topic for examination.
13. “Individual Defendants” “Individual Defendants” shall refer to the following
individual defendants in the legal action In re Carvana Co. Securities Litigation, No. 2:22-
cv-02126-PHX-MTL, United States District Court, District of Arizona, filed on August 3,
2022: Ernest Garcia III, Mark Jenkins, Stephen Palmer, Michael Maroone, Neha Parikh,
Ira Platt, and Greg Sullivan.
14. “LGIM” shall mean Legal & General Investment Management Ltd. and all of its
predecessors, affiliates, parents, and subsidiaries, including but not limited to well as all
agents, attorneys, consultants, directors, employees, investors, members, managers,
officers, principals, representatives, trustees, and all other persons acting or purporting to
act on behalf or under the control of the foregoing.
15. “Offering” shall refer to Carvana’s April 22, 2022 secondary offering of Class A
common stock.
16. “Purchase” or “Sell” or “Sale” shall mean purchase, sell, trade, convert, otherwise
acquire or otherwise dispose of, particularly with respect to Securities, whether for Your
own account or benefit, or for the account or benefit of any other Person.
17. “Refer(s)” or “Relate(s)” shall mean and refers to comprise, concern, describe,
evidence, constitute, reflect, record, identify, memorialize, diminish, refute, discuss,
explain, specify, consider, embody, evaluate, analyze, review, respect, state, establish,
bolster, show, support, contradict, note, contain, mention, study, pertain to, report on,
comment on, impinge upon or impact the subject matter of the topic for examination, in
whole or in part, either directly or indirectly.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 32 of 64

- 17 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
18. “Relating to” shall mean and refers to relating to, pertaining to, referring to,
evidencing, in connection with, reflecting, respecting, concerning, compromising, based
upon, stating, showing, considering, establishing, supporting, bolstering, explaining,
contradicting,refuting, diminishing, constituting, describing, recording, noting,
embodying, memorializing, containing, mentioning, reviewing, studying, analyzing,
evaluating, reporting, commenting, discussing, specifying, identifying, impinging upon or
impacting in any other way bearing on the matter addressed in the topics for examination,
in whole or in part, either directly or indirectly.
19. “Security” or “Securities” shall mean any common stock, preferred stock,
debenture, option, or other debt or equity interest, and any direct or indirect, legal, or
beneficial interest.
20. “Transaction(s)” shall mean any purchases, acquisitions, sales, dispositions,
tenders, donations, receipt, gifts, transfers, puts, call, short sales, execution of any option
contracts, or any other means by which You acquired or disposed of any interest in
Securities, whether for Your own account or benefit or for the account or benefit of any
other Person.
21. “You,” and “Your” shall mean and refer to LGIM, as defined herein.
22. The use of the singular form of any word shall include the plural form of the same
word and vice versa.
All defined terms shall retain their meaning even if not capitalized in these topics for
examination.
II. INSTRUCTIONS
The following instructions apply to each document request set forth below.
1. All Requests shall be construed pursuant to the applicable Federal Rules of Civil
Procedure, except to the extent incompatible with English law.
2. In responding to these Requests, You are required to furnish Documents that are in
Your possession, custody, or control, including Documents in the possession of Your
present and former attorneys, accountants, advisors, representatives, agents, or employees
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 33 of 64

- 18 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
(to the extent these are in Your control). All Documents that respond, in whole or in part,
to any portion of the Requests below shall be produced in their entirety, including all
attachments and enclosures.
3. If there are no Documents or things responsive to a particular Request, You should
so state in writing.
4. Each and every copy of a Document, that is different from the original because of
stamps, indications of the recipient(s), handwritten notes, marks, attachments, or any other
reason, is a separate Document that must be produced.
5. If You produce any tape, disk, card, wire, or other electronic or mechanical
recording or transcript, or any computer program in response to any Request, You shall
also produce such documents, software, and instructions as are necessary for the decoding,
playing back, printing, and/or interpretation thereof, and any other documents that are
necessary to convert said information into a useable format.
6. If any information requested is claimed to be privileged or otherwise immune from
discovery, please provide all information falling within the scope of the Request which is
not privileged, and for each item of information contained in a Document or
Communication to which a claim of privilege is made, identify such Document or
Communication with sufficient particularity for purposes of a motion to compel, such
identification to include at least the basis on which the privilege is claimed.
III. REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST FOR PRODUCTION NO. 1:
All Documents and Communications in LGIM’s possession, custody, or control
Concerning Your knowledge and research Relating to Carvana Securities from May 6,
2020 through October 7, 2022, including analyst reports, articles, recommendations, notes,
memoranda, opinions, ratings, valuations, and investor materials (such as road show decks,
shareholder letters).
REQUEST FOR PRODUCTION NO. 2:
All Documents and Communications in LGIM’s possession, custody, or control
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 34 of 64

- 19 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Concerning Your knowledge, analysis, and research of Carvana’s compliance with state
and local title and registration laws, including any lawsuits or regulatory actions related
thereto, from May 6, 2020 through October 7, 2022.
REQUEST FOR PRODUCTION NO. 3:
All Documents and Communications in LGIM’s possession, custody, or control
Concerning Your knowledge, analysis, and research of Carvana’s retail unit sales,
including drivers of its sales growth from May 6, 2020 through October 7, 2022.
REQUEST FOR PRODUCTION NO. 4:
All Documents in LGIM’s possession, custody, or control sufficient to reflect Your
Transactions in Carvana Securities and any accompanying gains or losses from May 6,
2020 through October 7, 2022, such as, for example, a trading list.
REQUEST FOR PRODUCTION NO. 5:
All Documents and Communications in LGIM’s possession, custody, or control
from May 6, 2020 through April 26, 2022, Concerning the basis for Your decision to
participate in the Offering, including any Documents You relied upon, consulted, or
considered.
REQUEST FOR PRODUCTION NO. 6:
All Documents and Communications in LGIM’s possession, custody, or control
Concerning any gains or losses from May 6, 2020 through October 7, 2022 on Your
investments in Carvana Securities purchased in the Offering.
REQUEST FOR PRODUCTION NO. 7:
All Documents and Communications in LGIM’s possession, custody or control
Concerning public disclosures from May 6, 2020 through October 7, 2022 made by, or on
behalf of Carvana, or other publicly available news articles, reports, or other information,
regarding:
(i) Carvana’s compliance with state and local title and registration laws, including
any lawsuits or regulatory actions related thereto;
(ii) Carvana’s retail unit sales, including drivers of its sales growth; and
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 35 of 64

- 20 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
(iii) Carvana’s Expansion and Growth Strategies.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 36 of 64

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
LETTER OF REQUEST NO. 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
United Association National Pension Fund, et
al.,
Plaintiffs,
v.
Carvana Company, et al.,
Respondents.
No. CV-22-02126-PHX-MTL
REQUEST FOR INTERNATIONAL
JUDICIAL ASSISTANCE PURSUANT
TO THE HAGUE CONVENTION OF
18 MARCH 1970 ON THE TAKING OF
EVIDENCE ABROAD IN CIVIL OR
COMMERCIAL MATTERS
TO THE SENIOR MASTER OF THE KING’S BENCH DIVISION OF THE HIGH
COURT OF JUSTICE OF ENGLAND AND WALES:
The United States District Court for the District of Arizona respectfully requests
judicial assistance pursuant to the Hague Convention of 18 March 1970 on the Taking of
Evidence Abroad in Civil or Commercial Matters (the “Hague Evidence Convention”), to
which both the United States and the United Kingdom are parties, to obtain documentary
evidence and oral testimony to be used at the trial of pending civil proceeding before this
Court in the above-captioned matter. The United States District Court for the District of
Arizona is a competent court of law and equity which properly has jurisdiction over this
proceeding and has the power to compel the production of documents and the attendance
of witnesses both within and outside its jurisdiction.
This Court respectfully asks that this Letter of Request be executed, and that
Defendants be permitted to obtain documentary evidence sought from Pelham Capital Ltd.
(“Pelham”) and oral testimony from Kavyan Larizadeh, an employee of Pelham.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 37 of 64

- 2 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
This Court considers that the evidence sought herein is directly relevant to the issues
in dispute for determination at trial, is evidence intended for use at trial, and without which
the ends of justice could not be properly met. This Court also believes that this evidence is
available to Pelham and Mr. Larizadeh and not available from any other source. This
request is made with the understanding that it will in no way require any person to commit
any offense, or to undergo a broader form of inquiry than he or she would if the litigation
were conducted in England and Wales. In the proper exercise of its authority, this Court
has determined that the documentary evidence and oral testimony are highly relevant to the
determination of these proceedings and cannot be secured except by the intervention of the
Senior Master of the King’s Bench Division of the High Court of Justice of England and
Wales.
1. Sender:
Honorable John Z. Boyle
United States Magistrate Judge
United States District Court, District of Arizona
Sandra Day O’Connor U.S. Courthouse, Suite 322
401 West Washington Street, SPC 75
Phoenix, AZ 85003-2160
United States of America
2. Central authority of the requested state:
The Senior Master of the King’s Bench Division of the High Court
Foreign Process Section
Room E16
Royal Courts of Justice
Strand
London WC2A 2LL
United Kingdom
Tel: +44 207 947 7772
E-mail: foreignprocess.rcj@justice.gov.uk
3. Person(s) to whom the executed request is to be returned:
Meryn C.N. Grant
Latham & Watkins LLP
10250 Constellation Blvd., Suite 1100
Los Angeles, CA 90067
Telephone: +1.424.653.5500
Email: meryn.grant@lw.com
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 38 of 64

- 3 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4. Specification of the date by which the requesting authority requires receipt of
the response to the letter request:
Date: As soon as reasonably practical consistent with the receiving Court’s calendar.
Reason for Urgency: The deadline for Defendants Carvana Co. (“Carvana”), Ernest
Garcia III, Mark Jenkins, Stephen Palmer, Michael Maroone, Neha Parikh, Ira Platt, and
Greg Sullivan (collectively, the “Carvana Defendants”), to collect all non-expert evidence
for trial has been set for October 2, 2026, and Carvana Defendants have been otherwise
unable to obtain the requested documentary evidence and testimony. A trial date for this
litigation has not yet been set.
5. In conformity with Article 3 of the Convention, the undersigned applicant has
the honor to submit the following request:
a. Requesting Authority:
Honorable John Z. Boyle
United States Magistrate Judge
United States District Court, District of Arizona
Sandra Day O’Connor U.S. Courthouse, Suite 322
401 West Washington Street, SPC 75
Phoenix, AZ 85003-2160
United States of America
b. To the Competent Authority of:
The United Kingdom
The Senior Master of the King’s Bench Division of the High Court
Foreign Process Section
Room E16
Royal Courts of Justice
Strand
London WC2A 2LL
United Kingdom
c. Name of the Case and Identifying Number:
In re Carvana Co. Securities Litigation
Case No. 2:22-cv-02126-PHX-MTL, pending before U.S. District Judge
Michael T. Liburdi (presiding) and U.S. Magistrate Judge John Z. Boyle
(referred for discovery matters) in the United States District Court for the
District of Arizona
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 39 of 64

- 4 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
6. Names and addresses of the parties and their representatives:
a. Plaintiffs:
Saskatchewan Healthcare Employees’ Pension Plan (“SHEPP”) and United
Association National Pension Fund (“UANPF”)
ROBBINS GELLER RUDMAN & DOWD LLP
DANIEL S. DROSMAN
TOR GRONBORG
ERIKA L. OLIVER
RACHEL A. COCALIS
SARAH A. FALLON
DANIEL S. DROSMAN
655 West Broadway, Suite 1900
San Diego, CA 92101
Telephone: 619/231-1058
619/231-7423 (fax)
ddrosman@rgrdlaw.com
torg@rgrdlaw.com
eoliver@rgrdlaw.com
rcocalis@rgrdlaw.com
sfallon@rgrdlaw.com
ROBBINS GELLER RUDMAN & DOWD LLP
ROBERT M. ROTHMAN
DAVID A. ROSENFELD
BRENT E. MITCHELL
58 South Service Road, Suite 200
Melville, NY 11747
Telephone: 631/367-7100
631/367-1173 (fax)
rrothman@rgrdlaw.com
drosenfeld@rgrdlaw.com
bmitchell@rgrdlaw.com
ROBBINS GELLER RUDMAN & DOWD LLP
JACOB G. GELMAN
Post Montgomery Center
One Montgomery Street, Suite 1800
San Francisco, CA 94104
Telephone: 415/288-4545
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 40 of 64

- 5 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
415/288-4534 (fax)
jgelman@rgrdlaw.com
O’DONOGHUE & O’DONOGHUE LLP
DINAH S. LEVENTHAL
5301 Wisconsin Avenue, N.W., Suite 800
Washington, D.C. 20015
Telephone: 202/362-0041
202/362-2640 (fax)
dleventhal@odonoghuelaw.com
BONNETT FAIRBOURN FRIEDMAN & BALINT PC
ANDREW FRIEDMAN
7301 N. 16th Street, Suite 102
Phoenix, AZ 85020
Telephone: 602/274-1100
602/274-1199 (fax)
afriedman@bffb.com
b. Carvana Defendants:
Carvana Co., Ernest Garcia III, Mark Jenkins, Stephen Palmer, Michael
Maroone, Neha Parikh, Ira Platt, and Greg Sullivan
LATHAM & WATKINS LLP
Meryn C.N. Grant
10250 Constellation Blvd., Suite 1100
Los Angeles, CA 90067
Telephone: +1.424.653.5500
Email: meryn.grant@lw.com
LATHAM & WATKINS LLP
Andrew B. Clubok
Susan E. Engel
J. Christian Word
Matthew J. Peters
555 Eleventh Street, N.W., Suite 1000
Washington, D.C. 20004
Telephone: +1.202.637.2200
Email: aclubok@lw.com
Email: susan.engel@lw.com
Email: christian.word@lw.com
Email: matthew.peters@lw.com
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 41 of 64

- 6 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Jeff G. Hammel
Kalana Kariyawasam
1271 Avenue of the Americas
New York, NY 10020
Telephone: +1.212.906.1200
Email: jeff.hammel@lw.com
Email: kalana.kariyawasam@lw.com
Robin Spedding
99 Bishopsgate, EC2M 3XF
London
Telephone: +44.20.7710.1193
Email: robin.spedding@lw.com
Anna Kullmann
99 Bishopsgate, EC2M 3XF
London
Telephone: +44.20.7710.1135
Email: anna.kullmann@lw.com
FENNEMORE CRAIG, P.C.
Douglas C. Northup (No. 013987)
Andrea L. Marconi (No. 022577)
2394 E. Camelback Road, Suite 600
Phoenix, AZ 85016
Telephone: +1.602.916.5000
Email: dnorthup@fennemorelaw.com
Email: amarconi@fennemorelaw.com
c. Other Parties:
Defendant Ernest Garcia II
DLA PIPER LLP (US)
Madeline A. Cordray
madeline.cordray@us.dlapiper.com
2525 East Camelback Road, Suite 1000
Phoenix, Arizona 85016
Tel: 480.606.5100
DLA PIPER LLP (US)
Melanie Walker
melanie.walker@us.dlapiper.com
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 42 of 64

- 7 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2000 Avenue of the Stars #400,
Los Angeles, California 90067
Tel: 310.595.3000
DLA PIPER LLP (US)
Yan Grinblat
yan.grinblat@us.dlapiper.com
444 West Lake Street, Suite 900
Chicago, Illinois 60606
Tel: 312.368.4000
Defendants Citigroup Global Markets Inc. and J.P. Morgan Securities LLC
PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP
Susanna M. Buergel
David P. Friedman
1285 Avenue of the Americas
New York, New York 10019
Telephone: (212) 373-3000
Email: sbuergel@paulweiss.com
Email: dfriedman@paulweiss.com
FENNEMORE CRAIG, P.C.
Douglas C. Northup
Andrea L. Marconi
2394 E. Camelback Road, Suite 600
Phoenix, Arizona 85016
Telephone: (602) 916-5000
Email: dnorthup@fennemorelaw.com
Email: amarconi@fennemorelaw.com
7. Nature of the proceedings:
This is a putative class action lawsuit in which Lead Plaintiffs UANPF and SHEPP
(“Plaintiffs”) allege that Carvana, a U.S. publicly-traded online used-car retailer, and other
Carvana Defendants, who are officers and directors of Carvana, made materially
misleading statements and omissions in violation of U.S. federal securities laws.
Specifically, Plaintiffs allege Carvana Defendants concealed from investors that Carvana
was systematically violating laws governing vehicle title and registration requirements, a
practice which was allegedly driving Carvana’s retail sales, and also concealed that other
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 43 of 64

- 8 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
business practices—including certain car-buying practices, nationwide expansion, and
related-party transactions—were driving Carvana’s growth. Plaintiffs seek to represent
individuals and entities who purchased Carvana’s common stock between May 6, 2020 and
October 7, 2022 and were damaged by the purported misleading statements and omissions.
Plaintiffs also seek to represent individuals and entities who received Carvana stock
directly through Carvana’s April 22, 2022 secondary offering (the “Offering”). Plaintiffs
assert claims individually and on behalf of class members pursuant to Section 10(b) and
Section 20(a) of the Securities and Exchange Act of 1934 (15 U.S.C. §§78j(b) and 78t(a)),
and Sections 11, 12(a)(2), and 15 of the Securities Act of 1933 (15 U.S.C. §§77k, 77l(a)(2),
and 77o) (“Securities Act claims”). Plaintiffs bring this action to recover damages caused
by the Defendants’ alleged wrongdoings. Defendants dispute the allegations and intend to
argue at trial, among other things, that: any allegedly omitted information was already
public and indeed known by many of the investors comprising the putative class, including
Pelham.
Pelham is one of thirty-four non-Carvana-affiliated investors (“allocants”) who
received stock directly in the Offering. As such, Pelham is a putative class member for
Plaintiffs’ Securities Act claims, meaning, if the class is certified and Pelham does not opt
out, that Pelham will technically be a party to the litigation and certain aspects of Carvana
Defendants’ liability to Pelham and other putative class members will be determined at
trial. To Carvana Defendants’ knowledge, Mr. Kavyan Larizadeh was the primary contact
at Pelham with respect to Pelham’s decision to participate in the Offering. An investor’s
absence of knowledge of the allegedly omitted information is an element of Plaintiffs’
Securities Act claim under Section 12(a)(2), 15 U.S.C. § 77l(a)(2), and such knowledge is
an affirmative defense to Plaintiffs’ Section 11 claim,15 U.S.C. § 77k(a). Accordingly,
Pelham’s actual knowledge of the allegedly omitted information is a dispositive issue as to
their Securities Act claims that Carvana Defendants will test at trial, and Pelham and Mr.
Larizadeh’s diligence prior to participating in the Offering, including what documents and
sources they reviewed, and what information was material to their decision, is also relevant
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 44 of 64

- 9 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
to matters to be determined at trial.
Further, Pelham and Mr. Larizadeh’s knowledge regarding the allegedly omitted
information, bases for Pelham’s participation in the Offering, and what sources they
consulted, are also relevant to whether class-wide claims may be decided at trial at all. In
this action, the U.S. court may certify a class for Plaintiffs’ Securities Act claims only if it
determines that common questions predominate over individual inquiries. Because investor
knowledge of the allegedly-omitted information defeats the Securities Act claims, if
individual inquiries into investor knowledge are necessary, they foreclose a finding of
predominance and preclude class certification. See Vignola v. Fat Brands, 2020 WL
1934976, at *5 (C.D. Cal. Mar. 13, 2020); In re Kosmos Energy Ltd. Sec. Litig., 299 F.R.D.
133, 152-54 (N.D. Tex. 2014). Accordingly, investor knowledge—including LGIM’s
knowledge—is determinative of what claims may be adjudicated at trial.
Pelham’s transactions in Carvana securities (including its common stock) in the
relevant period in and around the 2022 Offering, including any gains or losses on such
purchases, are relevant to the determination of the quantum of damages Pelham may
receive. See 15 U.S.C. § 77k(e) (setting forth a statutory formula for calculation of damages
for Securities Act claims that takes into account, among other things, “the price at which
such security shall have been disposed of in the market before [the] suit” was brought).
Pelham’s transactions in Carvana stock are also relevant to other defenses Carvana
Defendants may assert to Pelham’s Securities Act claims at trial, including that the claims
are barred, in whole or in part, because Pelham did not lose money or property that is
traceable to any wrongful act by any Carvana Defendant and/or traceable to stock
purchased in Carvana’s April 2022 Offering, and any of Pelham’s alleged injuries,
damages, or losses were caused by acts of third parties or superseding and intervening
events unconnected to and outside the control of the Carvana Defendants.
8. Evidence to be obtained:
a. Evidence to be obtained or other judicial act to be performed:
Carvana Defendants seek documentary evidence from Pelham, and oral evidence
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 45 of 64

- 10 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
from Kavyan Larizadeh concerning Pelham’s diligence and decision to participate in the
Offering, and Pelham’s transactions in Carvana securities in the relevant period around the
2022 Offering. In particular, Pelham and, to Carvana Defendants’ knowledge, Mr.
Larizadeh, researched and considered information in connection with Pelham’s decision to
participate in the Offering. And Pelham’s transactions in Carvana securities are
information uniquely in Pelham’s possession that are directly relevant to the trial
determination of any damages for Pelham’s Securities Act claims. As such, Pelham and
Mr. Larizadeh possess evidence that is relevant and material to the outcome of Plaintiffs’
claims for the reasons given in Section 7 above. Carvana Defendants have attempted to
request the documents and information they now seek directly from Pelham but were
unsuccessful.
In particular, Carvana seeks production of the documents described in the attached
Schedule B below. Each of the categories of documents described in Schedule B is directly
relevant to the dispute before this Court. Carvana also seeks oral testimony from Mr.
Larizadeh in accordance with the examination topics described in the attached Schedule A
below. Each of the examination topics described in Schedule A is directly relevant to the
dispute before this Court.
b. Purpose of the evidence of judicial act sought:
Each of the examination topics described in Schedule A and each of the categories
of documents described in Schedule B are directly relevant to the claims Plaintiffs assert
against Carvana Defendants in this litigation and to Carvana Defendants’ responses and
defenses to those claims. Accordingly, the evidence Carvana Defendants seek is needed to
evaluate the merits of Plaintiffs’ claims and to defend against them at trial. Further, the
evidence sought is or is likely to be, in the possession, custody, or power of Pelham, and
known by Mr. Larizadeh. Carvana Defendants have been unable to obtain the requested
evidence from other sources, notwithstanding its efforts. The Court considers that it is
necessary for the purposes of justice and the determination of the matters in dispute that
the deposition testimony set out at Schedule A and the documents described at Schedule B
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 46 of 64

- 11 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
below are produced in these proceedings.
9. Identity and address of entity and deponents to provide evidence:
a) Pelham Capital Limited
25 Bury Street
London, SW1Y 6AL
United Kingdom
b) Kavyan Larizadeh
25 Bury Street
London, SW1Y 6AL
United Kingdom
10. Questions to be put to the persons to be examined or statement of the subject-
matter about which they are to be examined:
See Schedule A (TOPICS FOR EXAMINATION).
11. Documents or other property to be inspected:
The documents described in the attached Schedule B below.
It is requested that Pelham produce the documents requested in the attached
Schedule A no later than fourteen (14) days prior to the date scheduled for the examination
of Mr. Larizadeh.
12. Any requirement that the evidence be given on oath or affirmation and any
special form to be used:
This Court requests that the witness to be examined be placed under oath before
answering questions. The requested form of the oath is: “Do you solemnly state that the
testimony you will give in this deposition proceeding will be the truth, the whole truth, and
nothing but the truth?”
13. Special Methods or Procedure to be Followed:
This Court respectfully requests that the following special procedures be observed
in respect of the oral testimony of Mr. Larizadeh:
1) That only the parties’ representatives or their designees, interpreters, a
court reporter or stenographer, a videographer, and counsel for the
witness, if so desired by the witness, be permitted to attend and participate
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 47 of 64

- 12 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
at the examination.
2) That the witness be placed under oath pursuant to the United States
Federal Rules of Civil Procedure, and that the examination be taken under
the United States Federal Rules of Civil Procedure, except to the extent
that such procedure is incompatible with English law.
3) That counsel for the witness, if so desired by the witness, be permitted to
defend the examination pursuant to the United States Federal Rules of
Civil Procedure, except to the extent that such procedure is incompatible
with English law.
4) That Plaintiffs’ counsel, with authorization of this Court, be permitted to
attend and participate in the witness’s examination, and that Carvana’s
counsel (including United States counsel), as well as counsel for other
Defendants in the action, with authorization of this Court, be permitted to
attend and participate in the witness’s examination, and to conduct
examination, cross-examination and re-examination of the witness
(including asking open, closed, and leading questions).
5) That a court reporter be present to record verbatim the witness’s
examination for the purpose of preparing a true and correct transcript of
the examination.
6) That the witness be required to review, correct, and sign the verbatim
transcript within 14 days after the transcript is furnished to the witness.
7) That the oral examination be video recorded.
8) That objections that may be raised during the examination, including as
to the admissibility of testimony or propriety of a question or the manner
in which a question is asked, be noted for the record but not otherwise
resolved during the examination.
9) That the witness be examined as soon as practical.
10) That the testimony be allowed to continue until completed, except that
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 48 of 64

- 13 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
the testimony shall not exceed seven hours on the record per day and more
than two days for the witness. Additionally, the testimony shall be limited
to 10 hours total.
11) That the examination shall take place at Latham & Watkins’ London
Office, 99 Bishopsgate, London EC2M 3XF, United Kingdom.
12) That the Stipulated Protective Order in this action (Dkt. No. 130) governs
the use, disclosure, and confidentiality of any documents, testimony, or
evidence provided pursuant to this letter of request and that any party may
designate such testimony or evidence as Confidential or Highly
Confidential.
13) That, to the extent that any portion of this Letter of Request cannot be
granted, it is respectfully requested that the remaining parts be granted.
Furthermore, if Mr. Larizadeh has any grounds to claim privilege under English or
United States law, he may assert such privilege during the examination. The issue of
whether potential testimony is privileged under United States law shall be submitted to the
United States District Court for the District of Arizona for its ruling. If Mr. Larizadeh
objects to providing testimony on the grounds that the testimony is privileged under
English law, the issue shall be submitted to and determined by the High Court of England
and Wales.
As to Carvana’s document requests, it is respectfully requested that the documents
listed in Schedule B that are within the possession, custody, or control of Pelham be
produced electronically to Carvana’s counsel at the following e-mail addresses no later
than forty-five (45) days after receipt of the Request: meryn.grant@lw.com,
ashley.gebicke@lw.com, anna.kullmann@lw.com and robin.spedding@lw.com. If
electronic production to Carvana’s counsel via e-mail is not possible, Pelham shall produce
documents responsive to the Request through another method of production to be agreed
between the Defendants and Pelham.
//
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 49 of 64

- 14 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
14. Request for Notification of the Time and Place for the Execution of the Request
and Identity and Address of any Person to be Notified:
As to the deposition of Mr. Larizadeh, it is respectfully requested that the
examination take place as soon as reasonably possible but in no case later than ten (10)
weeks after the date signed below. Further, the examination can be conducted at the
following address: Latham & Watkins’ London Office, 99 Bishopsgate, London EC2M
3XF, United Kingdom or, if that is not possible, at a location determined to be mutually
agreeable to Mr. Larizadeh and the parties.
The following counsel shall be notified regarding the time and place for the
execution of the Request:
LATHAM & WATKINS LLP
Meryn C.N. Grant
10250 Constellation Blvd., Suite 1100
Los Angeles, CA 90067
Telephone: +1.424.653.5500
Email: meryn.grant@lw.com
LATHAM & WATKINS LLP
Andrew B. Clubok
Susan E. Engel
J. Christian Word
Matthew J. Peters
555 Eleventh Street, N.W., Suite 1000
Washington, D.C. 20004
Telephone: +1.202.637.2200
Email: aclubok@lw.com
Email: susan.engel@lw.com
Email: christian.word@lw.com
Email: matthew.peters@lw.com
Jeff G. Hammel
Kalana Kariyawasam
1271 Avenue of the Americas
New York, NY 10020
Telephone: +1.212.906.1200
Email: jeff.hammel@lw.com
Email: kalana.kariyawasam@lw.com
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 50 of 64

- 15 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Robin Spedding
99 Bishopsgate, EC2M 3XF
London
Telephone: +44.20.7710.1193
Email: robin.spedding@lw.com
Anna Kullmann
99 Bishopsgate, EC2M 3XF
London
Telephone: +44.20.7710.1135
Email: anna.kullmann@lw.com
15. Request for Attendance or Participation of Judicial Personnel of the
Requesting Authority at the Execution of the Letter of Request:
None
16. Specification of Privilege or Duty to Refuse to Give Evidence Under the Law
of the State of Origin:
Under the laws of the United States, a witness has a privilege to refuse to give
evidence if to do so would disclose a confidential communication between the witness and
his or her attorney that was communicated specifically for the purpose of obtaining legal
advice and which privilege has not been waived. United States law also recognizes a
privilege against criminal self-incrimination. Other limited privileges on grounds not
applicable here also exist, such as certain communications between doctors and patients,
husband and wife, and clergy and penitent. Certain limited immunities are also recognized
outside the strict definition of privilege, such as the limited protection of work product
created by attorneys during or in anticipation of litigation. Neither this Letter of Request,
nor the transmission or provision of any evidence pursuant hereto, shall waive, or be
deemed to have waived, any of the foregoing privileges, protections, or immunities, nor
any other privileges, protections, or immunities that may apply to such evidence under the
laws of England and Wales, the laws of the United States, the laws of Arizona, or of any
applicable State.
//
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 51 of 64

- 16 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
17. Fees and Costs:
Any fees and costs incurred which are reimbursable under the second paragraph of
article 14 or under article 26 of the Hague Evidence Convention will be borne by Carvana,
through its counsel of record: Meryn C.N. Grant, Latham & Watkins LLP, 10250
Constellation Blvd., Suite 1100 Los Angeles, CA 90067. Carvana’s payment of such fees
and costs (if any) is without prejudice to its making a subsequent request to be reimbursed
for these costs by other parties in this proceeding.
18. Date of Request:
August 12th, 2026
19. Signature of Requesting Authority:
Honorable John Z. Boyle
United States Magistrate Judge
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 52 of 64

- 17 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
SCHEDULE A: SWORN EXAMINATION TOPICS
I. DEFINITIONS
1. “Action” shall mean the legal action In re Carvana Co. Securities Litigation, No.
2:22-cv-02126-PHX-MTL, United States District Court, District of Arizona, filed on
August 3, 2022.
2. “Amended Complaint” shall refer to the operative Amended Consolidated
Complaint filed in this Action on March 29, 2024, Dkt. No. 71.
3. “All,” “any,” and “each” shall mean and each be construed as encompassing any
and all.
4. “And” and “or” shall mean and be construed either disjunctively or conjunctively,
as necessary by the context, to bring within the scope of the topic for examination all
responses that might otherwise be construed to be outside of its scope by any other
construction.
5. “Carvana” shall refer to Defendant Carvana Co.
6. “Communication(s)” shall mean and refers to all evidence of the transmission of
information (in the form of facts, ideas, inquiries, or otherwise), transmitted between any
Person or Persons and any other Person or Persons, by or through any mode or medium,
including but not limited to the spoken word, written or electronic correspondence,
electronic mail (e-mail), instant messaging, telephone, facsimile, face-to-face meetings,
through third Persons, and/or via electronic recordings.
7. “Document(s)” shall have the full meaning ascribed in Federal Rule of Civil
Procedure 34 and shall include every writing or record (including Electronically Stored
Information) of every type and description such as communications, correspondence,
speech, writings, memoranda, stenographic or handwritten notes, language (machine,
foreign, or otherwise), studies, publications, books, pamphlets, reports, financial
statements, calculations, analyses, films, video tape, photographs, graphs, symbols, signs,
voice recordings, sound, radio and/or video signal, telephone, teletype, telecommunication,
photographic film of any type, e-mail, computer electronics of any kind, computer files or
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 53 of 64

- 18 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
all other data, compilations from which information can be obtained, including
electromagnetically sensitive stored media such as hard discs, magnetic disks, and
magnetic tapes, any preliminary versions, drafts or revisions of any of the foregoing, and
all copies of every such writing or record (or a draft thereof) whenever a copy of a
Document is not an identical copy of the original or where such copy contains any
commentary, notes or markings whatsoever that do not appear on the original. The term
Document(s) specifically includes Electronically Stored Information.
8. “DriveTime” shall mean DriveTime Automotive Group Inc. and all of its
predecessors, affiliates, parents, and subsidiaries, including but not limited to DriveTime
Automotive Group Inc., as well as all agents, attorneys, consultants, directors, employees,
investors, members, managers, officers, principals, representatives, trustees, and all other
persons acting or purporting to act on behalf or under the control of the foregoing.
9. “Electronically Stored Information” or “ESI” shall mean and refers to information
that is stored electronically, regardless of the media or whether it is in the original format
in which it was created, as opposed to stored in hard copy (i.e., on paper). ESI carries the
broadest possible meaning consistent with Fed. R. Civ. P. 34(a) and Fed. R. Evid. 1001.
For the avoidance of doubt, any electronic Documents or data shall include their associated
metadata.
10. “Expansions and Growth Strategies” shall refer to business strategies employed by
Carvana, such as: (1) prioritization of growth over profitability; (2) expansion nationwide,
including into new markets; (3) selling cars awaiting title and/or registration; (4) increases
in inventory, including by purchasing or permitting trade-ins of lower quality cars; and (5)
pass-through sales agreements with DriveTime.
11. “Including” shall mean “including, but not limited to” and shall not limit the scope
of any topic for examination.
12. “Pelham” shall mean Pelham Capital Ltd. and all of its predecessors, affiliates,
parents, and subsidiaries, including but not limited to well as all agents, attorneys,
consultants, directors, employees, investors, members, managers, officers, principals,
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 54 of 64

- 19 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
representatives, trustees, and all other persons acting or purporting to act on behalf or under
the control of the foregoing.
13. “Offering” shall refer to Carvana’s April 22, 2022 secondary offering of Class A
common stock.
14. “Purchase” or “Sell” or “Sale” shall mean purchase, sell, trade, convert, otherwise
acquire or otherwise dispose of, particularly with respect to Securities, whether for Your
own account or benefit, or for the account or benefit of any other Person.
15. “Refer(s)” or “Relate(s)” shall mean and refers to comprise, concern, describe,
evidence, constitute, reflect, record, identify, memorialize, diminish, refute, discuss,
explain, specify, consider, embody, evaluate, analyze, review, respect, state, establish,
bolster, show, support, contradict, note, contain, mention, study, pertain to, report on,
comment on, impinge upon or impact the subject matter of the topic for examination, in
whole or in part, either directly or indirectly.
16. “Relating to” shall mean and refers to relating to, pertaining to, referring to,
evidencing, in connection with, reflecting, respecting, concerning, compromising, based
upon, stating, showing, considering, establishing, supporting, bolstering, explaining,
contradicting,refuting, diminishing, constituting, describing, recording, noting,
embodying, memorializing, containing, mentioning, reviewing, studying, analyzing,
evaluating, reporting, commenting, discussing, specifying, identifying, impinging upon or
impacting in any other way bearing on the matter addressed in the topics for examination,
in whole or in part, either directly or indirectly.
17. “Security” or “Securities” shall mean any common stock, preferred stock,
debenture, option, or other debt or equity interest, and any direct or indirect, legal, or
beneficial interest.
18. “Transaction(s)” shall mean any purchases, acquisitions, sales, dispositions,
tenders, donations, receipt, gifts, transfers, puts, call, short sales, execution of any option
contracts, or any other means by which You acquired or disposed of any interest in
Securities, whether for Your own account or benefit or for the account or benefit of any
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 55 of 64

- 20 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
other Person.
19. “You,” and “Your” shall mean and refer to Mr. Kavyan Larizadeh.
20. The use of the singular form of any word shall include the plural form of the same
word and vice versa.
defined terms shall retain their meaning even if not capitalized in these topics for
examination.
I. TOPICS FOR EXAMINATION
1. Your knowledge of the basis for Pelham’s Transactions in Carvana Securities, from
and including May 6, 2020 through October 7, 2022, including any returns or losses on
such investments.1
2. Your understanding of the basis for Pelham’s decision to participate in the April 22,
2022 Offering of Carvana Securities, including any research, diligence, or analysis Pelham
relied upon or considered to inform that decision from May 6, 2020 through April 26, 2022,
the date of the closing of the Offering.
3. Your understanding, as pertinent to Pelham’s Transactions in Carvana Securities
from and including May 6, 2020 through October 7, 2022, of Pelham’s research,
knowledge and understanding of:
a. Carvana’s business model;
b. The industry in which Carvana operates as a used car dealer and e-
commerce retailer;
c. Carvana’s expansion and growth strategies, including the alleged
Expansion and Growth Strategies, and the impact of those strategies on
inventory, costs, revenues and profitability;
d. Carvana’s U.S. Securities and Exchange Commission filings and public
statements, including statements related specifically to (i) Carvana’s
compliance with state and local title and registration laws; (ii) Carvana’s
retail unit sales, including drivers of its sales growth; and (iii) Carvana’s
1 Plaintiffs have sought class certification for investors who purchased or acquired
Carvana common stock from May 6, 2020 through October 7, 2022.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 56 of 64

- 21 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
expansion and growth strategies, including alleged Expansion and
Growth Strategies;
e. The regulatory regime governing Carvana’s car sales, including state and
local title and registration laws; and
f. The material risks and benefits related to investments in Carvana
Securities, to the extent that these relate to the matters alleged in the
Amended Complaint.
4. Your understanding, as pertinent to Pelham’s Transactions in Carvana Securities
from and including May 6, 2020 through October 7, 2022, of Pelham’s research, knowledge
and analysis of publicly available information or news, regarding Carvana’s compliance
with state and local title and registration laws, including:
a. News coverage on or around August 9-11, 2021, regarding North
Carolina’s suspension of the dealer license at Carvana’s Wake Country
location;
b. The October 22, 2021 Wall Street Journal article, entitled “Carvana Faces
Government Scrutiny and Fines Following Consumer Complaints”;
c. The June 24, 2022 Barron’s article, entitled “Carvana Sought to Disrupt
Auto Sales. It Delivered Undriveable Cars.”;
d. The October 7, 2022 Michigan Department of State press release, entitled
“Department of State suspends Novi dealership”; and
e. Any other new reports criticizing Carvana’s compliance with state and
local title and registration laws.
5. Your knowledge, monitoring, analysis, reporting, Transactions, or other actions
taken as a result of or related to any gains or losses on investments in Carvana Securities
made by Pelham, from and including May 6, 2020 through October 7, 2022.
6. Pelham’s record-keeping, file maintenance, Document management, Document
preservation or Document retention policies and practices with respect to Electronically
Stored Information related to Carvana.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 57 of 64

- 22 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
SCHEDULE B: DOCUMENT REQUESTS
I. DEFINITIONS
1. “Action” shall mean the legal action In re Carvana Co. Securities Litigation, No.
2:22-cv-02126-PHX-MTL, United States District Court, District of Arizona, filed on
August 3, 2022.
2. “Amended Complaint” shall refer to the operative Amended Consolidated
Complaint filed in this Action on March 29, 2024, Dkt. No. 71.
3. “All,” “any,” and “each” shall mean and each be construed as encompassing any
and all.
4. “And” and “or” shall mean and be construed either disjunctively or conjunctively,
as necessary by the context, to bring within the scope of the topic for examination all
responses that might otherwise be construed to be outside of its scope by any other
construction.
5. “Carvana” shall refer to Defendant Carvana Co.
6. “Communication(s)” shall mean and refers to all evidence of the transmission of
information (in the form of facts, ideas, inquiries, or otherwise), record in Pelham’s
possession, custody, or control, transmitted between any Person or Persons and any other
Person or Persons, by or through any mode or medium, including but not limited to the
spoken word, written or electronic correspondence, electronic mail (e-mail), instant
messaging, telephone, facsimile, face-to-face meetings, through third Persons, and/or via
electronic recordings.
7. Concern,” “concerning,” “reflect,” “reflecting,” “related,” “relating,” “relate(s),”
“refer,” or “referring,” and other variations thereof, as used herein shall be construed in
their broadest possible sense, and shall mean without limitation and whether in whole or in
part: referring to, constituting, bearing upon, commenting upon, reflecting, evidencing,
pertaining to, describing, depicting, consisting of, containing, comprising, embodying,
identifying, stating, discussing, analyzing, studying, summarizing, dealing with, relating
to, or having any logical or factual connection whatsoever with the subject addressed,
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 58 of 64

- 23 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
regardless of whether the factual connection is favorable to or adverse to You.
8. “Document(s)” shall have the full meaning ascribed in Federal Rule of Civil
Procedure 34 and shall include every writing or record in Pelham’s possession, custody, or
control (including Electronically Stored Information) of every type and description such as
communications, correspondence, speech, writings, memoranda, stenographic or
handwritten notes, language (machine, foreign, or otherwise), studies, publications, books,
pamphlets, reports, financial statements, calculations, analyses, films, video tape,
photographs, graphs, symbols, signs, voice recordings, sound, radio and/or video signal,
telephone, teletype, telecommunication, photographic film of any type, e-mail, computer
electronics of any kind, computer files or all other data, compilations from which
information can be obtained, including electromagnetically sensitive stored media such as
hard discs, magnetic disks, and magnetic tapes, any preliminary versions, drafts or
revisions of any of the foregoing, and all copies of every such writing or record (or a draft
thereof) whenever a copy of a Document is not an identical copy of the original or where
such copy contains any commentary, notes or markings whatsoever that do not appear on
the original. The term Document(s) specifically includes Electronically Stored
Information.
9. “DriveTime” shall mean DriveTime Automotive Group Inc. and all of its
predecessors, affiliates, parents, and subsidiaries, including but not limited to DriveTime
Automotive Group Inc., as well as all agents, attorneys, consultants, directors, employees,
investors, members, managers, officers, principals, representatives, trustees, and all other
persons acting or purporting to act on behalf or under the control of the foregoing.
10. “Electronically Stored Information” or “ESI” shall mean and refers to information
that is stored electronically, regardless of the media or whether it is in the original format
in which it was created, as opposed to stored in hard copy (i.e., on paper). ESI carries the
broadest possible meaning consistent with Fed. R. Civ. P. 34(a) and Fed. R. Evid. 1001.
For the avoidance of doubt, any electronic Documents or data shall include their associated
metadata.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 59 of 64

- 24 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
11. “Expansions and Growth Strategies” shall refer to business strategies employed by
Carvana, such as: (1) prioritization of growth over profitability; (2) expansion nationwide,
including into new markets; (3) selling cars awaiting title and/or registration; (4) increases
in inventory, including by purchasing or permitting trade-ins of lower quality cars; and (5)
pass-through sales agreements with DriveTime.
12. “Including” shall mean “including, but not limited to” and shall not limit the scope
of any topic for examination.
13. “Individual Defendants” “Individual Defendants” shall refer to the following
individual defendants in the legal action In re Carvana Co. Securities Litigation, No. 2:22-
cv-02126-PHX-MTL, United States District Court, District of Arizona, filed on August 3,
2022: Ernest Garcia III, Mark Jenkins, Stephen Palmer, Michael Maroone, Neha Parikh,
Ira Platt, and Greg Sullivan.
14. “Pelham” shall mean Pelham Capital Ltd. and all of its predecessors, affiliates,
parents, and subsidiaries, including but not limited to well as all agents, attorneys,
consultants, directors, employees, investors, members, managers, officers, principals,
representatives, trustees, and all other persons acting or purporting to act on behalf or under
the control of the foregoing.
15. “Offering” shall refer to Carvana’s April 22, 2022 secondary offering of Class A
common stock.
16. “Purchase” or “Sell” or “Sale” shall mean purchase, sell, trade, convert, otherwise
acquire or otherwise dispose of, particularly with respect to Securities, whether for Your
own account or benefit, or for the account or benefit of any other Person.
17. “Refer(s)” or “Relate(s)” shall mean and refers to comprise, concern, describe,
evidence, constitute, reflect, record, identify, memorialize, diminish, refute, discuss,
explain, specify, consider, embody, evaluate, analyze, review, respect, state, establish,
bolster, show, support, contradict, note, contain, mention, study, pertain to, report on,
comment on, impinge upon or impact the subject matter of the topic for examination, in
whole or in part, either directly or indirectly.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 60 of 64

- 25 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
18. “Relating to” shall mean and refers to relating to, pertaining to, referring to,
evidencing, in connection with, reflecting, respecting, concerning, compromising, based
upon, stating, showing, considering, establishing, supporting, bolstering, explaining,
contradicting,refuting, diminishing, constituting, describing, recording, noting,
embodying, memorializing, containing, mentioning, reviewing, studying, analyzing,
evaluating, reporting, commenting, discussing, specifying, identifying, impinging upon or
impacting in any other way bearing on the matter addressed in the topics for examination,
in whole or in part, either directly or indirectly.
19. “Security” or “Securities” shall mean any common stock, preferred stock,
debenture, option, or other debt or equity interest, and any direct or indirect, legal, or
beneficial interest.
20. “Transaction(s)” shall mean any purchases, acquisitions, sales, dispositions,
tenders, donations, receipt, gifts, transfers, puts, call, short sales, execution of any option
contracts, or any other means by which You acquired or disposed of any interest in
Securities, whether for Your own account or benefit or for the account or benefit of any
other Person.
21. “You,” and “Your” shall mean and refer to Pelham, as defined herein.
22. The use of the singular form of any word shall include the plural form of the same
word and vice versa.
All defined terms shall retain their meaning even if not capitalized in these topics
for examination.
II. INSTRUCTIONS
The following instructions apply to each document request set forth below.
1. All Requests shall be construed pursuant to the applicable Federal Rules of Civil
Procedure, except to the extent incompatible with English law.
2. In responding to these Requests, You are required to furnish Documents that are in
Your possession, custody, or control, including Documents in the possession of Your
present and former attorneys, accountants, advisors, representatives, agents, or employees
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 61 of 64

- 26 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
(to the extent these are in Your control). All Documents that respond, in whole or in part,
to any portion of the Requests below shall be produced in their entirety, including all
attachments and enclosures.
3 If there are no Documents or things responsive to a particular Request, You should
so state in writing.
4. Each and every copy of a Document, that is different from the original because of
stamps, indications of the recipient(s), handwritten notes, marks, attachments, or any other
reason, is a separate Document that must be produced.
5. If You produce any tape, disk, card, wire, or other electronic or mechanical
recording or transcript, or any computer program in response to any Request, You shall
also produce such documents, software, and instructions as are necessary for the decoding,
playing back, printing, and/or interpretation thereof, and any other documents that are
necessary to convert said information into a useable format.
6. If any information requested is claimed to be privileged or otherwise immune from
discovery, please provide all information falling within the scope of the Request which is
not privileged, and for each item of information contained in a Document or
Communication to which a claim of privilege is made, identify such Document or
Communication with sufficient particularity for purposes of a motion to compel, such
identification to include at least the basis on which the privilege is claimed.
III. REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST FOR PRODUCTION NO. 1:
All Documents and Communications in Pelham’s possession, custody, or control
Concerning Your knowledge and research Relating to Carvana Securities from May 6,
2020 through October 7, 2022, including analyst reports, articles, recommendations, notes,
memoranda, opinions, ratings, valuations, and investor materials (such as road show decks,
shareholder letters).
REQUEST FOR PRODUCTION NO. 2:
All Documents and Communications in Pelham’s possession, custody, or control
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 62 of 64

- 27 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Concerning Your knowledge, analysis, and research of Carvana’s compliance with state
and local title and registration laws, including any lawsuits or regulatory actions related
thereto, from May 6, 2020 through October 7, 2022.
REQUEST FOR PRODUCTION NO. 3:
All Documents and Communications in LGIM’s possession, custody, or control
Concerning Your knowledge, analysis, and research of Carvana’s retail unit sales,
including drivers of its sales growth from May 6, 2020 through October 7, 2022.
REQUEST FOR PRODUCTION NO. 4:
All Documents in Pelham’s possession, custody, or control sufficient to reflect Your
Transactions in Carvana Securities and any accompanying gains or losses from May 6,
2020 through October 7, 2022, such as, for example, a trading list.
REQUEST FOR PRODUCTION NO. 5:
All Documents and Communications in Pelham’s possession, custody, or control
from May 6, 2020 through April 26, 2022, Concerning the basis for Your decision to
participate in the Offering, including any Documents You relied upon, consulted, or
considered.
REQUEST FOR PRODUCTION NO. 6:
All Documents and Communications in Pelham’s possession, custody, or control
Concerning any gains or losses from May 6, 2020 through October 7, 2022 on Your
investments in Carvana Securities purchased in the Offering.
REQUEST FOR PRODUCTION NO. 7:
All Documents and Communications in Pelham’s possession, custody or control
Concerning public disclosures from May 6, 2020 through October 7, 2022 made by, or on
behalf of Carvana, or other publicly available news articles, reports, or other information,
regarding:
(i) Carvana’s compliance with state and local title and registration laws, including
any lawsuits or regulatory actions related thereto;
(ii) Carvana’s retail unit sales, including drivers of its sales growth; and
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 63 of 64

- 28 -
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
(iii) Carvana’s Expansion and Growth Strategies.
Case 2:22-cv-02126-MTL Document 633 Filed 08/13/26 Page 64 of 64