Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 1 of 24

IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

FIRST JUDICIAL DISTRICT

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES PLAINTIFF

v. CAUSE No. 22-cv-00286-EFP

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC., ET AL. DEFENDANTS

and

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC. COUNTER-PLAINTIFF

v.

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES COUNTER-DEFENDANT

SUBPOENA DUCES TECUM

STATE OF MISSISSIPPI
COUNTY OF HINDS

TO: Dewey Phillip Bryant

7009 Highway 28
Hazlehurst, MS 39083

YOU ARE HEREBY SUMMONED to produce, ON OR BEFORE 10 DAYS FROM THE

DATE OF RECEIPT OF THIS SUBPOENA, a true and correct copy ofthe documents designated

below, and to mail or otherwise transmit exact copies of said documents to counsel for Mississippi

Community Education Center at Carroll Bufkin, PLLC, 1076 Highland Colony Parkway, 600

Concourse, Suite 125, Ridgeland, Mississippi 39157. The documents to be produced are:

ALL DOCUMENTS DESCRIBED IN EXHIBIT "A"

Your personal appearance is not required. The requested Documents may be delivered

personally to counsel or by U.S. Mail or other carrier to arrive at the aforesaid location within ten

(10) days from the date this Subpoena was served.

Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 2 of 24

Please complete and return a notarized original of the attached "Certificate of Authenticity"

with your production of Documents.

HEREIN YOU SHALL NOT FAIL UNDER PENALTY IN SUCH CASE PROVIDED,

and have then and there this writ.

GIVEN UNDER MY HAND AND SEAL AND ISSUED BY THIS OFFICE, this the

)£____day <if~~&r~+-----2022.
HINDS COUNTY CIRCUIT COURT

By:~ /

Deputy Clerk

Thomas G. Bufkin
Luke E. Whitaker
CARROLL BUFKIN, PLLC
1076 Highland Colony Parkway
600 Concourse, Suite 125
Ridgeland, MS 39157
T: (601) 982-5011
F: (601) 853-9540
[email protected]
[email protected]

2
..Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 3 of 24

CERTIFICATE OF AUTHENTICITY

I HEREBY CERTIFY that the reproduction of records attached to this certificate are, to

the best of my knowledge, true and accurate copies of the records requested in this Subpoena

Duces Tecum. The originals of said documents are on file with me personally and said records

were made and kept in the regular course of business.

I FURTHER CERTIFY that I am the person responsible for maintaining and controlling

these records, and/or the appointed designee responsible for the release of these records.

Dated this the _ _ day of _ _ _ _ _ _ 2022.

RECORDS CUSTODIAN

STATE OF MISSISSIPPI

COUNTY O F - - - - - - -

SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ _ __

2022.

NOTARY PUBLIC

My Commission Expires:

3
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 4 of 24

RETURN OF SERVICE

I , - - - - - - - - - - - - - - ' process server, do hereby certify that I am not

a party to the above-captioned civil action, am not less than 18 years of age, and have delivered

the above-and-foregoing SUBPOENA DUCES TECUM by serving a true and correct copy of

same upon_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

Thisthe __ dayof _ _ _ _ _ _ _ _ 2022.

Process Server

STATE OF MISSISSIPPI
COUNTY OF _ _ _ __

SWORN AND SUBSCRIBE before me this the __ day of _ _ _ _ _ _ _ 2022.

NOTARY PUBLIC

My Commission Expires:

4
...Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 5 of 24

EXHIBIT "A" TO SUBPOENA

Definitions

A "Document" is any written, recorded, or graphic material of any kind, whether prepared
by you or by any other person, that is in your possession, custody, or control. You are deemed to
have "control" if you have the right to secure the Document or a copy thereof from another person
or entity. The definition of "Document" includes, without limitation, electronic mail ("email");
text messages; instant messages; direct messages; correspondence; letters; telegrams; agreements;
contracts; inter-office communications; memoranda; reports; summaries; notes; notebooks;
scrapbooks; diaries; calendars; plans; drawings; sketches; blueprints; diagrams; photographs;
photocopies; charts; graphs; descriptions; minutes of meetings, conferences, conversations or
communications; invoices; purchase orders; bills of lading; recordings; published or unpublished
speeches or articles; publications; transcripts; phone voice mail; ledgers; financial statements;
accounting records; general ledgers; microfilm; microfiche; tape or disc recordings; and computer
print outs. It also includes all drafts of a Document and all copies that differ in any respect from
the original or other versions including any notation, underlining, marking, marginalia, or
information of any kind not in any original or other versions. A "Document" further includes all
electronically stored data from which any information can be obtained, either directly or indirectly,
or by translation through detection devices or readers, and includes information stored in, or
accessible through, computer or other information retrieval systems (including any computer
archives or back-up systems).

The "USM Volleyball Center" refers to the facilities located on the University of Southern
Mississippi campus at or around 101 M.K. Turk Circle, Hattiesburg, Mississippi 39406, which
have been or are being used, in whole or in part, to serve women's volleyball and/or women's
beach volleyball.

5
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 6 of 24

Exhibit "A"

DOCUMENTS TO BE PRODUCED WITHIN TEN (10) DAYS

1. All Documents including, without limitation, Documents reflecting communications

between you and any person or entity concerning the USM Volleyball Center.

2. All Documents including, without limitation, Documents reflecting communications

between you and any person or entity concerning funding for the USM Volleyball Center.

3. All Documents, including, without limitation, Documents reflecting communications

between you and any person intended to further efforts to secure funding from MDHS for
the USM Volleyball Center.

6
 Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 7 of 24

IN THE CIRCUIT COURT OF fiNDS COUNTY, MISSISSIPPI

FIRST JUDICIAL DISTRICT

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES PLAINTIFF

v. CAUSE No. 22-cv-00286-EFP

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC., ET AL. DEFENDANTS

and

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC. COUNTER-PLAINTIFF

v.

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES COUNTER-DEFENDANT

SUBPOENA DUCES TECUM

STATE OF MISSISSIPPI
COUNTY OF HINDS

TO: Office of Attorney General for Mississippi

550 High Street
Jackson, Mississippi 39201

YOU ARE HEREBY SUMMONED to produce, ON OR BEFORE 10 DAYS FROM THE

DATE OF RECEIPT OF THIS SUBPOENA, a true and correct copy ofthe documents designated

below, and to mail or otherwise transmit exact copies of said documents to counsel for Mississippi

Community Education Center at Carroll Bufkin, PLLC, 1076 Highland Colony Parkway, 600

Concourse, Suite 125, Ridgeland, Mississippi 39157. The documents to be produced are:

ALL DOCUMENTS DESCRIBED IN EXHIBIT "A"

Your personal appearance is not required. The requested Documents may be delivered

personally to counsel or by U.S. Mail or other carrier to arrive at the aforesaid location within ten

(10) days from the date this Subpoena was served.

Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 8 of 24

Please complete and return a notarized original of the attached "Certificate of Authenticity"

with your production of Documents.

HEREIN YOU SHALL NOT FAIL UNDER PENALTY IN SUCH CASE PROVIDED,

and have then and there this writ.

GIVEN UNDER MY HAND AND SEAL AND ISSUED BY THIS OFFICE, this the

~day~ 2022.

HINDS COUNTY CIRCUIT COURT

By~ /

Deputy Clerk

Thomas G. Bufkin
Luke E. Whitaker
CARROLL BUFKIN, PLLC
1076 Highland Colony Parkway
600 Concourse, Suite 125
Ridgeland, MS 39157
T: (601) 982-5011
F: (601) 853-9540
[email protected]
[email protected]

2
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 9 of 24

CERTIFICATE OF AUTHENTICITY

I HEREBY CERTIFY that the reproduction of records attached to this certificate are, to

the best of my knowledge, true and accurate copies of the records requested in this Subpoena

Duces Tecum. The originals of said documents are on file at the OFFICE OF THE ATTORNEY

GENERAL FOR MISSISSIPPI and said records are made and kept in the regular course of

business.

I FURTHER CERTIFY that I am the person responsible for maintaining and controlling

these records, and/or the appointed designee responsible for the release of these records.

Dated this the _ _ day of _ __ _ _ _ 2022.

RECORDS CUSTODIAN

STATE OF MISSISSIPPI

COUNTY OF _ _ _ _ _ __

SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ __

2022.

NOTARY PUBLIC

My Commission Expires:

3
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 10 of 24

RETURN OF SERVICE

I, _ _ _ _ _ _ _ _ _ _ _ _ _ _, process server, do hereby certify that I am not

a party to the above-captioned civil action, am not less than 18 years of age, and have delivered

the above-and-foregoing SUBPOENA DUCES TECUM by serving a true and correct copy of

same upon_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

This the __ day of _ _ _ _ _ _ _ _ 2022.

Process Server

STATE OF MISSISSIPPI
COUNTY OF _ _ _ __

SWORN AND SUBSCRIBE before me this the __ day of _ _ _ _ _ _ _ 2022.

NOTARY PUBLIC

My Commission Expires:

4
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 11 of 24

EXHIBIT "A" TO SUBPOENA

Definitions

A "Document" is any written, recorded, or graphic n::taterial of any kind, whether prepared
by you or by any other person, that is in your possession, custody, or control. You are deemed to
have "control" if you have the right to secure the Document or a copy thereof from another person
or entity. The definition of "Document" includes, without limitation, electronic mail ("email");
text messages; instant messages; direct messages; correspondence; letters; telegrams; agreements;
contracts; inter-office communications; memoranda; reports; summaries; notes; notebooks;
scrapbooks; diaries; calendars; plans; drawings; sketches; blueprints; diagrams; photographs;
photocopies; charts; graphs; descriptions; minutes of meetings, conferences, conversations or
communications; invoices; purchase orders; bills of lading; recordings; published or unpublished
speeches or articles; publications; transcripts; phone voice mail; ledgers; financial statements;
accounting records; general ledgers; microfilm; microfiche; tape or disc recordings; and computer
print outs. It also includes all drafts of a Document and all copies that differ in any respect from
the original or other versions including any notation, underlining, marking, marginalia, or
information of any kind not in any original or other versions. A "Document" further includes all
electronically stored data from which any information can be obtained, either directly or indirectly,
or by translation through detection devices or readers, and includes information stored in, or
accessible through, computer or other information retrieval systems (including any computer
archives or back-up systems).

The "USM Volleyball Center" refers to the facilities located on the University of Southern
Mississippi campus at or around 101 M.K. Turk Circle, Hattiesburg, Mississippi 39406, which
have been or are being used, in whole or in part, to serve women's volleyball and/or women's
beach volleyball.

The "USM Volleyball Center Leases" include all Documents related in any way to:

(a) "Amended and Restated Lease between the University of Southern Mississippi and the
University of Southern Mississippi Athletic Foundation, Inc." and/or

(b) "Sublease between The University of Southern Mississippi Athletic Foundation, Inc.
and Mississippi Community Education Center."

"TANF" is the Temporary Assistance for Needy Families program operated by the State
ofMississippi pursuant to Miss. Code Ann. 43-17-1 and 42 U.S.C. §601, as well as other provision
of State and federal law.

5
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 12 of 24

EXHIBIT "A"

DOCUMENTS TO BE PRODUCED WITIDN TEN (10) DAYS

1. All Documents relating in any way to the USM Volleyball Center.

2. All Documents relating in any way to the USM Volleyball Center Leases.

3. All Documents reflecting or relating in any way to approval, in whole or in part, by the
Office of the Attorney General for Mississippi of any aspect of the USM Volleyball Center
and/or the USM Volleyball Center Leases.

4. All Documents reflecting or relating in any way to conclusions reached by the Office of
the Attorney General for Mississippi, prior to the date of execution of the USM Volleyball
Center Leases, that construction of the USM Volleyball Center was a permissible TANF
expenditure and served a TANF purpose.

6
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 13 of 24

IN THE CIRCillT COURT OF IDNDS COUNTY, MISSISSIPPI

FIRST JUDICIAL DISTRICT

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES PLAINTIFF

v. CAUSE No. 22-cv-00286-EFP

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC., ET AL. DEFENDANTS

and

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC. COUNTER-PLAINTIFF

v.

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES COUNTER-DEFENDANT

SUBPOENA DUCES TECUM

STATE OF MISSISSIPPI
COUNTY OF HINDS

TO: Institutions of Higher Learning

State of Mississippi
3825 Ridgewood Rd.
Jackson, Mississippi 39211

YOU ARE HEREBY SUMMONED to produce, ON OR BEFORE 10 DAYS FROM THE

DATE OF RECEIPT OF THIS SUBPOENA, a true and correct copy ofthe documents designated

below, and to mail or otherwise transmit exact copies of said documents to counsel for Mississippi

Community Education Center at Carroll Bufkin, PLLC, 1076 Highland Colony Parkway, 600

Concourse, Suite 125, Ridgeland, Mississippi 39157. The documents to be produced are:

ALL DOCUMENTS DESCRIBED IN EXHIBIT "A"

Your personal appearance is not required. The requested Documents may be delivered

personally to counsel or by U.S. Mail or other carrier to arrive at the aforesaid location within ten

(1 0) days from the date this Subpoena was served.

.Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 14 of 24

Please complete and return a notarized original of the attached "Certificate of Authenticity"

with your production of Documents.

HEREIN YOU SHALL NOT FAIL UNDER PENALTY IN SUCH CASE PROVIDED,

and have then and there this writ.

GIVEN UNDER MY HAND AND SEAL AND ISSUED BY THIS OFFICE, this the

~ day of 2022.

HINDS COUNTY CIRCUIT COURT

Deputy Clerk

ISSUED AT THE REQUEST OF:

Thomas G. Bufkin
Luke E. Whitaker
CARROLL BUFKIN, PLLC
107 6 Highland Colony Parkway
600 Concourse, Suite 125
Ridgeland, MS 39157
T: (601) 982-5011
F: (601) 853-9540
[email protected]
[email protected]

2
.Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 15 of 24

CERTIFICATE OF AUTHENTICITY

I HEREBY CERTIFY that the reproduction of records attached to this certificate are, to

the best of my knowledge, true and accurate copies of the records requested in this Subpoena

Duces Tecum. The originals of said documents are on file at the INSTITUTIONS OF IDGHER

LEARNING OF THE STATE OF MISSISSIPPI and said records are made and kept in the

regular course of business.

I FURTHER CERTIFY that I am the person responsible for maintaining and controlling

these records, and/or the appointed designee responsible for the release of these records.

Dated this thL - day of 2022.

RECORDS CUSTODIAN

STATE OF MISSISSIPPI

COUNTY OF ____________

SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ ___

2022.

NOTARY PUBLIC

My Commission Expires:

3
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 16 of 24

RETURN OF SERVICE

I, _ _ _ _ _ _ _ _ _ _ _ _ _ _, process server, do hereby certify that I am not

a party to the above-captioned civil action, am not less than 18 years of age, and have delivered

the above-and-foregoing SUBPOENA DUCES TECUM by serving a true and correct copy of

same upon_ _ _ _ _ __ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___

This the __ day of _ _ _ _ _ _ _ _ 2022.

Process Server

STATE OF MISSISSIPPI
COUNTY OF _ _ _ __

SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ __ _ _ 2022.

NOTARY PUBLIC

My Commission Expires:

4
..Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 17 of 24

EXHffiiT "A" TO SUBPOENA

Definitions

A "Document" is any written, recorded, or graphic material of any kind, whether prepared
by you or by any other person, that is in your possession, custody, or control. You are deemed to
have "control" if you have the right to secure the Document or a copy thereof from another person
or entity. The definition of "Document" includes, without limitation, electronic mail ("email");
text messages; instant messages; direct messages; correspondence; letters; telegrams; agreements;
contracts; inter-office communications; memoranda; reports; summaries; notes; notebooks;
scrapbooks; diaries; calendars; plans; drawings; sketches; blueprints; diagrams; photographs;
photocopies; charts; graphs; descriptions; minutes of meetings, conferences, conversations or
communications; invoices; purchase orders; bills of lading; recordings; published or unpublished
speeches or articles; publications; transcripts; phone voice mail; ledgers; financial statements;
accounting records; general ledgers; microfilm; microfiche; tape or disc recordings; and computer
print outs. It also includes all drafts of a Document and all copies that differ in any respect from
the original or other versions including any notation, underlining, marking, marginalia, or
information of any kind not in any original or other versions. A "Document" further includes all
electronically stored data from which any information can be obtained, either directly or indirectly,
or by translation through detection devices or readers, and includes information stored in, or
accessible through, computer or other information retrieval systems (including any computer
archives or back-up systems).

The "USM Volleyball Center" refers to the facilities located on the University of Southern
Mississippi campus at or around 101 M.K. Turk Circle, Hattiesburg, Mississippi 39406, which
have been or are being used, in whole or in part, to serve women's volleyball and/or women's
beach volleyball.

The "USM Volleyball Center Leases" include all Documents related in any way to:

(a) "Amended and Restated Lease between the University of Southern Mississippi and the
University of Southern Mississippi Athletic Foundation, Inc." and/or

(b) "Sublease between The University of Southern Mississippi Athletic Foundation, Inc.
and Mississippi Community Education Center." .

5
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 18 of 24

EXHIBIT "A"

DOCUMENTS TO BE PRODUCED WITIDN TEN (10) DAYS

1. All Documents relating in any way to the USM Volleyball Center.

2. All Documents relating in any way to the USM Volleyball Center Leases.

3. All Documents reflecting, or relating in any way to, approval, in whole or in part, by the
Office of the Attorney General for Mississippi of any aspect of the USM Volleyball Center
and/or either of the USM Volleyball Center Leases.

6
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 19 of 24

IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

FIRST JUDICIAL DISTRICT

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES PLAINTIFF

v. CAUSE No. 22-cv-00286-EFP

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC., ET AL. DEFENDANTS

and

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC. COUNTER-PLAINTIFF

v.

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES COUNTER-DEFENDANT

SUBPOENA DUCES TECUM

STATE OF MISSISSIPPI
COUNTY OF HINDS

TO: The University of Southern Mississippi Athletic Foundation, Inc.

Registered Agent: Richard C. Giannini
Pat Ferlise Center- 3001 West 4th Street
Hattiesburg, MS 39402

YOU ARE HEREBY SUMMONED to produce, ON OR BEFORE 10 DAYS FROM THE

DATE OF RECEIPT OF THIS SUBPOENA, a true and correct copy of the documents designated

below, and to mail or otherwise transmit exact copies of said documents to counsel for Mississippi

Community Education Center at Carroll Bufkin, PLLC, 1076 Highland Colony Parkway, 600

Concourse, Suite 125, Ridgeland, Mississippi 39157. The documents to be produced are:

ALL DOCUMENTS DESCRIBED IN EXHIBIT "A"

Your personal appearance is not required. The requested Documents may be delivered

personally to counsel or by U.S. Mail or other carrier to arrive at the aforesaid location within ten

(10) days from the date this Subpoena was served.

Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 20 of 24

Please complete and return a notarized original of the attached "Certificate of Authenticity"

with your production of Documents.

HEREIN YOU SHALL NOT FAIL UNDER PENALTY IN SUCH CASE PROVIDED,

and have then and there this writ.

GIVEN UNDER MY HAND AND SEAL AND ISSUED BY THIS OFFICE, this the

::AS day of~"""7

~:. . _ _ _=.,,___ _ 2022.

HINDS COUNTY CIRCUIT COURT

Deputy Clerk

ISSUED AT THE REQUEST OF:

Thomas G. Bufkin
Luke E. Whitaker
CARROLL BUFKIN, PLLC
1076 Highland Colony Parkway
600 Concourse, Suite 125
Ridgeland, MS 39157
T: (601) 982-5011
F: (601) 853-9540
[email protected]
[email protected]

2
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 21 of 24

CERTIFICATE OF AUTHENTICITY

I HEREBY CERTIFY that the reproduction of records attached to this certificate are, to

the best of my knowledge, true and accurate copies of the records requested in this Subpoena

Duces Tecum. The originals of said documents are on file at THE UNIVERSITY OF

SOUTHERN MISSISSIPPI ATHLETIC FOUNDATION, INC. and said records are made and

kept in the regular course of business.

I FURTHER CERTIFY that I am the person responsible for maintaining and controlling

these records, and/or the appointed designee responsible for the release of these records.

Dated this the _ _ day of _ _ _ _ _ _ 2022.

RECORDS CUSTODIAN

STATE OF MISSISSIPPI

COUNTY OF _ _ _ _ _ __

SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ __ __

2022.

NOTARY PUBLIC

My Commission Expires:

3
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 22 of 24 I
I
RETURN OF SERVICE

I, _ _ _ _ _ _ _ _ _ _ _ _ _ _, process server, do hereby certify that I am not

a party to the above-captioned civil action, am not less than 18 years of age, and have delivered

the above-and-foregoing SUBPOENA DUCES TECUM by serving a true and correct copy of

same upon._ __ _ _ _ __ _ _ _ _ _ _ __ _ _ _ __ _ _ _ __

This the _ _ day of _ _ _ _ _ _ _ _ 2022.

Process Server

STATE OF MISSISSIPPI
COUNTY OF _ _ _ __

SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ _ _ 2022.

NOTARY PUBLIC

My Commission Expires:

4
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 23 of 24

EXHIBIT "A" TO SUBPOENA

Definitions

A "Document" is any written, recorded, or graphic material of any kind, whether prepared
by you or by any other person, that is in your possession, custody, or control. You are deemed to
have "control" if you have the right to secure the Document or a copy thereof from another person
or entity. The definition of "Document" includes, without limitation, electronic mail ("email");
text messages; instant messages; direct messages; correspondence; letters; telegrams; agreements;
contracts; inter-office communications; memoranda; reports; summaries; notes; notebooks;
scrapbooks; diaries; calendars; plans; drawings; sketches; blueprints; diagrams; photographs;
photocopies; charts; graphs; descriptions; minutes of meetings, conferences, conversations or
communications; invoices; purchase orders; bills of lading; recordings; published or unpublished
speeches or articles; publications; transcripts; phone voice mail; ledgers; financial statements;
accounting records; general ledgers; microfilm; microfiche; tape or disc recordings; and computer
print outs. It also includes all drafts of a Document and all copies that differ in any respect from
the original or other versions including any notation, underlining, marking, marginalia, or
information of any kind not in any original or other versions. A "Document" further includes all
electronically stored data from which any information can be obtained, either directly or indirectly,
or by translation through detection devices or readers, and includes information stored in, or
accessible through, computer or other information retrieval systems (including any computer
archives or back-up systems).

"You" and "Your" refer to the University of Southern Mississippi Athletic Foundation,
Inc. ("USMAF") and its board members, officers, employees, agents, and any other person acting
on its behalf.

The "USM Volleyball Center" refers to the facilities located on the University of Southern
Mississippi campus at or around 101 M.K. Turk Circle, Hattiesburg, Mississippi 39406, which
have been or are being used, in whole or in part, to serve women' s volleyball and/or women's
beach volleyball.

The "USM Volleyball Center Leases" include all Documents related in any way to:

(a) "Amended and Restated Lease between the University of Southern Mississippi and the
University of Southern Mississippi Athletic Foundation, Inc." and/or

(b) "Sublease between The University of Southern Mississippi Athletic Foundation, Inc.
and Mississippi Community Education Center."

"TANF" is the Temporary Assistance for Needy Families program operated by the State
of Mississippi in conjunction with the federal government pursuant to 42 U.S.C. §601 and Miss.
Code Ann. 43-17-1 , as well as other applicable provisions of federal and State law.

5
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 24 of 24

DOCUMENTS TO BE PRODUCED WITHIN TEN (10) DAYS

1. All Documents including, without limitation, Documents reflecting communications

between You and any person or entity relating in any way to the USM Volleyball Center
and/or the USM Volleyball Center Leases.

2. All Documents including, without limitation, Documents reflecting communications

between You and any person or entity relating in any way to funding, in whole or in part,
for the USM Volleyball Center.

3. All Documents including, without limitation, Documents reflecting communications

between You and any person or entity relating in any way to pledges or promises for
funding, in whole or in part, for the USM Volleyball Center.

4. All Documents relating in any way to Your conclusion prior to the date of execution of the
USM Volleyball Center Leases that the USM Volleyball Center and/or the USM Volleyball
Center Leases were permissible TANF expenditures and the USM Volleyball Center
served a T ANF purpose.

5. All Documents including, without limitation, Documents reflecting communications

between You and anyone with the Attorney General ' s Office for Mississippi in relation to
the USM Volleyball Center and/or the USM Volleyball Center Leases.

6. All Documents, including, without limitation, bank statements and other financial records
identifying transactions wherein funds were received by You from any entity or person, or
paid by You to any person or entity, in relation to the USM Volleyball Center and/or the
USM Volleyball Center Leases.