DOCUMENT 48

ELECTRONICALLY FILED
4/2/2016 10:01 AM
38-CV-2015-900358.00
CIRCUIT COURT OF
HOUSTON COUNTY, ALABAMA
CARLA H. WOODALL, CLERK

IN THE CIRCUIT COURT OF HOUSTON COUNTY, ALABAMA

STATE OF ALABAMA
DOUGLAS ALBERT VALESKA,
DISTRICT ATTORNEY OF THE 20TH
JUDICIAL CIRCUIT OF ALABAMA,
COMPLAINANT.
v.
JAMES TIMOTHY VIBBERT,
CONSOLIDATED SOLUTIONS, INC., AND
TWENTY-FIVE THOUSAND AND NINETYSEVEN DOLLARS, U.S. CURRENCY,
RESPONDENTS.

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Case No.: 38-CV-2015-900358

RESPONDENTS' MOTION FOR SUMMARY JUDGMENT

COMES NOW Respondents, James Vibbert and Consolidated Solutions, Inc., pursuant to
Ala. R. Civ. P. 56, hereby moves this Honorable Court to enter summary judgment on their
behalf on all claims asserted by the Plaintiff, as there is no genuine issue of any material fact, and
Respondents are entitled to judgment as a matter of law. Respondents' Motion is based upon the
following:
1.

The pleadings;

2.

The official trial transcript from the trial held in Houston County case number
CC-2016-389.

3.

The deposition of Brantley Taylor.

4.

The Indictment filed in CC-2016-389.

5.

The deposition of James Vibbert.

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6.

The bill of sale from the 2007 Chevrolet Tahoe

7.

The bill of sale from the 2009 BMW 3-Series.

8.

The Order of Not Guilty in Counts I and II in CC-16-389.

9.

The Order of Dismissal in Count III in CC-16-389.

Respectfully submitted this the 2nd day of April, 2016.

PARKMAN WHITE, LLP

/s/ M. John Steensland, III

M. John Steensland, III (STE168)
Attorney for Respondents
661 W. Main Street
Dothan, AL 36301
334-792-1900
334-712-1352 (FAX)
jsteensland@parkmanlawfirm.com

CERTIFICATE OF SERVICE
I certify that on the 2nd day of April, 2016 the foregoing was filed with the Clerk of the
Court using the electronic filing system which will send notification of such filing to all counsel
of record.

/s/ M. John Steensland, III

Of Counsel