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IN THE UNITED STATES BANKRUPTCY COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI IN RE: JON CHRISTOPHER EVANS AND JOINTLY ADMINISTERED RELATED CASES DEBTORS. Case No. 09-03763-NPO

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G&B INVESTMENTS, INC. VS. DEREK A. HENDERSON, TRUSTEE FOR THE BANKRUPTCY ESTATE OF JOHN CHRISTOPHER EVANS, ET AL

PLAINTIFF ADV. PROC. NO. 10-00040-NPO

DEFENDANTS

Notice to Take Rule 30(b)(6) Deposition of G&B Investments, Inc.

PLEASE TAKE NOTICE that pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure, as incorporated by Fed. R. Bankr. P. 7030, Defendants, Mississippi Valley Title Insurance Company and Old Republic National Title Insurance Company (the "Title Companies") will take the stenographic and/or video tape deposition upon oral examination continuing day to day until completed before a notary public or some other person authorized to administer oaths as follows: DEPONENT: DATE: TIME: LOCATION: Plaintiff, G&B Investments, Inc. November 15, 2010 9:30 a.m. Law offices of Wells, Moore, Simmons & Hubbard 4450 Old Canton Rd, Suite 200 Jackson, Mississippi

Pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure, Plaintiff, G&B Investments, Inc. (“G&B”), must designate one or more officers, directors, or managing

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agents, or other person who consent to testify on its behalf as to matters known or reasonably available to the company as to the following topics or matters upon which examination is requested: 1. All matters asserted or alleged in G&B’s Second Amended Complaint filed in the above-captioned matter, including all exhibits attached thereto (the “Second Amended Complaint”); 2. All written or oral communications between G&B, its agents, officers, attorneys or employees and the Title Companies from January 1, 2003 to present; 3. All written or oral communications between G&B, its agents, officers or employees and Jon Christopher Evans, Charles H. Evans, Jr., Hanover Investments, LLC, 463 Development Company, LLC, and/or White Oaks Investment Company, LLC, their agents or employees, relating in any way to the allegations or assertions contained in the Second Amended Complaint and/or any pleading filed by the Plaintiff in the above captioned matter and/or any related proceeding; 4. All written or oral communications between G&B, its agents, officers or employees and any other person or entity relating in any way to the transactions, allegations, or assertions identified or contained in any pleading filed by G&B or any other party in the above captioned matter and/or any related proceeding; 5. All documents or information relating in any way to the matters asserted or alleged by any party in the above-captioned matter; 6. All documents or information relating in any way to any transactions between G&B and Jon Christopher Evans, Charles H. Evans, Jr. and/or any entities owned,

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controlled or represented by Jon Christopher Evans, Charles H. Evans, Jr., including without limitations Hanover Investments, LLC and 463 Development Company, LLC; 7. All written or oral communications between G&B, its agents, officers or employees and any person or entity retained by G&B or otherwise consulted with in connection with any transactions between G&B and Jon Christopher Evans, Charles H. Evans, Jr. and/or any entities owned, controlled or represented by Jon Christopher Evans, Charles H. Evans, Jr.; 8. All documents or information relating in any way to payments or money received from or through Jon Christopher Evans, Charles H. Evans, Jr. and/or any entities owned, controlled or represented by Jon Christopher Evans, Charles H. Evans, Jr., including without limitations Hanover Investments, LLC and 463 Development Company, LLC; 9. All written or oral communications between G&B, its agents, officers, attorneys, or employees and any banks, their agents, officers, attorneys or employees, relating in any way to the above-caption matter or any related matter from September, 2009, until present; 10. All matters regarding assignments of liens and/or conveyances of property to or from G&B from January 1, 2008 until present regarding the property known as Tract 4 and as described in G&B’s Second Amended Complaint; 11. All matters relating in any way to the real estate agreement, attached as Exhibit 2 to the Second Amended Complaint; 12. Facts known and relied upon by G&B for purposes of filing the lis pendens filed

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in the Madison County Chancery Court records on September 16, 2009, at book 2468, page 985; 13. All matters relating in any way to the warranty deed, attached as Exhibit 7 to the Second Amended Complaint; 14. All matters relating in any way to the deed of trust, attached as Exhibit 9 to the Second Amended Complaint; 15. All matters relating in any way to the promissory note, attached as Exhibit 8 to the Second Amended Complaint; 16. All matters relating to G&B’s the notice of foreclosure and the subsequent Trustee’s deed obtained by G&B arising out of the instruments attached to the Second Amended Complaint as Exhibits 32-33; 17. G&B’s alleged damages and a calculation therefore arising out of the facts asserted in the Second Amended Complaint; 18. All investigations, decisions, recommendations, findings, proposals, minutes, communications, memoranda, or notes of any agent, officer, employee, or committee of G&B relating in any way to the matters alleged or asserted in any pleading filed in the above-captioned matter; 19. Any and all claims and/or allegations pending or to be asserted by G&B against the Title Companies; 20. G&B’s net worth; 21. The location of and/or G&B’s use of the $5,000,000.00 received from Hanover Investments, LLC arising out of the transaction regarding the property known as Tract 4 and as described in the Second Amended Complaint;

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22. G&B’s ownership and organizational structure; and 23. All matters relating in any way to the management, oversight, direction, operation, or supervision of G&B. Respectfully submitted, this the 21st day of October, 2010. MISSISSIPPI VALLEY TITLE INSURANCE COMPANY and OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY By: /s/ Scott Jones William C. Brabec (MSB No. 4240) M. Scott Jones (MSB No. 102239) ADAMS AND REESE LLP 111 East Capitol Street, Ste. 350 Post Office Box 24297 Jackson, Mississippi 39225-4297 Telephone: 601-353-3234 Facsimile: 601-355-9708 E-mail: bill.brabec@arlaw.com E-mail: scott.jones@arlaw.com

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CERTIFICATE OF SERVICE I hereby certify that on this day, a copy of the foregoing has been served by electronic filing through the ECF System, which provides electronic notice to all counsel of record. This the 21st day of October, 2010. /s/ Scott Jones OF COUNSEL

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