S.tahue Mooret James Edward Bradley’ Shella McNair Robinson Christian. Spradley willam H. Edwards Stanley L. Myers Jane H. Downey? 5. lahue Moore, J. william 8. Fortino Ralph Nichols Riley sr Melissa K. Moore Lester McG Bal, Bryan C tettear Sierra D, Carini Lawrence 0. Turner J. Mark Taylor** Robert D. Hazel! David Sawyer, John C. Bradley Je. August 25, 2022 Billy C, Coleman (1936-2019) VIA PROCESS SERVER Margaret Harvey 300 West Third Street ‘Swansea, SC 29160 RE: Doris Simmons, Mike Luongo and Barrett Black vs. The Town of Swansea, Viola McDaniel, Margaret Harvey and John E. Brown C.A. No.: 2022-CP-32-02829 Dear Margaret Harvey: You will please find enclosed a Subpoena Duces Tecum and a copy of the Notice of Taking Deposition wit SIM/bw Enclosures ecwiencl.: Joseph D. Dickey, Jr., Esquire Doris Simmons Mike Luongo Barrett Black regard to the above matter which is hereby served upon you. ‘Ydurs very truly, ee ree eae eee S. Jahue Moore 1700 Sunset Boulevard, West Columbia SC 29169 | PO Box 5709, West Columbia SC 29171, ei 803.796.9160 rax 803.791.8410 www.mbmlawsc.com "amber of American Bare ofa Aévecstas "Flow ofthe Amaran Academy of Matimaniltawners "Cerin Sori RanSTATE OF SOUTH CAROLINA ISSUED BY THE COURT OF COMMON PLEAS IN THE COUNTY OF LEXINGTON Doris Simmons, Mike Luongo and DUCES TECUM SUBPOENA IN A CIVIL CASE Barrett Black, CASE NO.: C/A # 2020-CP-32-02829 Plaintiffs, vs. PENDING IN LEXINGTON COUNTY ‘The Town of Swansea, Viola McDaniel, Margaret Harvey and John E. Brown, Defendants. TO: Margaret Harvey 300 West Third Street Swansea, SC 29160 YOU ARE COMMANDED to appear in the above named court at the place, date and time specified below to testify in the above case, PLACE OF TESTIMONY: COURTROOM: DATE AND TIME: XXX_YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the taking of a deposition in the above case. PLACE OF DEPOSITION: DATE AND TIME: Friday, September 30, 2022 MOORE BRADLEY MYERS, P.A. 10:00 o°clock a.m. 1700 Sunset Boulevard, West Columbia SC 29169 XXX_YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or objects in your possession, custody or control at the place, date and time specified below: SEE ATTACHED EXHIBIT “A”, PLACE: DATE AND TIME: Friday, September 30, 2022 MOORE BRADLEY MYERS, P.A. 10:00 o’clock a.m, 1700 Sunset Boulevard, West Columbia, SC 29169 YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below. PREMISES: DATE AND TIME: ANY SUBPOENAED ORGANIZATION NOT A PARTY TO THIS SUIT IS HEREBY DIRECTED PURSUANT TO RULE 30(b)(6), SOUTH CAROLINA RULES OF CIVIL PROCEDURE, TO FILE A DESIGNATION WITH THE COURT SPECIFYING ONE OR MORE OFFICERS, DIRECTORS, OR MANAGING AGENTS, OR OTHER PERSONS WHO CONSENT TO TESTIFY ON ITS BEHALF, AND SHALL SET FORTH, FOR EACH PERSON DESIGNATED, ‘THE MATTERS ON WHICH HE WILL TESTIFY OR PRODUCE DOCUMENTS OR THINGS. THE PERSON SO DESIGNATED SHALL TESTIFY AS TO MATTERS KNOWN OR REASONABLY AVAILABLE TO THE ORGANIZATION, ISSUING OFFICER'S NAME, ADDRESS AND PHONE NUMBER, Jahue Moore, Esquire, P.O. Box 5709, West Columbia, SC_29169 (803) 796-9160 : I CERTIFY THAT THE SUBPOENA IS ISSUED IN COMPLIANCE WITH RULE 45(e)(1) AND THAT NOTICE AS REQUIRED BY RULE 45(b)(1) HAS BEEN GIVEN TO ALL PARTII Attorhey for Plaintiffs DATE August 25,2022 ISSUING OFFICER'S SIGNATURE AND TITLE (INDICATE IF ATTORNEY FOR PLAINTIFF OR DEFENDANT)EXHIBIT A Bring the actual deposit slips for the Town of Swansea Water Account for the years 2017, 2018, 2019, 2020, 2021 and 2022. Specifically, but without limiting the generality of the foregoing, bring all documents showing the amounts deposited by way of check and the amounts deposited by way of cash, along with all receipt books for each year mentioned above.STATE OF SOUTH CAROLINA} IN THE COURT OF COMMON PLEAS COUNTY OF LEXINGTON ) Doris Simmons, Mike Luongo and CA. No.: 2020-CP-32-02829 Barrett Black, ) ) ) Plaintiffs, ) vs ) NOTICE OF TAKING DEPOSITION ) ) ) ) ) The Town of Swansea, Viola McDaniel, Margaret Harvey and John E. Brown, Defendants. TO: MARGARET HARVEY, DEFENDANT: YOU WILL PLEASE TAKE NOTICE that on FRIDAY, SEPTEMBER 30, 2022 beginning at 10:00 o’elock a.m. on said date, at the offices of MOORE BRADLEY MYERS, P.A. 1700 Sunset Boulevard, West Columbia, South Carolina, the attomey for the Plaintiffs. will take the deposition of MARGARET HARVEY on oral examination, pursuant to South Carolina Rule of Civil Procedure No. 30, before a Notary Public or before some other officer authorized by law to take depositions; said deposition to continue from day to day until completed. You are invited to attend and take such part as is fit and proper MOORE BRADLEY MYERS, P.A. \ BY iy attetdteaeeoeeeeee S. Jahue Moore 1700 Sunset Boulevard P.O. Box 5709 West Columbia, SC 29171 (803) 796-9160 ATTORNEY FOR THE PLAINTIFFS ‘West Columbia, South Carolina August 25, 2022S.Jahue Moret James Edward Bradley! Sheila McNair Robinson Christian G. Spradiey Willam H. Edwards Stanley L. Myers Jane H. Downey* S.tahue Moore, J. Wiliam 8. Fortina Raloh Nichols Rey, John €. Bradley, J August 25, 2022 VIA PROCESS SERVER John B. Brown 209 Meadow Crest Drive West Columbia, SC 29169 Melissa K. Moore Lester McGil Bel, Bryan. Letteer Serra. Catint Lawrence D. Tuer Emily. Coline Retires J. Mark Taylor" Robert D. Harel? David Sawyer, Bily C. Coleman (1816-2013) RE: Doris Simmons, Mike Luongo and Barrett Black vs. The Town of Swansea, Viola McDaniel, Margaret Harvey and John E. Brown CA. No.: 2022-CP-32-02829 Dear Mr. Brown: “ember of American Bout of Tal Adora ‘You will please find enclosed a Subpoena Duces Tecum and a copy of the Notice of Taking, Deposition with regard to the above matter which is hereby served upon you. Thave enclosed a witness fee check in the amount of $25.00, te very trul; I S. Jahue Moore SIM/ow Enclosures cewiencl: Joseph D. Dickey, Jr., Esquire Doris Simmons Mike Luongo Barrett Black 1700 Sunset Boulevard, West Columbia SC 29169 | PO Box 5709, West Columbia SC 29171 el 803.796.9160 rax 803.791.8410 www.mbmlawse.com “Fallow ofthe American Academy of Mtrimonal Lawyers. *Cered Spat in ankrunty & Debtor/CreitorLaw "ResendSTATE OF SOUTH CAROLINA ISSUED BY THE COURT OF COMMON PLEAS IN THE COUNTY OF LEXINGTON Doris Simmons, Mike Luongo and DUCES TECUM SUBPOENA IN A CIVIL CASE Barrett Black, CASE NO.: C/A# 2020-CP-32-02829 Plaintiffs, vs. PENDING IN LEXINGTON COUNTY ‘The Town of Swansea, Viola McDaniel, Margaret Harvey and John E. Brown, Defendants. TO: John E, Brown 209 Meadow Crest Drive West Columbia, SC 29169 YOU ARE COMMANDED to appear in the above named court at the place, date and time specified below to testify in the above case. PLACE OF TESTIMONY: COURTROOM: DATE AND TIME: XXX_YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the taking of a deposition in the above ease. PLACE OF DEPOSITION: DATE AND TIME: Friday, September 30, 2022 MOORE BRADLEY MYERS, P.A. 1:00 o’elock p.m, 1700 Sunset Boulevard, West Columbia SC 29169 XXX YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or objects in your possession, custody or control at the place, date and time specified below: SEE ATTACHED EXHIBIT “A” PLACE: DATE AND TIME: Friday, September 30,2022 MOORE BRADLEY MYERS, P.A. 1:00 o°elock p.m. 1700 Sunset Boulevard, West Columbia, SC 29169 YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below. PREMISES: DATE AND TIME: ANY SUBPOENAED ORGANIZATION NOT A PARTY TO THIS SUIT IS HEREBY DIRECTED PURSUANT TO RULE 30(b)(6), SOUTH CAROLINA RULES OF CIVIL PROCEDURE, TO FILE A DESIGNATION WITH THE COURT SPECIFYING ONE OR MORE OFFICERS, DIRECTORS, OR MANAGING AGENTS, OR OTHER PERSONS: WHO CONSENT TO TESTIFY ON ITS BEHALF, AND SHALL SET FORTH, FOR EACH PERSON DESIGNATED, ‘THE MATTERS ON WHICH HE WILL TESTIFY OR PRODUCE DOCUMENTS OR THINGS. THE PERSON SO DESIGNATED SHALL TESTIFY AS TO MATTERS KNOWN OR REASONABLY AVAILABLE TO THE ORGANIZATION. ISSUING OFFICER'S NAME, ADDRESS AND PHONE NUMBER S.Jahue Moore, Esquire. P. O. Box $709, West Columbia, SC 29169 (803) 796-9160 L CERTIFY THAT THE SUBPOENA IS ISSUED IN COMPLIANCE WITH RULE 45(e)(1) AND THAT NOTICE AS REQUIRED BY RULE 45(b)(1) HAS BEEN GIVEN TO ALL PARVIIES. Attorney for Plaintl DATE August 25, 202: ISSUING OFFICER'S SIGNATURE AND TITLE (INDICATE IF ATTORNEY FOR PLAINTIFF OR DEFENDANT)1 EXHIBIT A Bring all of your working papers related to the audit of the Town of Swansea along with your audit report of the Town of Swansea,STATE OF SOUTH CAROLINA) IN THE COURT OF COMMON PLEAS COUNTY OF LEXINGTON ) Doris Simmons, Mike Luongo and C.A.No.: 2020-CP-32-02829 Barrett Black, ) ) ) Plaintiffs, ) vs. ) NOTICE OF TAKING DEPOSITION ) ) ) ) ) The Town of Swansea, Viola McDaniel, Margaret Harvey and John E. Brown, Defendants, TO: JOHN E. BROWN, DEFENDANT: YOU WILL PLEASE TAKE NOTICE that on FRIDAY, SEPTEMBER 30, 2022 beginning at 1:00 o’clock p.m. on said date, at the offices of MOORE BRADLEY MYERS, P.A. 1700 Sunset Boulevard, West Columbia, South Carolina, the attomey for the Plaintiffs will take the deposition of JOHN E. BROWN on oral examination, pursuant to South Carolina Rule of Civil Procedure No. 30, before a Notary Public or before some other officer authorized by law to take depositions; said deposition to continue from day to day until completed, You are invited to attend and take such part as is fit and proper. MOORE BRADLEY MYERS, P.A. BY: Cc ——— S. Jahue Moore 1700 Sunset Boulevard P.O. Box 5709 West Columbia, SC 29171 (803) 796-9160 ATTORNEY FOR THE PLAINTIFFS West Columbia, South Carolina August 25, 2022