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IN THE UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI

IN RE:

JON CHRISTOPHER EVANS Case No. 09-03763-NPO

AND JOINTLY ADMINISTERED
RELATED CASES

DEBTORS. Chapter 7

G&B INVESTMENTS, INC. PLAINTIFF

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

DEREK A. HENDERSON, TRUSTEE

FOR THE BANKRUPTCY ESTATE OF
JOHN CHRISTOPHER EVANS, ET AL 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: Plaintiff, G&B Investments, Inc.

DATE: November 15, 2010
TIME: 9:30 a.m.
LOCATION: 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