McRae v. Gilmer File I

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IN THE CHANCERY COURT OF HINDS COUNTY, MISSISSIPPI
MCRAE LAW FIRM, PLLC
VS.
PLAINTIFF
CAUSE NO. 16-cv-1064
GILMER LAW FIRM, P.A., ET AL.
DEFENDANTS
MOTION TO QUASH TRIAL SUBPOENA AND FOR PROTECTIVE ORDER

OF SETH C. LITTLE
COMES NOW, Seth C. Little, entering a special limited appearance for the
purpose of filing the instant Motion to Quash Trial Subpoena and for Protective Order
seeking relief regarding a trial subpoena served upon him, and in support thereof, states
as follows:
1. On August 11, 2016, Seth C. Little was served at his place of employment
with a Trial Subpoena compelling his attendance at a court proceeding in the instant
action at the Chancery Court of Hinds County on August 15, 2016 at 10:00 a.m.
2. Seth C. Little is not a party in the instant action, and is not sure of the
character or nature of the hearing set for August 15, 2016, as such was not described in
the Trial Subpoena nor has Seth C. Little been in any communication with Chuck
McRae or any agent or employee of the McRae Law Firm, PLLC regarding the August
15, 2016 hearing.
3.
Seth C. Little is currently employed as an associate attorney with the
Schwartz Law Firm and has only been in such employment for less than one month. As a
new hire with the firm, Seth C. Little is still in his initial probationary period of
employment with the firm and his continued employment beyond this probationary
period will be based on Seth C. Littles performance with the cases assigned to him.
4. On August 15, 2016, Seth C. Little is scheduled to attend two depositions in

Filed: 08/11/2016 Page 2 of 6
Brookhaven, Mississippi, one in which Seth C. Littles client is being deposed by defense
counsel, and a deposition in which Seth C. Little is deposing an employee of one of the
Defendants. These depositions have been scheduled and noticed since before Seth C.
Little was served with the instant subpoena on August 11, 2016.
See Notices of
Deposition collectively attached as Exhibit A. The instant case is Seth C. Littles sole
responsibility as this case is his assigned file and Little is the only attorney from the
Schwartz Law Firm assigned to the case and familiar with the case.
5. Compelling Seth C. Littles attendance at the hearing or court proceeding on
August 15, 2016 would present an undue burden to Little as not appearing or cancelling
the previously scheduled deposition in Brookhaven, Mississippi could create negative
consequences in the case in which Seth C. Little is the only assigned attorney from the
Schwartz Law Firm and by extension would likely result in negative consequences to
Seth C. Littles probationary employment with the Schwartz Law Firm.
6.
Although Seth C. Little is unaware of the nature of the August 15, 2016
hearing, it is his understanding that this is not an emergency hearing seeking any type of
emergency relief. Seth C. Little is available to appear and provide testimony on several
other dates in August, September, and beyond, and would be glad to present to the Court
and counsel his schedule for the next several months ahead, as these contain several dates
in which Little does not have a scheduled deposition or court appearance.
7.
Furthermore, after receiving the Trial Subpoena in the instant matter on
August 11, 2016, it came to Seth C. Littles attention that McRae Law Firm, PLLC has
previously sought in this matter via subpoena Littles cell phone records and bank
records. Little has no idea the relevance of these records to the instant proceeding, and
2

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strongly objects to their production and will seek relief regarding said subpoenae via
separate motion. Little has also viewed the Complaint in this matter, which makes
several factual allegations involving Little.
8.
The above facts clearly show that the McRae Law Firm has considered Seth
C. Little as a necessary an integral party in the instant lawsuit, and began subpoenaing
Littles personal records on August 1, 2016. Per the docket in this matter, the Plaintiff
knew of the August 15, 2016 hearing date in this matter as early as August 4, 2016.
Despite this fact, the Plaintiff waited until the Thursday prior to a Monday court
proceeding to subpoena Seth C. Littles attendance at the August 15, 2016 court
proceeding, undoubtedly for the purpose of leaving a very short amount of time, basically
one business day, to respond or seek any relief to which he may be entitled regarding the
subpoena pursuant to Rule 26 and Rule 45 of the Mississippi Rules of Civil Procedure.
9.
The above facts, that the Plaintiff began subpoenaing Seth C. Littles personal
records on August 1, 2016 and yet waited to subpoena Little for trial until August 11,
2016 strongly suggests that the Plaintiff are using the August 15, 2016 hearing as a back
door to obtain sworn testimony from Little, complete with his personal records, without
having to name Seth C. Little as a party. Without Little being a Defendant or other party
in the instant action and therefore not being a party to be noticed in the instant action, the
Plaintiff has essentially been able to request Littles personal records without notice to
Little. The foregoing facts strongly suggest that the Plaintiff is using the August 15, 2016
hearing and their subpoena of Seth C. Little to provide testimony as a trial or hearing by
ambush.
10. As the Plaintiff has requested Littles personal records via subpoena with a
3

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clear intent to use them in the instant proceeding and further in this matter, Seth C. Little
has a right to object to the production of these records pursuant to Rule 45 and Rule 26 of
the Mississippi Rules of Civil Procedure prior to being compelled to provide testimony in
this matter.
Furthermore, if the Court allows the Plaintiff to receive and use said
documents, Seth C. Little is entitled to receive and review these records prior to
providing any testimony in this matter. Allowing the Plaintiff to request Seth C. Littles
personal records as a non-party without notice to Little, while at the same time
subpoenaing Little to provide testimony with less than one business day of notice to him
is oppressive and creates an undue burden to Little who, as a non-party, should not be
compelled to endure.
11. Rule 45(d) of the Mississippi Rules of Civil Procedure provides that a court
shall quash a subpoena if it fails to allow a reasonable time for compliance, requires
disclosure of privileged or other protected material, or subjects a person to undue burden
or expense. In the instant matter, compelling Seth C. Littles attendance at the August
15, 2016 court proceeding would subject Seth C. Little of the undue burden of cancelling
a previously scheduled deposition in a civil action in which he is the sole responsible
attorney for the Plaintiff, thereby threatening negative consequences to Littles
representation in said matter as well as threatening irreparable harm to Littles
probationary employment with Schwartz Law Firm. Furthermore, allowing the Plaintiff
in this matter to subpoena Seth C. Littles personal records without notice to him and then
subpoenaing Littles attendance at a hearing in the matter less than one business day prior
to said hearing is akin to attempting a trial or hearing by ambush, and would certainly
result in an undue burden to Little. There is no compelling reason why the instant matter
4

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cannot be rescheduled to one of the many dates in August and September that Little
would be available to provide testimony, thereby allowing Little to properly object to the
production of his personal records and to review said records in the event the production
of said records are allowed by the Court.
WHEREFORE, PREMISES CONSIDERED, Seth C. Little, appearing for the
limited purpose of filing the instant motion for relief, asks the Court to enter an Order
quashing the instant subpoena due to the undue burden that would be imposed on Seth C.
Little should he be compelled to appear in this matter on August 15, 2016. Little requests
any other relief to which he may be entitled.
__/s/ Seth C. Little, pro se
Seth C. Little, MSB#102890
162 E. Amite Street
Jackson, Mississippi 39201
(601) 988-8888
slittle@1call.org
CERTIFICATE OF SERVICE
5

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I, Seth C. Little, certify that on this date I served the foregoing pleading in the
instant matter via ECF electronic filing to all counsel of record.
/s/ Seth C. Little

_
Seth C. Little, MSB#102890

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IN THE CHANCERY COURT FOR THE FIRST JUDICIAL DISTRICT

OF HINDS COUNTY, MISSISSIPPI
PLAINTIFF
V.
CIVIL ACTION NO: G2016-1064 W/Y
BARRY WADE
DBA GILMER
GILMER LAW
AKA GILMER
GILMER LAW
GILMER, INDIVIDUALLY AND

LAW FIRM, PA;
FIRM, A PROFESSIONAL ASSOCIATION
LAW FIRM, PA; AND
FIRM, PLLC (Business ID 1041903)
DEFENDANTS
SPECIAL ENTRY OF APPEARANCE OF MATTHEW WADE GILMER,

MOTION TO QUASH AND MOTION FOR PROTECTIVE ORDER
COMES NOW Matthew Wade Gilmer and appears specially before
this Court without waiving any procedural or substantive defenses,
affirmative or otherwise, and files this Motion To Quash and Motion
For Protective Order, and would most respectfully show unto the
Court the following, to wit:
SPECIAL ENTRY OF APPEARANCE

1.
Matthew Wade Gilmer specially appears before this Court
and alleges that Matthew Wade Gilmer has not been properly served
with process of any summons, complaint or notice of subpoena duces
tecum. As a result, Matthew Wade Gilmer reserves all procedural
and due process objections and defenses, whether affirmative or
otherwise, afforded to him by Mississippi Law, Mississippi Rules
Of
Civil
Procedure,
the
Mississippi
Constitution,
the
United
States Constitution, the Uniform Rules Of Chancery Court and any

applicable local rule of Chancery Court Practice. Without waiving
said defenses, Matthew Wade Gilmer would show unto the Court the
following, to wit:

Filed: 08/12/2016 Page 2 of 8
FACTS
2.
On
August
11,
2016
Matthew
Wade
Gilmer
received
facsimile notice from BankPlus alerting Matthew Wade Gilmer that

Plaintiff caused to be issued and served upon BankPlus two subpoena
duces tecum. Said subpoenas command BankPlus to produce highly
confidential bank records which are the property of Matthew Wade
Gilmer and pertain to bank accounts which Matthew Wade Gilmer is
charged as the sole agent in charge of said accounts and the sole
signator on said accounts. Said subpoenas bear a stamped filed
issue date of August 8, 2016. Said subpoenas were made returnable
only six days later from the date of issuance, that date being
August 15, 2016 at 8:30 AM.
3.
On August 11, 2016 Matthew Wade Gilmer was contacted by
BankPlus telephonically and informed that said subpoenas were

served upon BankPlus along with a letter from Plaintiffs counsel,
Michele Biegel, urging BankPlus to produce the documents requested
by the subpoenas in less time than ten days.
4.
On August 12, 2016 Matthew Wade Gilmer received a Motion
To Quash the trial subpoena of Seth C. Little. Littles Motion

alleges inter alia that Plaintiff, Plaintiffs Counsel and Chuck
McCrae have engaged in ambush-type discovery practices seeking
instant production of documents which are private to Seth Little.
Littles Motion also alleges that Plaintiff is attempting to
procure back-door testimony from Little and that Plaintiff has
designed his entire Complaint with the intent to ambush the parties
involved and other persons by abusing chancery court emergency
jurisdiction.
5.
As a result of the totality of the circumstances, Matthew
Wade Gilmer appears here specially to contest the two subpoenas

duces tecum (Docket #13 and #14) caused by Plaintiff and requests
that a protective order be issued prohibiting Plaintiff from
engaging in improper discovery practices in the future.
2

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MOTION TO QUASH SUBPOENAS DUCES TECUM

[DOCKET #13 AND DOCKET #14]
I.
BOTH SUBPOENAS ARE VOID AND DEFECTIVE AS ISSUED

6.
Pursuant to Mississippi Rules Of Civil Procedure Rule
45, subpoena duces tecum may only be made returnable not less than
ten days after said subpoena has been served upon the person or
entity that is to produce the documents commanded by said subpoena.
Specifically, Unless for good cause shown the court shortens the
time, a subpoena for production or inspection shall allow not less
than ten days for the person upon whom it is served to comply with
the
subpoena.
copy
of
all
such
subpoenas
shall
be
served
immediately upon each party in accordance with Rule 5. M.R.C.P.

45.
7.
The two subpoena duces tecum (Docket #13 and #14) are
defective and void as issued. Specifically, each subpoena was

issued by the clerk on August 8, 2016 at the insistence Plaintiff
even though said subpoenas are made returnable only six days later.
See Exhibit A. The very face of each subpoena is defective as it
renders it impossible to produce the requested documents in the
mandatory time permitted by M.R.C.P. Rule 45. Therefore, each
subpoena is fatally defective on its face and should be held a
nullity.
8.
Plaintiffs Counsel and Plaintiff, a law firm comprised
of lawyers the chief officer of which served as a Mississippi

Supreme Court Justice, are both charged with understanding the
Mississippi Rules Of Civil Procedure. Additionally, Plaintiffs
counsel and Plaintiff are further charged with a duty of candor
which runs not only to their clients but to the courts, the courts
clerks, neutral third parties and Plaintiffs adversaries. By
causing
the
two
facially
defective
subpoenas
to
take
issue,
Plaintiff committed a material misrepresentation to the clerk, to

3

Filed: 08/12/2016 Page 4 of 8
the court and to the non-lawyer third party to whom the subpoena
is directed (BankPlus). In addition to causing defective subpoenas
to take issue, Plaintiff and its counsel wrote to BankPlus and
attempted to persuade BankPlus to obey each subpoena in a length
of time shorter than the mandatory ten days afforded to BankPlus
and the parties to object to said subpoena. by M.R.C.P. Rule 45.
This overt act in conjunction with Plaintiffs failure to advise
BankPlus of its legal right to ten days to obey each subpoena
constitutes an attempt by Plaintiff and its counsel to subvert
justice. These acts and omissions further constitute a calculated
plan to prey upon a non-lawyer third-partys ignorance of the law
for the benefit of Plaintiff and Plaintiffs counsel. These acts
and omissions not only constitute a calculated plan to subvert
justice, said acts and omissions have gone unnoticed and have
potentially caused irreparable harm to Matthew Wade Gilmer, the
clients of Matthew Wade Gilmer and others who may become affected
by the production of the documents sought by the subpoenas.
9.
Upon
information
and
belief,
Plaintiffs
Complaint
alleges that Matthew Wade Gilmer is somehow a party-defendant to

this action, and therefore, Matthew Wade Gilmer is entitled to
service of all subpoena duces tecum.
M.R.C.P. 45. Therefore,
Matthew Wade Gilmer would be permitted the same ten days to file
and serve upon Plaintiff a written objection to said subpoenas.
Matthew Wade Gilmer has not been served any subpoena issued under
this cause of action. This includes the subpoenas directed to
BankPlus and AT&T. Upon further information and belief, the public
docket reflects no document has been filed certifying service of
the subpoenas upon any person or entity, including BankPlus. This
attempt to disguise the service of the subpoenas further supports
1 Matthew Wade Gilmer has not been served with a copy of a summons and/or
Complaint by traditional means or otherwise.

Filed: 08/12/2016 Page 5 of 8
the allegation that the issuance and service of the defective

subpoenas upon BankPlus was intentional. Therefore, Plaintiffs
and Plaintiffs counsels actions constitute a clear breach of the
duty of candor owed to the court, the clerk, the parties 2 and to
third parties at large. As such, Matthew Wade Gilmer respectfully
requests that his Court award attorneys fees associated with the
prosecution of this motion as well as sanctions aimed at deterring
Plaintiff and Plaintiffs counsel from engaging in this type of
improper discovery in the future.
II.
THE MATERIALS SOUGHT TO BE PRODUCED UNDER THE SUBPOENAS ARE
PROTECTED
BY
ATTORNEY
CLIENT
PRIVILEGE
AND
CONFIDENTIALITY
AGREEMENTS EXISTING BETWEEN MATTHEW WADE GILMER AND OTHERS

10.
The two subpoenas duces tecum issued by Plaintiff and
served upon BankPlus seek to discover documents which contain

highly sensitive information protected by the attorney client
privilege then and now existing between Matthew Wade Gilmer and
his clients. See Mississippi Rules Of Civil Procedure Rule 26 in
its entirety. As such, Matthew Wade Gilmer alleges that obedience
of the subpoenas by BankPlus will cause dissemination of highly
confidential
information
thereby
causing
irreparable
harm
to
Matthew Wade Gilmer and his clients. Matthew Wade Gilmer further
alleges that the production of documents sought by each subpoena
duces tecum will breach the confidentiality owed by Matthew Wade
Gilmer to his clients.
11.
Matthew Wade Gilmer further alleges that the documents
sought by each subpoena are highly confidential and subject to a

confidentiality
agreement
and/or
non-disclosure
agreement.
Production of the documents by BankPlus will constitute a violation

of this agreement as Matthew Wade Gilmer is the sole signator and
2
Matthew Wade Gilmer takes the position that he is not a party to this
action.

Filed: 08/12/2016 Page 6 of 8
agent charged with the duty of control over the bank accounts that
are the subject of the subpoenas. This duty requires Matthew Wade
Gilmer to preserve the confidentiality of the banking documents
associated with said accounts including the documents sought by
each subpoena. Production of said documents by BankPlus will
subject Matthew Wade Gilmer and others to irreparable harm which
is not quantifiable at this time.
MOTION FOR PROTECTIVE ORDER

12.
Pursuant to Mississippi Rules Of Civil Procedure Rule
26(d) a court may make any order which justice requires to protect
a party or person from annoyance, embarrassment, oppression, or
undue burden or expense, including one or more of the following:
(4) that certain matters not be inquired into, or that the scope
of the discovery be limited to certain matters.. M.R.C.P 26(d)(4).
13.
Matthew Wade Gilmer now petitions this court to enter an
order pursuant to M.R.C.P Rule 26 which protects Matthew Wade

Gilmer, BankPlus and the clients of Matthew Wade Gilmer from
further improper discovery seeking to discover documents covered
by
attorney
client
privilege
and/or
violates
the
duty
of
confidentiality owed by Matthew Wade Gilmer to his clients. This

includes requests to discover information directly related to the
financial of affairs of Matthew Wade Gilmer and/or his clients.

Filed: 08/12/2016 Page 7 of 8
WHEREFORE,
PREMISES
CONSIDERED,
Matthew
Wade
Gilmer
respectfully requests the following relief:
(a)
this Court enter an Order which makes a finding of fact
that the subpoenas caused to be issued by Plaintiff (Docket #13

and #14) are each defective on its face;
(b)this Court quash said subpoenas and strike the same from
the record;
(c)
this Court enter an Order which makes a finding of fact
that Plaintiff and its counsel engaged in improper discovery

tactics aimed at subverting justice and ambushing the litigants
and other third parties;
(d)
this Court award Matthew Wade Gilmer attorneys fees and
sanctions related to the prosecution of this Motion;
(e)
Plaintiff
this
from
Court
enter
attempting
to
Protective
discover
any
Order
prohibiting
information
which
relates to the affairs of Matthew Wade Gilmer and/or the affairs

of the clients of Matthew Wade Gilmer from any person or entity
including BankPlus.
Respectfully Submitted,
Matthew Wade Gilmer
By: /s/ MATTHEW WADE GILMER
MATTHEW WADE GILMER
LITIGANT BY SPECIAL APPEARANCE
MATTHEW WADE GILMER

POST OFFICE BOX 919
MADISON, MISSISSIPPI 39130
601-898-9130
FAX-898-9785
7

Filed: 08/12/2016 Page 8 of 8
I, Matthew Wade Gilmer, do hereby certify I have filed the
above Pleading and Special Appearance with the Clerk of this Court
using the MEC/ECF system which has served a true and correct copy
of the same on the following persons:
Michele Biegel
Attorney For Plaintiff
michele@brjlaw.net
I, Matthew Wade Gilmer, further certify that I have served
this Motion by hand delivery on the following non-MEC participants:
BankPlus
Legal Department
1068 Highland Colony Pkwy
Ridgeland, MS 39157
SO CERTIFIED, this the 12th day of August, 2016.
/s/ MATTHEW WADE GILMER
MATTHEW WADE GILMER

POST OFFICE BOX 919
MADISON, MISSISSIPPI 39130
601-898-9130
FAX-898-9785

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IN THE CHANCERY COURT OF THE FIRST JUDICIAL DISTRICT

OF HINDS COUNTY, MISSISSIPPI
PLAINTIFF
VS
CAUSE NO. G2016-1064 W/4
BARRY WADE
DBA GILMER
GILMER LAW
AKA GILMER
GILMER LAW
GILMER, INDIVIDUALLY AND

LAW FIRM, PA;
FIRM, A PROFESSIONAL ASSOCIATION
LAW FIRM, PA; AND
FIRM, PLLC (Business ID 1041903)
DEFENDANTS
NOTICE
PLEASE TAKE NOTICE that the undersigned has this morning
telephoned the Hinds County Chancery Clerks office upon
learning that certain documents were incorrectly filed via MEC
and attempted to speak with the Clerk but she was unavailable.
Ultimately,
the
undersigned
spoke
to
three
different
individuals in the Clerks office in an effort to have these

documents immediately removed from MEC and placed back under
seal.
SO NOTICED, this the 15th day of August, 2016.
MICHELE D. BIEGEL, Attorney for

McRae Law Firm

Filed: 08/15/2016 Page 2 of 2
I, Michele D. Biegel, certify that I have this date
served a copy of the above and foregoing MOTION with the Clerk
of the Court using the MEC system which sent notification of
such filing to the following:
Gilmer Law Firm, PLLC
c/o Matthew Wade Gilmer, Registered Agent
140 Fountains Boulevard, Suite E
Madison, Mississippi 39130
mwgilmer@gilmerlawfirm.com
Barry W. Gilmer, Individually and
d/b/a Gilmer Law Firm, PA
gilmerlaw@gilmerlawfirm.com
Gilmer Law Firm, a Professional Association
a/k/a Gilmer Law Firm, PA
c/o Barry Wade Gilmer, Registered Agent
gilmerlaw@gilmerlawfirm.com
SO CERTIFIED, this the 15th day of August, 2016.
MICHELE D. BIEGEL
LAW OFFICE OF B. RUTH JOHNSON, PLLC
B. Ruth Johnson
br@brjlaw.net
Mississippi Bar No. 3106
Michele D. Biegel
michele@brjlaw.net
Mississippi Bar No. 101166
405 Tombigbee Street (39201)
Post Office Box 2433
Jackson, Mississippi 39225-2433
Telephone: (601) 354-1000
Facsimile: (601) 354-9994
ATTORNEYS FOR MCRAE LAW FIRM, PLLC
2

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GILMER LAW FIRM, P.A., ET AL.

MOTION TO QUASH TRIAL SUBPOENA AND FOR PROTECTIVE ORDER

Seth C. Little is currently employed as an associate attorney with the

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Furthermore, after receiving the Trial Subpoena in the instant matter on

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