ELECTRONICALLY FILED

Washington County Circuit Court

Kyle Sylvester, Circuit Clerk
2021-Apr-15 16:43:12
72CV-18-3357
C04D05 : 6 Pages

IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS

BRUCE LEWIN PLAINTIFF

VS. CASE NO.: 72CV-18-3357

HANNOVER HOUSE INC.;

MEDALLION RELEASING, INC.;
ERIC PARKINSON; and
D. FREDERICK SHEFTE DEFENDANTS

NOTICE OF INTENT TO ISSUE SUBPOENA

Pursuant to Rule 45(b)(1) of the Arkansas Rules of Civil Procedure, Bruce Lewin gives

notice to all parties that it intends to serve the attached subpoena upon Lisa Lashley Higgins, CPA

three business days or more after publication of this notice.

Respectfully submitted,

/s/ J. Brian Ferguson

J. Brian Ferguson
Arkansas Bar No. AR2018117
Ferguson Law Firm, PLLC
3333 Pinnacle Hills Pkwy, Suite 410
Rogers, AR 72758
(479) 464-4418 (Telephone)
brian@ozarkfunds.com

Attorney for Bruce Lewin

 CERTIFICATE OF SERVICE

I, J. Brian Ferguson, hereby certify that on the date the foregoing was electronically filed,
I also mailed copies of the Notice of Intent to Issue Subpoena and the subpoena via Fist Class U.S.
Mail postage prepaid to the following:

Hannover House, Inc.

c/o Eric F. Parkinson
1 W. Center Street
Fayetteville, AR 72701

Medallion Releasing, Inc.

c/o Eric Parkinson
1722 N. College Ave
Suite D
Fayetteville, AR 72701

Eric Parkinson
335 W. Holly St
Fayetteville, AR 72701

Eric Parkinson
355 N. College, Ave. Suite D
Fayetteville, AR 72701

Don Frederick Shefte

3741 N. Old Wire Road
Fayetteville, AR 72703-0000

VODWIZ, Inc.
c/o Steven H. Kay
300 N. College, Ste 311
Fayetteville, AR 72701

And via email to Steven H. Kay, Esq at steven@rockhouselaw.com

 Issued by the
CIRCUIT COURT
Washington County, Arkansas

BRUCE LEWIN SUBPOENA IN A CIVIL CASE

v. CASE NUMBER 74CV-18-3357
HANNOVER HOUSE, INC., ET AL.

TO: LISA LASHLEY HIGGINS

Of HIGGINS ACCOUNTING
111 N. CHURCH, St.
FAYETTEVILLE, AR 72701

□ YOU ARE COMMANDED to appear in the ___________ Court of ___________ County, Arkansas, at the place, date, and
time specified below to testify in the above case.

Place of Testimony Courtroom

Date and Time

□ YOU ARE COMMANDED to appear at the place, date, and time specified below to testify in the taking of a deposition in
the above case.

Place of Deposition Date and Time

□ YOU ARE COMMANDED, at the time of the trial, hearing or deposition described above, to produce and permit inspection
and copying of the following documents or objects (list documents or objects):
____________________________________________________________________________________________
____________________________________________________________________________________________

□ YOU ARE COMMANDED, no more than Fourteen (14) business days after receiving this subpoena, to produce and permit
inspection and copying of the following documents or objects (list documents or objects):

All DOCUMENTS DESCRIBED IN EXHIBIT A TO THIS SUBPOENA. The documents should be

produced to the Issuing Officer, whose name and address appears below
Any organization not a party to this suit that is subpoenaed for the taking of a deposition shall designate one or more officers,
directors, managing agents, or other persons who consent to testify on its behalf, and may set forth, for each person designated,
the matters on which the person will testify. Arkansas Rules of Civil Procedure 30(b)(6).
 Attorney for Plaintiff
Issuing Officer Signature and Title (Indicate if Attorney for Plaintiff or Defendant) Date

J. Brian Ferguson, Ferguson Law Firm, PLLC, 3333 Pinnacle Hills Parkway, Suite 410, Rogers,
AR 72758, (479) 464-4418, brian@ozarkfunds.com

Issuing Officer’s Name, Address, and Phone Number

PROOF OF SERVICE

SERVED Date Place

Served on (Print name) Manner of Service

Served by (Print name) Title

DECLARATION OF SERVER

I declare, under penalty of perjury under the laws of the State of Arkansas that the foregoing information
contained in the Proof of Service is true and correct.

Executed on _________________ ____________________________________

Date Signature of Server

____________________________________
Address of Server

NOTICE TO PERSONS SUBJECT TO SUBPOENAS

Regardless of his or her county of residence, a witness subpoenaed for examination at a trial or hearing must be properly served with a
subpoena at least two days prior to the trial or hearing, or within a shorter time if the court so orders. The subpoena must be accompanied by a
witness fee calculated at the rate of $30.00 per day for attendance and $0.25 per mile for travel from the witness’ residence to the place of the trial
or hearing. Rule 45(d), Ark. R. Civ. P.
A witness subpoenaed in connection with a deposition must be properly served with a subpoena at least five business days prior to a
deposition, or within a shorter time if the court so orders. The witness is required to attend a deposition at any place within 100 miles of where he
or she resides, is employed, or transacts business in person, or at such other convenient place set by court order. The subpoena must be accompanied
by a witness fee calculated at the rate of $30.00 per day for attendance and $0.25 per mile for travel from the witness’ residence to the place of the
deposition. Rule 45(e), Ark. R. Civ. P.
A subpoena may command the person to whom it is directed to produce for inspection any books, papers, documents, or tangible things
designated in the subpoena. The person subpoenaed may ask the court to quash or modify the subpoena if it is unreasonable or oppressive or to
require that the person on whose behalf the subpoena is issued pay the reasonable cost of such production. Rule 45(b), Ark. R. Civ. P. The person
subpoenaed may also object in writing to inspection or copying of any or all of the designated materials or seek a protective order from the court.
If a written objection is made within ten days of service of the subpoena or on or before the time specified for compliance if such time is less than
ten days, the party causing the subpoena to be issued is not entitled to inspect the materials unless the court so orders. Rule 45(e), Ark. R. Civ. P.
When a witness fails to attend in obedience to a subpoena or intentionally evades the service of a subpoena by concealment or otherwise,
the court may issue a warrant for arresting and bringing the witness before the court to give testimony and answer for contempt. Rule 45(g), Ark.
R. Civ. P.
 EXHIBIT A
TO SUBPOENA
Schedule of Documents to be Produced
Pursuant to the Arkansas Rules of Civil Procedure, you must produce the following
documents if such document is within your possession, custody, or control, unless you timely
object or file a motion to quash.

1. Federal and all state tax returns for the years 2020, 2019, 2018, 2017, and 2016 for: (a)
Hannover House, Inc.; (b) Medallion Releasing, Inc.; (c) Bookworks, Inc.; (d) VODWIZ,
Inc.; and (e) Eric Parkinson.

2. Documents sufficient to show the financial institutions in which Hannover House, Inc.;
Medallion Releasing, Inc.; Bookworks, Inc.; and VODWIZ, Inc. have held bank or other
financial accounts in any year from 2015 to 2021.

3. Documents sufficient to show revenues that Hannover House, Inc. or Medallion Releasing,
Inc. received concerning or relating to the movie “Dancin’, It’s On!”.

4. Documents sufficient to show how any revenues received concerning or relating to

Dancin’, It’s On! were distributed.

5. Documents sufficient to show how you were paid for any tax or accounting work you did
for Hanover House, Inc. in the last two years. If you were paid by checks, please produce
a legible copy of the checks. If you were paid by some type of electronic funds transfer,
please produce documents sufficient to show the remitter’s name, account number and
financial institution from which the payment was made.

6. Documents sufficient to show how you were paid for any tax or accounting work you did
for Medallion Releasing, Inc. in the last two years. If you were paid by checks, please
produce a legible copy of the checks. If you were paid by some type of electronic funds
transfer, please produce documents sufficient to show the remitter’s name, account number
and financial institution from which the payment was made.

7. Documents sufficient to show how you were paid for any tax or accounting work you did
for Bookworks, Inc. in the last two years. If you were paid by checks, please produce a
legible copy of the checks. If you were paid by some type of electronic funds transfer,
please produce documents sufficient to show the remitter’s name, account number and
financial institution from which the payment was made.

EXHIBIT A TO SUBPOENA Page 1 of 2

8. Documents sufficient to show how you were paid for any tax or accounting work you did
for VODWIZ, Inc. in the last two years. If you were paid by checks, please produce a
legible copy of the checks. If you were paid by some type of electronic funds transfer,
please produce documents sufficient to show the remitter’s name, account number and
financial institution from which the payment was made.

9. Documents sufficient to show how you were paid for any tax or accounting work you did
for Eric Parkinson in the last two years. If you were paid by checks, please produce a
legible copy of the checks. If you were paid by some type of electronic funds transfer,
please produce documents sufficient to show the remitter’s name, account number and
financial institution from which the payment was made.

10. Documents sufficient to show all debit or credit cards for which either Hannover House,
Inc; Medallion Releasing, Inc.; Bookworks, Inc.; or VODWIZ, Inc. is an obligor, but where
the card has been used by Eric Parkinson in the last five years.

11. For each card identified in the above document request, please provide the monthly
statements from March 2018 until March 2021.

12. Documents sufficient to show all expenditures by Hannover House, Inc. in the last two
years which were for the sole or joint benefit of Eric Parkinson, including but not limited
to expenditures for: salary, bonus, other compensation, rent, transportation, travel, dining,
legal, accounting, tax or insurance.

EXHIBIT A TO SUBPOENA Page 2 of 2