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IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

FIRST JUDICIAL DISTRICT

STATE OF MISSISSIPPI

V. CAUSE NO. 22-601

TONI JOHNSON DEFENDANT

SUBPOENA DUCES TECUM

STATE OF MISSISSIPPI
COUNTY OF HINDS

TO: Jonathan Tate Reeves

Governor of the State of Mississippi
550 High Street Ste. 19
Jackson, MS 39201

You are hereby summoned to produce on or before 10 days from the date of

receipt of this subpoena, a true and correct copy of the documents designated

below, and to mail or otherwise transmitted exact copies of said documents to the

Honorable Jess Dickinson, Hinds County Courthouse, 407 E. Pascagoula Street,

Jackson, Ms. 39201. The documents to be produced are:

ALL DOCUMENTS DESCRIBED IN EXHIBIT "A"

Your personal appearance is not required. The requested documents may be

delivered personally or sent by U.S. Mail mail or other carrier to arrive at the

aforesaid location within 10 days from the date that this subpoena was served.
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Case: 25CI1:22-cr-00601 Document #: 39 Filed: 12/13/2022 Page 2 of 8

Please complete and return a notarized original of the attached "Certificate

of Authenticity" with your production of documents.

HEREIN YOU SHALL NOT FAIL UNDER PENALTY IN SUCH

CASE PROVIDED, and have then and there this writ.

GIVEN UNDER MY AND SEAL AND ISSUED BY THIS OFFICE, this

the Z3 day of ix,/ ,2022.

HINDS COUNTY CIRCUIT C U T

ISSUED AT THE REQUEST OF:

Lisa M. Ross
MSB # 9755
514 E. Woodrow Wilson Avenue
Jackson, Mississippi 39216
T: (601) 981-7900
F: (601) 981-7917
IrossAlmrossatlaw.com

CERTIFICATE OF SERVICE

I, Lisa M. Ross, attorney for the defendant, Toni Johnson, certify that I have

this date filed the subpoena duces tecum with the Clerk of this Court using the

MEC system which sent notification of such filing to all counsel of record. In

addition, I have caused on this day a copy of the subpoena duces tecum to be
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Case: 25CI1:22-cr-00601 Document #: 39 Filed: 12/13/2022 Page 3 of 8

delivered to David Moron, Chief Legal Counsel to Governor Tate Reeves, P.O.

Box 139, Jackson, Ms. 39205-0139 (david.maron@govreeves.com) and

Mississippi Attorney General Lynn Fitch, 550 High Street, Suite 1200, Jackson,

Ms. 39205-1113 (lynn.fitch@ago.ms.gov).

This the,"5" day of November, 2022.

,S44, ge
Lisa M. Ross
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Case: 25CI1:22-cr-00601 Document #: 39 Filed: 12/13/2022 Page 4 of 8

EXHIBIT "A" TO SUBPOENA

Definitions

A "Document" is any written, recorded, or graphic material of any kind,

whether prepared by you or by any other person or, that is in your possession,
custody, or control. You are deemed to have "control" if you have the right
to secure the document or a copy thereof from another person or entity. The •
definition of document includes, without limitation, electronic mail (email),
text messages; instant messages; direct messages; correspondence; letters;
telegrams; contracts; interoffice communications, memorandas, reports,
summaries, notes, notebooks, scrapbooks, diaries, calendars, plans, drawings,
sketches, blueprints, diagrams, photographs, photocopies, charts, graphs,
descriptions, minutes of meetings, conferences, conversations or
communications, invoices, purchase orders, bills of lading, recordings,
published or unpublished speeches or articles, publications, transcripts, phone
voice mails, ledgers, financial statements, accounting records, general ledgers,
microfilm, microfiche, tape or disc recordings, and computer printouts. It
also includes all drafts of a document and all copies that differ in any respect
from the original or other versions including any notation, underlining,
marking, marginalia, or information of any kind not in any original or other
versions. A "Document" further includes all files (including any computer
archives or backup systems).

Exhibit "A"
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Case: 25CI1:22-cr-00601 Document #: 39 Filed: 12/13/2022 Page 5 of 8

Exhibit "A"

DOCUMENTS TO BE PRODUCED WITHIN TEN (10) DAYS

1. All documents including, without limitation, document reflecting

communications between you and any person or entity concerning the
USM Volleyball Center;
2. All documents including, without limitation, documents reflecting
communications between you and entity concerning funding for the
USM Volleyball Center;
3. All documents, including, without limitation, documents reflecting
communications between you and any person intended to further efforts
to secure funding from MDHS for USM Volleyball Center;
4. All documents, including, without limitation, documents reflecting
communications concerning funding pertaining to Prevacus and Brett
Favre and any other entity;
5. All documents, including, without limitation, documents reflecting
communications between you and any other person intended to further
secure funding from the Mississippi Department of Human Services for
Mississippi Community Education Center;
6. All documents, including, without limitation, documents reflecting
communications between you and any other person, not limited to but
including Nancy New, Zack New, Ted Dibiase Jr., Brett Favre, John
Davis;
7. All documents, including, without limitation, documents reflecting
communications between you and any other person, not limited to but
including Paul Victor Lacoste regarding funding for a fitness program;
8. Any documents, including, without limitation, documents reflecting
communications between you and any other person, not limited to but
including Shadrick White regarding funding from the Center for Tech
and Civic Life during the past three years;
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Case: 25CI1:22-cr-00601 Document #: 39 Filed: 12/13/2022 Page 6 of 8

9. All documents, including, without limitation, documents reflecting

communication between you and any other person, not limited to but
including Shadrick White regarding Hinds County Election
Commissioner Toni Johnson.
Case: 25CI1:22-cr-00601 Document #: 39 Filed: 12/13/2022 Page 7 of 8

ATTORNEY GENERAL

March 20, 2020

Notice

Service of Process Upon the Office of the Attorney General

During the COVID-19 State of Emergency

The 12th floor lobby of the Attorney General's Office is closed to

the public. As of March 20, 2020, and until further notice, Attorney
General Lynn Fitch has designated the lockbox located at the Capitol
Police desk in the lobby of the Walter Sillers State Office Building at
550 High Street, Jackson, Mississippi as the location for the Attorney
General to receive service of process pursuant to Mississippi Rule of
Civil Procedure 4(d)(5) and Federal Rule of Civil Procedure 4(j)(2)(B).
Summonses and subpoenas to be served on the Attorney General's
Office Should be placed in this lockbox.
The Capitol Police will not provide an acknowledgment of service.
However, you may take a copy of this notice and the accompanying
Attorney General's Office business card for your files.
As a reminder, subpoenas seeking documents in the possession,
custody, or control of a state agency other than the Attorney General's
Office must be served directly on that agency. Placing those subpoenas
in this lockbox is not legally sufficient service of process.
The lockbox will be checked once a day. If the matter requires
immediate attention, or if you have a question about service of process,
please call or email Assistant Attorney General Doug Miracle at
601-359-5654 or doug.miracle@ago.ms.gov.
( 4//// • "%a/

ATTORNEY GENERAL

Summons Receipt

Received Date: 2022 Time:

Capitol Police:
Case: 25CI1:22-cr-00601 Document #: 39 Filed: 12/13/2022 Page 8 of 8

PROOF OF SERVICE

Name of Person or Entity Served (Ltsk-r-

I, the undersigned process server, served
upon the person or entity
named above in the manner set forth below (process server must check proper space and
provide all additional information that is request and pertinent to the mode of service
sued):
FIRST CLASS MAIL AND ACKNOWLEDGEMENT SERVICE. By mailing (by first
class mail, postage prepaid), on the date stated in the attached Notice, Copies to the person served,
together with copies of the form of notice and acknowledgement and return envelope, postage
prepaid, addressed to the sender
(attached complete acknowledgement of receipt pursuant to M/R/C.P. Forml
L., -4ERSONAL SERVICE. I personally delivered copies to on the
9 day of 1\1‘. \,4 ,
2011.where I found said person(s) in 14 #
County of the State of Mississippi.
RESIDENCESERVICE. After exercising reasonable diligence I was unable to deliver
copies to said person within county, , (State). I served the summons
and complaint on the day of who is the
(here insert wife, husband, son, daughter or other person as the case may be), a member of the
family of the person served above the age of sixteen years and willing to received the
, and thereafter on the day of _
, 20 , I mailed (by first mail, postage prepaid) copies to the person served at his or
her usual place of abode where the copies were left.
CERTIFIED MAIL SERVICE. By mailing to an address outside Mississippi (by first
class mail, postage prepaid, requiring a return receipt) copies to the person served. Attached signed
return receipt or other evidence of actual delivery to the person served.) At the time of service I
was at least 18 years of age and not a party to this action.

Process s rver must kikt b w (please print or type):

Name el it_ 1 1 6; A
Social Security No.
Address g , (s-
Telephone No. (I) - 9 5
State of 11‹1 ' )-1
County of , 0.4
Personally appeared before in the undersigned authority in and for the state and county aforesaid,
the within name QA
(.01 c-4 who being first by me duly sworn states on oath that
the matters and facts set foihJn the foregoing Proof of Service" are true and correct as therein
stated.
(Process Server) Signature
a ...„
Sworn to and subscribed before me this the '") ficlay of ,20Z&
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