Byrant Subpoena

Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 1 of 24
IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

FIRST JUDICIAL DISTRICT
MISSISSIPPI DEPARTMENT OF HUMAN SERVICES PLAINTIFF
v. CAUSE No. 22-cv-00286-EFP
MISSISSIPPI COMMUNITY EDUCATION CENTER, INC., ET AL. DEFENDANTS
and
MISSISSIPPI COMMUNITY EDUCATION CENTER, INC. COUNTER-PLAINTIFF
v.
MISSISSIPPI DEPARTMENT OF HUMAN SERVICES COUNTER-DEFENDANT
SUBPOENA DUCES TECUM
STATE OF MISSISSIPPI
COUNTY OF HINDS
TO: Dewey Phillip Bryant

7009 Highway 28
Hazlehurst, MS 39083
YOU ARE HEREBY SUMMONED to produce, ON OR BEFORE 10 DAYS FROM THE
DATE OF RECEIPT OF THIS SUBPOENA, a true and correct copy ofthe documents designated
below, and to mail or otherwise transmit exact copies of said documents to counsel for Mississippi
Community Education Center at Carroll Bufkin, PLLC, 1076 Highland Colony Parkway, 600
Concourse, Suite 125, Ridgeland, Mississippi 39157. 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 to counsel or by U.S. Mail or other carrier to arrive at the aforesaid location within ten
(10) days from the date this Subpoena was served.

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 HAND AND SEAL AND ISSUED BY THIS OFFICE, this the
)£____day <if~~&r~+-----2022.
HINDS COUNTY CIRCUIT COURT
By:~ /
Deputy Clerk
Thomas G. Bufkin
Luke E. Whitaker
CARROLL BUFKIN, PLLC
1076 Highland Colony Parkway
600 Concourse, Suite 125
Ridgeland, MS 39157
T: (601) 982-5011
F: (601) 853-9540
tgb@carrollbutkin.com
lwhitaker@carrollbutkin.com
2
..Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 3 of 24
CERTIFICATE OF AUTHENTICITY
I HEREBY CERTIFY that the reproduction of records attached to this certificate are, to
the best of my knowledge, true and accurate copies of the records requested in this Subpoena
Duces Tecum. The originals of said documents are on file with me personally and said records
were made and kept in the regular course of business.
I FURTHER CERTIFY that I am the person responsible for maintaining and controlling
these records, and/or the appointed designee responsible for the release of these records.
Dated this the _ _ day of _ _ _ _ _ _ 2022.
RECORDS CUSTODIAN
COUNTY O F - - - - - - -
SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ _ __

2022.
NOTARY PUBLIC
My Commission Expires:
3
RETURN OF SERVICE
I , - - - - - - - - - - - - - - ' process server, do hereby certify that I am not
a party to the above-captioned civil action, am not less than 18 years of age, and have delivered
the above-and-foregoing SUBPOENA DUCES TECUM by serving a true and correct copy of
same upon_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Thisthe __ dayof _ _ _ _ _ _ _ _ 2022.
Process Server
COUNTY OF _ _ _ __
SWORN AND SUBSCRIBE before me this the __ day of _ _ _ _ _ _ _ 2022.
NOTARY PUBLIC
4
...Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 5 of 24
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, 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; agreements;
contracts; inter-office communications; memoranda; 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 mail; ledgers; financial statements;
accounting records; general ledgers; microfilm; microfiche; tape or disc recordings; and computer
print outs. 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
electronically stored data from which any information can be obtained, either directly or indirectly,
or by translation through detection devices or readers, and includes information stored in, or
accessible through, computer or other information retrieval systems (including any computer
archives or back-up systems).
The "USM Volleyball Center" refers to the facilities located on the University of Southern
Mississippi campus at or around 101 M.K. Turk Circle, Hattiesburg, Mississippi 39406, which
have been or are being used, in whole or in part, to serve women's volleyball and/or women's
beach volleyball.
5
Exhibit "A"
DOCUMENTS TO BE PRODUCED WITHIN TEN (10) DAYS
1. All Documents including, without limitation, Documents reflecting communications

between you and any person or entity concerning the USM Volleyball Center.

between you and any person or 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
the USM Volleyball Center.
6
IN THE CIRCUIT COURT OF fiNDS COUNTY, MISSISSIPPI

and
v.
COUNTY OF HINDS
TO: Office of Attorney General for Mississippi

550 High Street
Jackson, Mississippi 39201

~day~ 2022.
By~ /
Deputy Clerk
Thomas G. Bufkin
Luke E. Whitaker
Ridgeland, MS 39157
T: (601) 982-5011
F: (601) 853-9540
tgb@carrollbufkin.com
lwhitaker@carrollbufkin.com
2
Duces Tecum. The originals of said documents are on file at the OFFICE OF THE ATTORNEY
GENERAL FOR MISSISSIPPI and said records are made and kept in the regular course of
business.
Dated this the _ _ day of _ __ _ _ _ 2022.
RECORDS CUSTODIAN
COUNTY OF _ _ _ _ _ __
SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ __

2022.
NOTARY PUBLIC
3
RETURN OF SERVICE
I, _ _ _ _ _ _ _ _ _ _ _ _ _ _, process server, do hereby certify that I am not
same upon_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
This the __ day of _ _ _ _ _ _ _ _ 2022.
Process Server
COUNTY OF _ _ _ __
SWORN AND SUBSCRIBE before me this the __ day of _ _ _ _ _ _ _ 2022.
NOTARY PUBLIC
4
Definitions
A "Document" is any written, recorded, or graphic n::taterial of any kind, whether prepared
beach volleyball.
The "USM Volleyball Center Leases" include all Documents related in any way to:
(a) "Amended and Restated Lease between the University of Southern Mississippi and the
University of Southern Mississippi Athletic Foundation, Inc." and/or
(b) "Sublease between The University of Southern Mississippi Athletic Foundation, Inc.
and Mississippi Community Education Center."
"TANF" is the Temporary Assistance for Needy Families program operated by the State
ofMississippi pursuant to Miss. Code Ann. 43-17-1 and 42 U.S.C. §601, as well as other provision
of State and federal law.
5
EXHIBIT "A"
DOCUMENTS TO BE PRODUCED WITIDN TEN (10) DAYS
1. All Documents relating in any way to the USM Volleyball Center.
2. All Documents relating in any way to the USM Volleyball Center Leases.
3. All Documents reflecting or relating in any way to approval, in whole or in part, by the
Office of the Attorney General for Mississippi of any aspect of the USM Volleyball Center
and/or the USM Volleyball Center Leases.
4. All Documents reflecting or relating in any way to conclusions reached by the Office of
the Attorney General for Mississippi, prior to the date of execution of the USM Volleyball
Center Leases, that construction of the USM Volleyball Center was a permissible TANF
expenditure and served a TANF purpose.
6
IN THE CIRCillT COURT OF IDNDS COUNTY, MISSISSIPPI

and
v.
COUNTY OF HINDS
TO: Institutions of Higher Learning

State of Mississippi
3825 Ridgewood Rd.
Jackson, Mississippi 39211
(1 0) days from the date this Subpoena was served.

.Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 14 of 24
~ day of 2022.
Deputy Clerk
ISSUED AT THE REQUEST OF:
Thomas G. Bufkin
Luke E. Whitaker
107 6 Highland Colony Parkway
Ridgeland, MS 39157
T: (601) 982-5011
F: (601) 853-9540
2
.Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 15 of 24
Duces Tecum. The originals of said documents are on file at the INSTITUTIONS OF IDGHER
LEARNING OF THE STATE OF MISSISSIPPI and said records are made and kept in the
regular course of business.
Dated this thL - day of 2022.
RECORDS CUSTODIAN
COUNTY OF ____________
SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ ___

2022.
NOTARY PUBLIC
3
RETURN OF SERVICE
same upon_ _ _ _ _ __ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___
This the __ day of _ _ _ _ _ _ _ _ 2022.
Process Server
COUNTY OF _ _ _ __
SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ __ _ _ 2022.
NOTARY PUBLIC
4
..Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 17 of 24
EXHffiiT "A" TO SUBPOENA
Definitions
beach volleyball.
and Mississippi Community Education Center." .
5
EXHIBIT "A"
DOCUMENTS TO BE PRODUCED WITIDN TEN (10) DAYS
1. All Documents relating in any way to the USM Volleyball Center.
2. All Documents relating in any way to the USM Volleyball Center Leases.
3. All Documents reflecting, or relating in any way to, approval, in whole or in part, by the
Office of the Attorney General for Mississippi of any aspect of the USM Volleyball Center
and/or either of the USM Volleyball Center Leases.
6
IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

and
v.
COUNTY OF HINDS
TO: The University of Southern Mississippi Athletic Foundation, Inc.

Registered Agent: Richard C. Giannini
Pat Ferlise Center- 3001 West 4th Street
Hattiesburg, MS 39402
DATE OF RECEIPT OF THIS SUBPOENA, a true and correct copy of the documents designated

::AS day of~"""7

~:. . _ _ _=.,,___ _ 2022.
Deputy Clerk
ISSUED AT THE REQUEST OF:
Thomas G. Bufkin
Luke E. Whitaker
Ridgeland, MS 39157
T: (601) 982-5011
F: (601) 853-9540
2
Duces Tecum. The originals of said documents are on file at THE UNIVERSITY OF
SOUTHERN MISSISSIPPI ATHLETIC FOUNDATION, INC. and said records are made and
kept in the regular course of business.
Dated this the _ _ day of _ _ _ _ _ _ 2022.
RECORDS CUSTODIAN
COUNTY OF _ _ _ _ _ __
SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ __ __

2022.
NOTARY PUBLIC
3
Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 22 of 24 I
I
RETURN OF SERVICE
same upon._ __ _ _ _ __ _ _ _ _ _ _ __ _ _ _ __ _ _ _ __
This the _ _ day of _ _ _ _ _ _ _ _ 2022.
Process Server
COUNTY OF _ _ _ __
SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ _ _ 2022.
NOTARY PUBLIC
4
Definitions
"You" and "Your" refer to the University of Southern Mississippi Athletic Foundation,
Inc. ("USMAF") and its board members, officers, employees, agents, and any other person acting
on its behalf.
have been or are being used, in whole or in part, to serve women' s volleyball and/or women's
beach volleyball.
and Mississippi Community Education Center."
"TANF" is the Temporary Assistance for Needy Families program operated by the State
of Mississippi in conjunction with the federal government pursuant to 42 U.S.C. §601 and Miss.
Code Ann. 43-17-1 , as well as other applicable provisions of federal and State law.
5
DOCUMENTS TO BE PRODUCED WITHIN TEN (10) DAYS

between You and any person or entity relating in any way to the USM Volleyball Center
and/or the USM Volleyball Center Leases.

between You and any person or entity relating in any way to funding, in whole or in part,
for the USM Volleyball Center.

between You and any person or entity relating in any way to pledges or promises for
funding, in whole or in part, for the USM Volleyball Center.
4. All Documents relating in any way to Your conclusion prior to the date of execution of the
USM Volleyball Center Leases that the USM Volleyball Center and/or the USM Volleyball
Center Leases were permissible TANF expenditures and the USM Volleyball Center
served a T ANF purpose.

between You and anyone with the Attorney General ' s Office for Mississippi in relation to
the USM Volleyball Center and/or the USM Volleyball Center Leases.
6. All Documents, including, without limitation, bank statements and other financial records
identifying transactions wherein funds were received by You from any entity or person, or
paid by You to any person or entity, in relation to the USM Volleyball Center and/or the
USM Volleyball Center Leases.

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Case: 25CI1:22-cv-00286-EFP Document #: 93 Filed: 07/25/2022 Page 1 of 24

IN THE CIRCUIT COURT OF HINDS COUNTY, MISSISSIPPI

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES PLAINTIFF

v. CAUSE No. 22-cv-00286-EFP

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC., ET AL. DEFENDANTS

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC. COUNTER-PLAINTIFF

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES COUNTER-DEFENDANT

SUBPOENA DUCES TECUM

TO: Dewey Phillip Bryant

YOU ARE HEREBY SUMMONED to produce, ON OR BEFORE 10 DAYS FROM THE

ALL DOCUMENTS DESCRIBED IN EXHIBIT "A"

(10) days from the date this Subpoena was served.

with your production of Documents.

and have then and there this writ.

were made and kept in the regular course of business.

Dated this the _ _ day of _ _ _ _ _ _ 2022.

SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ _ __

I , - - - - - - - - - - - - - - ' process server, do hereby certify that I am not

Thisthe __ dayof _ _ _ _ _ _ _ _ 2022.

SWORN AND SUBSCRIBE before me this the __ day of _ _ _ _ _ _ _ 2022.

EXHIBIT "A" TO SUBPOENA

DOCUMENTS TO BE PRODUCED WITHIN TEN (10) DAYS

1. All Documents including, without limitation, Documents reflecting communications

2. All Documents including, without limitation, Documents reflecting communications

3. All Documents, including, without limitation, Documents reflecting communications

IN THE CIRCUIT COURT OF fiNDS COUNTY, MISSISSIPPI

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES PLAINTIFF

v. CAUSE No. 22-cv-00286-EFP

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC., ET AL. DEFENDANTS

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC. COUNTER-PLAINTIFF

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES COUNTER-DEFENDANT

SUBPOENA DUCES TECUM

TO: Office of Attorney General for Mississippi

YOU ARE HEREBY SUMMONED to produce, ON OR BEFORE 10 DAYS FROM THE

ALL DOCUMENTS DESCRIBED IN EXHIBIT "A"

(10) days from the date this Subpoena was served.

with your production of Documents.

and have then and there this writ.

HINDS COUNTY CIRCUIT COURT

Dated this the _ _ day of _ __ _ _ _ 2022.

SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _ _ __

I, _ _ _ _ _ _ _ _ _ _ _ _ _ _, process server, do hereby certify that I am not

This the __ day of _ _ _ _ _ _ _ _ 2022.

SWORN AND SUBSCRIBE before me this the __ day of _ _ _ _ _ _ _ 2022.

EXHIBIT "A" TO SUBPOENA

DOCUMENTS TO BE PRODUCED WITIDN TEN (10) DAYS

1. All Documents relating in any way to the USM Volleyball Center.

IN THE CIRCillT COURT OF IDNDS COUNTY, MISSISSIPPI

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES PLAINTIFF

v. CAUSE No. 22-cv-00286-EFP

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC., ET AL. DEFENDANTS

MISSISSIPPI COMMUNITY EDUCATION CENTER, INC. COUNTER-PLAINTIFF

MISSISSIPPI DEPARTMENT OF HUMAN SERVICES COUNTER-DEFENDANT

SUBPOENA DUCES TECUM

TO: Institutions of Higher Learning

YOU ARE HEREBY SUMMONED to produce, ON OR BEFORE 10 DAYS FROM THE

ALL DOCUMENTS DESCRIBED IN EXHIBIT "A"

(1 0) days from the date this Subpoena was served.

with your production of Documents.

and have then and there this writ.

HINDS COUNTY CIRCUIT COURT

ISSUED AT THE REQUEST OF:

regular course of business.

same upon_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___

SWORN AND SUBSCRIBE before me this the _ _ day of _ _ _ _