Party Discovery: COUNTY OF DALLAS vs. ALLERGAN FINANCE LLC (F/K/A ACTAVIS INC F/K/A WATSON PHARMACEUTICALS

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                                MDL PRETRIAL CAUSE NO. 2018-77098

   COUNTY OF DALLAS,                                         §
            Plaintiff,                                       §
                                                             §                        IN THE DISTRICT COURT
   v                                                                                  116th JUDICIAL DISTRICT
                                                                                      DALLAS COUNTY, TEXAS
   PURDUE PHARMA, L.P. et al.,
                  Defendants.
                                                             §
ARE CICI ICI   ICICI     RIG I CIE     ACI ICIGIGIGCGICI CI CIICIGI OSI IGISIS SSSI   AICI CIGAR   IIA AIAG RII
                                       MASTER        FILE NO. 2018-63587

                                                             §
       IN RE: TEXAS OPIOID LITIGATION                        §                        IN THE DISTRICT COURT
                                                             §                        152nd JUDICIAL DISTRICT
                 MDL NO. 18-0358
                                                             §                        HARRIS COUNTY, TEXAS


                                          THE STATE OF TEXAS

SUBPOENA FOR DEPOSITION ON WRITTEN QUESTIONS (WITH DUCES TECUM)!

TO:    Custodian of Records, Texas State Board of Dental Examiners, at George H. W.
Bush State Office Building, 1801 Congress Avenue, Suite 8.600, Austin, Texas 78701

SUBPOENA ISSUED IN THE NAME OF THE STATE OF TEXAS

TO ANY SHERIFF OR ANY CONSTABLE OF THE STATE OF TEXAS, OR ANY OTHER
PERSON AUTHORIZED TO SERVE AND EXECUTE SUBPOENAS AS PROVIDED IN
TEXAS RULE OF CIVIL PROCEDURE 176

Greetings:

          You are commanded to appear for a deposition on written questions of the custodian of

records for the Texas State Board of Dental Examiners in accordance with Rule 200 of the Texas

Rules of Civil Procedure. The questions directed to the designated person(s) that will be examined

are described in Exhibit A.



          ' This document is issued subject to and without waiver of the Pharmacy Defendants’ motion to stay
discovery, which is currently pending with the Court. If the Court grants that motion and stays discovery, we will
promptly notify you.




                                                                                                   ert: B\ao|2       23   €   ['qo
                                                                                                                                     fu
You are further commanded to produce all documents within your possession, custody, or

control responsive to the requests that are set forth in the Requests for Production of Documents

attached hereto as Exhibit B. The production of documents and deposition on written questions

will occur at the office of the custodian of records at George H. W. Bush State Office Building,

1801 Congress Avenue, Suite 8.600, Austin, Texas 78701 within twenty (20) days of your receipt

of the subpoena, at a date and time that will be coordinated with the Texas State Board of Dental

Examiners.

FAILURE TO OBEY THIS SUBPOENA MAY BE TREATED AS A CONTEMPT OF
COURT. TEXAS RULE OF CIVIL PROCEDURE 176.8(a) PROVIDES AS FOLLOWS:
“Failure by any person without adequate excuse to obey a subpoena served upon that
person may be deemed a contempt of the court from which the subpoena is issued or a
district court in the county in which the subpoena is served, and may be punished by fine
or confinement, or both.”

This subpoena is issued at the request of Defendant Walmart.”

Date of Issuance: March 22, 2023

SUBPOENA ISSUED BY:

/s/ Christopher H. Domingo
Christopher H. Domingo
Texas Bar No. 24069621
JONES DAY
717 Texas, Suite 3300
Houston, Texas 77002
Phone: 832.239.3939
Fax: 832.239.3600
chdomingo@jonesday.com

Attorney for Defendants Walmart Inc.;
Walmart Stores East, LP; Wal-Mart Stores
East, LLC; Wal-Mart Stores Texas, LLC;
WSE Management, LLC; WSE Investment,
LLC; Sam's East, Inc.; Sam’s West, Inc.



         2 Walmart Inc., Walmart Stores East, LP, Wal-Mart Stores East, LLC, Wal-Mart Stores Texas, LLC, WSE
 Management, LLC, WSE Investment, LLC, Sat            t, Inc., Sam’s West, Inc.
THIS SUBPOENA HAS ALSO BEEN ISSUED BY THE FOLLOWING COUNSEL:

/s/ Bradley A. Monk
Bradley A. Monk
Texas Bar No. 24077502
Hilgers Graben PLLC
7859 Walnut Hill Lane, Suite 335
Dallas, TX 75230
469-640-6842
bmonk@hilgersgraben.com

Attorney for Walgreen Co., Walgreen
Eastern Co., Inc., and Walgreens Boots
Alliance, Ine.

/s/ Katrina G. Eash
Katrina G. Eash
WINSTON & STRAWN LLP
2121 N. Pearl Street, Suite 900
Dallas, TX 75201
(214) 453-6500
KEash@winston.com

Christopher B. Essig
Scott M. Ahmad
WINSTON & STRAWN           LLP
35 W. Wacker Drive
Chicago, IL 60601
(312) 558-5600
CEssig@winston.com
SAhmad@winston.com

Counsel for Defendant West-Ward Pharmaceuticals
Corporation n/k/a Hikma Pharmaceuticals USA Inc.




                                             3
MEMORANDUM             OF ACCEPTANCE

I accepted service of a copy of this subpoena on                                            » 2023

Signature:

Printed Name:

Title:

                                   RETURN OF SUBPOENA

I certify that I served the attached subpoena by delivering a copy and the required fee of $11 to
  * DIANE HOBSON                         in person at George H. W. Bush State Office Building,
 1801 Congress Avenue, Suite 8.600, Austin, TX 78701 on           More Ze            , 2023. My
fee for this service has been paid in advance.

Signature:                        aes
Printed Name:              C        € L. CreniLo

Process Server ID:

                                 CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing document was served in accordance
with the Texas Rules of Civil Procedure through the state’s e-filing system on all counsel of
record on March 22, 2023.



                                                    /s/ Christopher H. Domingo
                                                    Christopher H. Domingo
                                                    Texas Bar No. 24069621
                                                    JONES DAY
                                                    717 Texas, Suite 3300
                                                    Houston, Texas 77002
                                                    Phone: 832.239.3939
                                                    Fax: 832.239.3600
                                                    chdomingo@jonesday.com

                                                    Attorney for Defendants Walmart Inc.;
                                                    Walmart Stores East, LP; Wal-Mart Stores
                                                    East, LLC; Wal-Mart Stores Texas, LLC;
                                                     WSE Management, LLC; WSE Investment,
                                                    LLC; Sam’s East, Inc.; Sam’s West, Inc.
" ‘        farts

      De