Letter,Correspondence: Blake Tartt, III vs. John Doe, Et Al

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                                Filed: 9/23/2021 5:59 PM
                                                                              JOHN D. KINARD - District Clerk
                                                                                    Galveston County, Texas
                                                                                     Envelope No. 57560513
                                                                                                By: Lisa Kelly
                                                                                           9/24/2021 7:57 AM



                               CAUSE NO. 20-CV-1975

BLAKE TARTT, III                           §               IN THE DISTRICT COURT OF
                                           §
VS.                                        §             GALVESTON COUNTY, TEXAS
                                           §
JOHN DOE AND                               §
JANE DOE                                   §                    56TH JUDICIAL DISTRICT


                MOTION FOR ISSUANCE OF LETTERS ROGATORY
             FOR DEPOSITION OF THE CUSTODIAN OF RECORDS OF
       THE OFFICE OF HUMAN RESOURCES OF MISSISSIPPI STATE UNIVERSITY


TO THE HONORABLE COURT:

      Plaintiff Blake Tartt, III requests the issuance of letters rogatory and a subpoena

duces tecum, directed to The Custodian of Records of the Office of Human Resources

of Mississippi State University (“MSU”), in The Circuit Court of Mississippi, County of

Lafayette, requesting the production of certain business records, and in support of this

motion shows:

      1.     This is an action for defamation.

      2.     If there are costs associated with the production of the requested

information, Plaintiff will pay the cost of production prior to delivery by MSU.

      3.     The witness is a resident of the State of Mississippi and is the custodian

of the records of the Office of Human Resources of MSU. Telephone(s) and/or email
addresses assigned to MSU personnel are alleged to have been used to disseminate false

information regarding Plaintiff, to Plaintiff's detriment.

        4.      Plaintiff has good cause to believe that the witnesses have knowledge of

and are competent to testify on these matters:

        5.      Requested documents that relate, refer or pertain to Martray Thompson-

Murphy, to be produced:

                a.      University of Mississippi issued phones used by Martray
                        Thompson Murphy to copy stored data that mention "Tartt" or
                        "Blake Tartt" or "Blake Tartt III"

                b.      Complete, unredacted employment file of Martray Thompson
                        Murphy, Martray K. Thompson Murphy, Martray K. Murphy, or
                        Martray K. Thompson-Murphy SSN XXX-XX-1322.

                c.      All emails sent to or received by Martray Thompson Murphy,
                        Martray K. Thompson Murphy, Martray K. Murphy, or Martray
                        K. Thompson-Murphy.

                d.      All emails sent to or received by martraythompson38@gmail.com.

                e.      Office and cell Phone logs for Martray Thompson Murphy

                f.      All correspondence to or from phone number 662-371-5937.

                g.      All documents, emails or other correspondence that mention
                        phone number 662-371-5937.

A business records affidavit is attached for MSU's use.

        6.      WHEREFORE, Plaintiff Blake Tart, III requests that the Court order

the Clerk of the Court to issue The Custodian of Records of MSU a letter rogatory.

Motion for Issuance of Letters Rogatory
Re The Custodian of Records of the Office of
H uman Resources of Mississippi State University                          20-CV-1975 – Page 2
                                                   Respectfully Submitted,

                                                   Johnston & McLean, PLLC
                                                   7950 Legacy Drive, Suite 330
                                                   Plano, Texas 75024
                                                   (972) 436-1661
                                                   (972) 436-1615 – Facsimile



                                                             /s/ William W. Johnston
                                                   By______________________________
                                                   William W. Johnston
                                                   State Bar No. 10846700
                                                   billjohnstonlawoffice@gmail.com
                                                   Attorney for Plaintiff

                                                               /s/ Calvin G. McLean
                                                   By_______________________________
                                                   Calvin G. McLean
                                                   State Bar No. 24091885
                                                   goc.garfieldlaw@gmail.com
                                                   Attorney for Plaintiff




Motion for Issuance of Letters Rogatory
Re The Custodian of Records of the Office of
H uman Resources of Mississippi State University                             20-CV-1975 – Page 3
                                     CERTIFICATE OF SERVICE

        I hereby certify that the foregoing

                  MOTION FOR ISSUANCE OF LETTERS ROGATORY
               FOR DEPOSITION OF THE CUSTODIAN OF RECORDS OF
         THE OFFICE OF HUMAN RESOURCES OF MISSISSIPPI STATE UNIVERSITY

was served on Defendants via electronic filing service

on this 23rd day of September 2021.




                                                         /s/ Calvin G. McLean
                                                   _________________________________
                                                   Calvin G. McLean




Motion for Issuance of Letters Rogatory
Re The Custodian of Records of the Office of
H uman Resources of Mississippi State University                       20-CV-1975 – Page 4
                         Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.




Envelope ID: 57560513
Status as of 9/24/2021 7:57 AM CST

Associated Case Party: Blake Tartt

Name                      BarNumber   Email                          TimestampSubmitted      Status

William Wilson Johnston   10846700    billjohnstonlawoffice@gmail.com 9/23/2021 5:59:52 PM   SENT

Calvin McLean             24091885    GoC.GarfieldLaw@gmail.com      9/23/2021 5:59:52 PM    SENT