On December 13, 2023 a
Pet Filed in Circuit Ct
was filed
for CC Other Miscellaneous Actions
in the District Court of Stoddard County.
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Electronically Filed - STODDARD - December 13, 2023 - 11:30 AM
23SD-CC00120
IN THE CIRCUIT COURT OF STODDARD COUNTY, MISSOURI
CIVIL DIVISION
JOSHUA MELTON PLAINTIFF
vs. No. _______________
BAYIRD, INC. DEFENDANT
APPLICATION FOR ORDER DIRECTING ISSUANCE OF SUBPOENA
IN AID OF TAKING DEPOSITIONS FOR USE IN A FOREIGN JURISDICTION
Pursuant to Rules 57.08 and 57.09, Missouri Rules of Civil Procedure, Defendant, Bayird,
Inc., applies for an order directing the issuance of subpoenas in aid of taking depositions for use
in a foreign jurisdiction. A matter styled Joshua Melton v. Bayird, Inc., Case No. 16JCV-23-1405,
is pending in the Western District of the Circuit Court of Craighead County, Arkansas. Defendant
applies for the issuance of subpoenas for use in that matter and states as follows:
1. Defendant requests this Court to order the issuance of a subpoena directed to (1)
Joshua Robinson; (2) Lori Robinson; and (3) other deponents to be named as discovery progresses,
with due notice to be filed. Exhibit 1 attached hereto is a notice of deposition for Joshua Robinson.
Exhibit 2 attached hereto is a notice of deposition for Lori Robinson.
2. Defendant will file and serve upon all counsel of record in the Arkansas action a
Notice to Take Deposition notifying all parties of each deposition to be held before the issuance of
the applicable subpoena.
3. The named deponents may be found in Stoddard County, Missouri. The production
of documents by and the depositions upon oral examination of these deponents are to be done by
counsel for Defendant, before a court reporter and a person duly appointed to administer oaths, at
Electronically Filed - STODDARD - December 13, 2023 - 11:30 AM
the Stoddard County Justice Center, 403 South Prairie Street, Courtroom B, Bloomfield, MO
63825. Specific dates and times will be designated in the subpoenas and notices filed.
4. Attached to this Application as Exhibits 1 and 2 are the original subpoenas issued
pursuant to Arkansas law.
WHEREFORE, Defendant, Bayird, Inc. prays for an immediate Order of the Court
authorizing the issuance of subpoenas as may be necessary for the depositions noticed up in the
pending action.
Respectfully submitted,
BARBER LAW FIRM PLLC
Attorneys for Defendant
425 West Capitol Avenue, Suite 3400
Little Rock, AR 72201
(501) 372-6175
By /s/ Perry Wilson
Perry Wilson, MO BIN 72286
pwilson@barberlawfirm.com
James D. Robertson, AR BIN 95181
jrobertson@barberlawfirm.com
Casey L. Mynatt, AR BIN 2022143
cmynatt@barberlawfirm.com
2
Document Filed Date
December 13, 2023
Case Filing Date
December 13, 2023
Category
CC Other Miscellaneous Actions
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Electronically Filed - STODDARD - December 13, 2023 - 11:30 AM 23SD-CC00120 IN THE CIRCUIT COURT OF STODDARD COUNTY, MISSOURI CIVIL DIVISION JOSHUA MELTON PLAINTIFF vs. No. _______________ BAYIRD, INC. DEFENDANT APPLICATION FOR ORDER DIRECTING ISSUANCE OF SUBPOENA IN AID OF TAKING DEPOSITIONS FOR USE IN A FOREIGN JURISDICTION Pursuant to Rules 57.08 and 57.09, Missouri Rules of Civil Procedure, Defendant, Bayird, Inc., applies for an order directing the issuance of subpoenas in aid of taking depositions for use in a foreign jurisdiction. A matter styled Joshua Melton v. Bayird, Inc., Case No. 16JCV-23-1405, is pending in the Western District of the Circuit Court of Craighead County, Arkansas. Defendant applies for the issuance of subpoenas for use in that matter and states as follows: 1. Defendant requests this Court to order the issuance of a subpoena directed to (1) Joshua Robinson; (2) Lori Robinson; and (3) other deponents to be named as discovery progresses, with due notice to be filed. Exhibit 1 attached hereto is a notice of deposition for Joshua Robinson. Exhibit 2 attached hereto is a notice of deposition for Lori Robinson. 2. Defendant will file and serve upon all counsel of record in the Arkansas action a Notice to Take Deposition notifying all parties of each deposition to be held before the issuance of the applicable subpoena. 3. The named deponents may be found in Stoddard County, Missouri. The production of documents by and the depositions upon oral examination of these deponents are to be done by counsel for Defendant, before a court reporter and a person duly appointed to administer oaths, at Electronically Filed - STODDARD - December 13, 2023 - 11:30 AM the Stoddard County Justice Center, 403 South Prairie Street, Courtroom B, Bloomfield, MO 63825. Specific dates and times will be designated in the subpoenas and notices filed. 4. Attached to this Application as Exhibits 1 and 2 are the original subpoenas issued pursuant to Arkansas law. WHEREFORE, Defendant, Bayird, Inc. prays for an immediate Order of the Court authorizing the issuance of subpoenas as may be necessary for the depositions noticed up in the pending action. Respectfully submitted, BARBER LAW FIRM PLLC Attorneys for Defendant 425 West Capitol Avenue, Suite 3400 Little Rock, AR 72201 (501) 372-6175 By /s/ Perry Wilson Perry Wilson, MO BIN 72286 pwilson@barberlawfirm.com James D. Robertson, AR BIN 95181 jrobertson@barberlawfirm.com Casey L. Mynatt, AR BIN 2022143 cmynatt@barberlawfirm.com 2