On November 18, 2022 a
Party Discovery
was filed
involving a dispute between
Ccb Community Bank,
and
Calhoun Liberty Employees Cred,
Clemons, Barbara A,
Clemons, James E Jr,
Clemons, Robin D,
for Circuit Civil 3-C
in the District Court of Jackson County.
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Filing # 164469561 E-Filed 01/10/2023 03:53:40 PM
IN THE CIRCUIT COURT IN AND FOR JACKSON COUNTY, FLORIDA
CCB COMMUNITY BANK, an Alabama banking
corporation,
Plaintiff, Case No. 2022 CA 000202
VS.
JAMES E. CLEMONS, JR. a/k/a EDDIE
CLEMONS, ROBIN D. CLEMONS, and
BARBARA ANN CLEMONS,
Defendants.
PLAINTIFF’S MOTION FOR COMMISSION TO ISSUE
QUT-OF-STATE SUBPOENA FOR
DEPOSITION DUCES TECUM OF RONNIE WATSON
Plaintiff, CCB COMMUNITY BANK (‘Plaintiff’), by and through its undersigned
attorneys and pursuant to Florida Rules of Civil Procedure 1.300 and 1.410, and the Uniform
Foreign Depositions Law, § 92.251, Florida Statutes, moves this Court for the issuance of a
commission directing the Clerk of the Circuit Court of Henry County, State of Alabama, to issue
a subpoena for deposition duces tecum in Henry County, Alabama, based upon the following:
1 On November 18, 2022, Plaintiff filed a Complaint against Defendants, James E.
Clemons, Jr. a/k/a Eddie Clemons (“Eddie Clemons”), Robin D. Clemons and Barbara Ann
Clemons.
2 Defendants have filed an Answer and Demand for Trial denying the majority of the
allegations of the Complaint.
3 Upon information and belief, Ronnie Watson, who resides in Henry County,
Alabama, may have information that may assist in locating collateral cross-collateralized by the
note which is the subject of this action.
Electronically File Jackson Case# 22000202CAAXMX 01/10/2023 02:53:40 PM
4 Plaintiff seeks a Commission of this Court to apply to the Circuit Court in and for
Henry County, Alabama for issuance of a Subpoena for Deposition Duces Tecum for the
deposition of Ronnie Watson to appear before a person authorized by law to take deposition via
Zoom on February 14, 2023 at 2:00 p.m. CT.
WHEREFORE, Plaintiff, CCB COMMUNITY BANK, requests this Court enter an Order
granting this motion and issue a commission directing the Clerk of the Circuit Court of Henry
County, Alabama, to issue a Subpoena Duces Tecum for Deposition of Ronnie Watson and to
grant any and such other relief as this Court deems just and proper.
DATED this 10th day of January 2023.
/s/ Judson C. Brandt
JUDSON C. BRANDT
Florida Bar No. 0040737
CLARK PARTINGTON
125 East Intendencia Street
P. O. Box 13010
Pensacola, Florida 32591-3010
(850)434-9200 - Phone
(850)432-7340 — Fax
jbrandt@clarkpartington.com
Idunlap@clarkpartington.com
vhoyt@clarkpartington.com
Attomey for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing has been furnished to the following service on
this 10th day of January 2023:
Ronald A. Mowrey, Esq.
Mowrey Law Firm
515 North Adams Street
Tallahassee, FL 32301
Attorney for Defendants
VIA SERVICE THROUGH E-PORTAL TO:
rmowrey@mowreylaw.com
legaladmin@mowreylaw.com
/s/ Judson C. Brandt
JUDSON C. BRANDT
Preview
Filing # 164469561 E-Filed 01/10/2023 03:53:40 PM IN THE CIRCUIT COURT IN AND FOR JACKSON COUNTY, FLORIDA CCB COMMUNITY BANK, an Alabama banking corporation, Plaintiff, Case No. 2022 CA 000202 VS. JAMES E. CLEMONS, JR. a/k/a EDDIE CLEMONS, ROBIN D. CLEMONS, and BARBARA ANN CLEMONS, Defendants. PLAINTIFF’S MOTION FOR COMMISSION TO ISSUE QUT-OF-STATE SUBPOENA FOR DEPOSITION DUCES TECUM OF RONNIE WATSON Plaintiff, CCB COMMUNITY BANK (‘Plaintiff’), by and through its undersigned attorneys and pursuant to Florida Rules of Civil Procedure 1.300 and 1.410, and the Uniform Foreign Depositions Law, § 92.251, Florida Statutes, moves this Court for the issuance of a commission directing the Clerk of the Circuit Court of Henry County, State of Alabama, to issue a subpoena for deposition duces tecum in Henry County, Alabama, based upon the following: 1 On November 18, 2022, Plaintiff filed a Complaint against Defendants, James E. Clemons, Jr. a/k/a Eddie Clemons (“Eddie Clemons”), Robin D. Clemons and Barbara Ann Clemons. 2 Defendants have filed an Answer and Demand for Trial denying the majority of the allegations of the Complaint. 3 Upon information and belief, Ronnie Watson, who resides in Henry County, Alabama, may have information that may assist in locating collateral cross-collateralized by the note which is the subject of this action. Electronically File Jackson Case# 22000202CAAXMX 01/10/2023 02:53:40 PM 4 Plaintiff seeks a Commission of this Court to apply to the Circuit Court in and for Henry County, Alabama for issuance of a Subpoena for Deposition Duces Tecum for the deposition of Ronnie Watson to appear before a person authorized by law to take deposition via Zoom on February 14, 2023 at 2:00 p.m. CT. WHEREFORE, Plaintiff, CCB COMMUNITY BANK, requests this Court enter an Order granting this motion and issue a commission directing the Clerk of the Circuit Court of Henry County, Alabama, to issue a Subpoena Duces Tecum for Deposition of Ronnie Watson and to grant any and such other relief as this Court deems just and proper. DATED this 10th day of January 2023. /s/ Judson C. Brandt JUDSON C. BRANDT Florida Bar No. 0040737 CLARK PARTINGTON 125 East Intendencia Street P. O. Box 13010 Pensacola, Florida 32591-3010 (850)434-9200 - Phone (850)432-7340 — Fax jbrandt@clarkpartington.com Idunlap@clarkpartington.com vhoyt@clarkpartington.com Attomey for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing has been furnished to the following service on this 10th day of January 2023: Ronald A. Mowrey, Esq. Mowrey Law Firm 515 North Adams Street Tallahassee, FL 32301 Attorney for Defendants VIA SERVICE THROUGH E-PORTAL TO: rmowrey@mowreylaw.com legaladmin@mowreylaw.com /s/ Judson C. Brandt JUDSON C. BRANDT