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THE STATE OF TEXAS
SUBPOENA (DUCES TECUM)
CAUSE NO. 2017-48075
TOTAL PETROCHEMICALS & § INTHE DISTRICT COURT
REFINING USA, INC., and
ACE PROPERTY & CASUALTY
INSURANCE COMPANY, HARRIS COUNTY
ve
164" DISTRICT COURT
KINDER MORGAN PETCOKE, LP
AND KINDER MORGAN
PETCOKE GP LLC
LR LN LP LP LP Lf Si LP LP
TO ANY SHERIFF, CONSTABLE, OR ANY OTHER PERSON WHO IS NOT A PARTY AND IS.
EIGHTEEN YEARS OF AGE OR OLDER, OR THE STATE OF TEXAS, AUTHORIZED TO SERVE
AND EXECUTE SUBPOENAS AS PROVIDED IN TEXAS RULE OF CIVIL PROCEDURE 176:
YOU ARE HEREBY COMMANDED TO SUMMON Non-Party TGS Development. LP by and through
its registered agent, Craig Cavalier, 4265 San Felipe Street, Suite 1100, Houston, Texas 77027, on or
before October 15 , 2017 at 9:00 A.M., to produce and permit inspection and copying of documents or
tangible things to be used as evidence in this case.
TGS Development, LP’s Custodian of Records is commanded to produce and permit inspection
and copying of the documents as seen on Exhibit “A”.
This subpoena is issued at the insistence of a Plaintiff in the above-reterenced case, by and
through their attorneys of record, Jack G. Carnegie and Strasburger & Price. LLC.
FAILURE OF 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. TEX. R. CIV. P. 176.8(a)
ATTORNEY OR PERSON REQUESTING ISSUANCE:
Respectfully submitted,
F I /s/ Sack G. Carnegie
ch L E D Jack G. Carnegie
ris it a
District ariel State Bar No. 03826100
Kelly H. Leonard
State Bar No. 24078703
Stephanie C. Gaston
State Bar No. 24065280
3074122. 1/SPH/17604/0133/002217 RECORDER'S MEMORY
is instrument is of poor quality
™ at the time of imaging.DATE OF ISSUANCE: September __, 2017
3074122. 1/SPH!17604/0133/092217
Strasburger & Price, LLP
2 Houston Center
909 Fannin Street, Suite 2300
Houston, TX 77010
713.951.5600 tel
713.951.5660 fax
ATTORNEYS FOR PLAINTIFF
TOTAL PETROCHEMICALS & REFINING USA,
INC.PROOF OF SERVICE
| accept service of the attached subpoena and will appear at the time and place directed in the
subpoena.
Date:
(Signature of Witness)
OFFICER’S RETURN
delivered a copy of thg fos) witness subpoena to
> 1
Nm f fever fe, - TGS Nevalpa person, at Zy 25°. le 3., pees County, Texas
on Qbser $., 2017, a Z! gop o'clock, Pm, and tendered to the witness a fee of
$_f7.g0_.
I was unable to deliver a copy of this witness subpoena to
_ for the following reasons:
Eye. siJea
BY: LE StH F2s
Person who is not a party and is 18 years of age or older.
3074122. /SPH!17604/0133/092017AFFIDAVIT OF AUTHORITY
I, Trent Bavaro, Director of Operations & Corporate Counsel of Corporate
Creations Network Inc. and United oh CREPES authorize Regus, and
all of its staff, including but not limited t&Donald Gainess |d Joshua Provenzano, to
accept and mail all documents, including any and all court documents served or
delivered by the court, private server, sheriff, courier, or otherwise on behalf of me
and my companies. This authorization includes signing on behalf of myself,
Corporate Creations Network Inc., or United Agent Group Inc. to accept all mail and
documents, including court documents served or delivered by the court, private
server, sheriff, courier, or otherwise to 2425 W Loop South #200, Houston TX
77027.
HEREBY SEEN AND AGREED:
OF Faz = Ne
Trent Bavaro DATE
Director of Operations & Corporate Counsel
Corporate Creations Network Inc.
United Agent Group Inc.
STATE OF FLORIDA
COUNTY OF PALM BEACH
The foregoing instrument was acknowledged before me this 29th day of September,
2017 by the above named signatory, who is personally known to me or who
produced a drivers license or passport as identification and who did take an oath.
FILED
Chris Dani
District aie
Stamp of Notary Public
Die