IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS ~ 934 L102 CIVIL DIVISION FANTASTIC FILMS, LLC Er 2 = vs. CASE NO. CV-2011-3606-2 = 4 oe TARGET DEVELOPMENT GROUP, IN TRUMAN PRESS, INC., d/b/a HANNOVER HOUSE, and EMPIRE FILM GROUP, INC. DEFENDANTS MOTION TO COMPEL DISCOVERY ‘Comes now the Plaintiff, FANTASTIC FILMS, LLC, by and through its attomy, Marshall Dale Evans, and pursuant to Rule 37 (a) of the Arkansas Rules of Civil Procedure, moves this Court for an order to compel discovery. The Plaintiff states and alleges as follows: 1. That on December 22", 2016, the Plaintiff took the deposition of Fred Shéfte in which the deponent agreed to produce the following information. 1. The addresses to all of the companies listed on Ex 2. A list of all new releases 3. How much money was produced in the 3 Quarter The Plaintiff further requested the listed information in a letter dated January 4, 2017 ‘addressed to the deponent’s attomey a copy of which is attached to this motion as Exhibit “1”, 3. That this Court should order the Defendant deponent to answer the requested information fully and completely. 4. The Plaintiff sent an email the attorney for the Plaintiff requesting a resplution to the discovery dispute which is attached hereto as Exhibit “2”. 5. That as of the date of the preparation of this motion no additional ipformation or clarification or complete answers to the interrogatories has been forth coming.6. That the Court should award the Defendant its costs and attomeys fees for hdving to file this motion. WHEREFORE, the Plaintiff prays that this Court enter an Order directing thd Defendant Fred Shefte to answer the requested questions and grant sanctions, as the Court deenjs proper as authorized by Rule 37 of the Arkansas Rules of Civil Procedure. Fantastic Films, LLC, Plaintiff, BY: THE EVANS LAW FIRM, P.A. 2333 North Green Acres Rd. P.O. Box 1986 Fayetteville, AR 72701 (479) 521-9998 ABA No/ 78050 CERTIFICATE OF SERVICE 1, Marshall Dale Evans, hereby certify that a true and correct copy of fhe foregoing Motion to Compel Discovery was deposited in the U.S. Mail, postage prepaid, addr¢ssed to: George B. Morton Attorney at Law 217 E. Dickson, Ste 103 Fayetteville, AR_72703 on this 7 “day of February, 2017.THE EVANS LAW FIRM A Professional Ascocationt POST OFFICE BOX 1985, 2333 NORTH GREEN ACRES PAYEVTEVILLE, ARKANSAS 727021986 TELEPHONE (479) 521-9998 TELEFAX (9) 321.995 wor Evane-LawFirmcom (CHARLES N. MILUIAMSt + Formerly Circuit Chancery Judge ‘writer's dirt emai, daledevane-laptinm com January 4, 2017 George B. Morton 217 E. Dickson, Suite 103 Fayetteville, AR 72701 RE: Deposition of D. Fred Shefte Dear Bo: Thope you had a very wonderful holiday. | now need to request the information that Fred Shefte agreed to supply at his deposition. He agreed to produce the following: 1. The addresses to all of the companies listed on Exhibit 6 2. A list of all new releases 3. How much money was produced in the 3 Quarter Please have him produce that information as soon as possible, or let me know when if will be produced. Obviously, we want to close out this account. If you could give me a payment arra would try to get some authority to work out a payment for the balance. If you should have any questions, please contact me. With kindest regards, THE EVANS LAW FIRM, P.A. Marshall Dale Evans, MDE/mw = Fantastic Films EXHIBIT 2 ieir Search Results > Message Detail 5 Entire thread Subject: [RE FFiv Rannover house Print RE: FF v hannover house (Add es Prefered Sendor) ‘Mon, Jan 30, 2017 3:21 pm To: "George Morton" | Folder | From | Subject | Bo, * Lean't wait any longer for some cooperation from Fred. | feel I must take some affirmative action unless Thave something concrete. Please advise, Dale EXHIBIT 2