Filing # 35797974 E-Filed 12/21/2015 06:43:17 PM
IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT
IN AND FOR DIXIE COUNTY, FLORIDA
STATE OF FLORIDA, Case No.: 2014-201-CF
v
TERRY G. TRUSSELL,
Defendant.
SUBPOENA FOR DEPOSITION DUCES TECUM,
To: Judge Cynthia Munkittrick
11295 NW 129" Place
Chiefland, FL 32626-4539
YOU ARE HEREBY COMMANDED to appear before a person authorized by law to take
depositions at the Dixie County Courthouse, Jury Room, Courtroom A, 214 NE 351
Highway, Cross City, FL 32628 on Tuesday, December 29, 2015, at 4:00 PM. and
continuing from day to day until completed for the taking of your deposition in this cause.
Bring the following records with you:
1, Certified copy of Judge Greg Parker's 'Order' cross-swearing Judge Cynthia
Munkittriek as Cire:
judge;
Cettified copy of ‘Order’ by Judge Greg Parker to replace Judge Cynthia
Munkittrick over Grand Jury;
3. Certified copies of all written communications between Judge Cynthia
Munkittrick (and her office), and anyone re: TL-11-0119 or the above referenced
case;
4. Cert
copies of any orders, any court records or public records, in any
courthouse in the Third Circuit, or any other Circuit in Florida entered by you or
Electronically Filed Dixie Case # 14000201 CF AS#AK 2/31/2015 06:43:17 PM6.
Chief Judge Parker conceming Terry G. Trussell and the Grand Jury of which he
was the Foreman;
Certified Copies of official travel records for Judge Cynthia Munkittrick on
August 1, 2014, and any written records in support of his activities on that date;
Certified copy of Judge Cynthia Munkittrick’s official court calendar for
October 9, 2014;
Certified copies of all court records and documents related to first appearance
hearing presided over by Judge Cynthia Munkittrick, in the Dixie County Jail,
the evening of October 9, 2014, including all defendants heard, including, Terry
G. Trussell.
All emails, text messages, cell phone call logs, correspondence; or other
documents which discuss Terry Trussell in any way, including business and
personal emails and cell phones,
If you fail to appear at the above place and time you may be held in contempt of court.
‘You are subpoenaed to appear by the following attomey, and unless excused from this
subpoena by this attorney, you shall respond to this subpoena as directed.
Dated this 20th day of December, 2015
Inger M. Garcia, Esq
Garcia Legal Group, P.A.
Attorneys for Defendant
4839 Volunteer Road - #514
Fort Lauderdale. Florida 33330
Tel - (954)894-9962 - Fax: (954) 446-1635,
Service E-Mail: attorney @ingergarcia.com
By: /s/ Inger M. Garcia
Inger M. Garcia, Esq. * FBN: 0106917
Page 2 of 5IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT
IN AND FOR DIXIE COUNTY, FLORIDA
STATE OF FLORIDA, Case No.: 2014-201 CF
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I
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TERRY G. TRUSSELL, I
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Defendant. I
NOTICE FOR DEPOSITION DUCES TECUM,
TO: — State Attorney William N. Megs
Leon County Courthouse
301 S. Monroe Street
Tallahassee, Florida 32399
E-mail: s402_leon@leoncountyfl. gov
PLEASE TAKE NOTICE that counsel for the Defendant, TERRY G. TRUSSELL, will take
the deposition oft
NAME OF DEPONENT: Judge Cynthia Munkittrick — 11295 NW 129" Place,
Chiefland, FL 32626-4539
DATE AND TIME: Thursday, December 21, 2015, commencing at 4:00 PM
and continuing from day to day until complete.
LOCATION Dixie County Courthouse
Jury Room, Courtroom A
214 NE 351 Highway
Cross City, FL 32628
DOCUMENTS: Your entire case file in relation to Terry Trussell in the
above-styled case and specifically those documents
described herein, below:
Page 3 of 5Centfied copy of Judge Greg Parker's
Munkittrick as Circuit Judge;
Contified copy of Order’ by Judge Greg Parker to replace Judge Cynthia
Munkittrick over Grand Jury;
Centified copies of all written communications between Judge Cynthia
Munkittrick (and her office), and anyone re: TL-11-0119 or the above referenced
case;
Certified copies of any orders, any court records or public records, in any
courthouse in the Third Circuit, ot any other Circuit in Florida entered by you or
Chief Judge Parker conceming Terry G. Trussell and the Grand Jury of which he
‘was the Foreman;
Certified Copies of official travel records for Judge Cynthia Munkittrick on
August 1, 2014, and any written records in support of his activities on that date;
Certified copy of Judge Cynthia Munkittrick’s official court calendar for
October 9, 2014;
Certified copies of all court records and documents related to first appearance
hearing presided over by Judge Cynthia Munkitirick, in the Dixie County Jail,
the evening of October 9, 2014, including all defendants heard, including, Terry
G, Trussell
All emails, text messages, cell phone call logs, correspondence; or other
documents which discuss Terry Trussell in any way, including business and
personal emails and cell phone:
Page 4 of 5pursuant to the Florida Rules of Criminal Procedure before a court reporter authorized by law to
take depositions: "For the Record Court Reporters" Kav @TallahasseeCourtReporting.com.
((850)-222-5491) for the taking of his deposition in this action for the purpose of discovery and
use at trial, and all other lawful purposes.
DATED this 20th day of December, 2015
Respectfully submitted,
Inger M. Garcia, Esq
Garcia Legal Group, P.A.
Attorneys for Defendant
4839 Volunicer Road - #514
Fort Lauderdale, Florida 33330
Tel - (954)894-9962 - Fax: (954) 446-1635
Service E-Mail: allomey@ingergarcia.com
By: /s/ Inger M. Gareia
Inger M. Garcia, Esq. * FBN: 0106917
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via electronic mail on December 21, 2015 to: William N. Meggs, Esq., Attorney for the State,
Leon County Courthouse, 301 S. Monroe Street, Tallahassee, Florida 32399 (850) 606-6000
(email: sa02 1eon@leoncountvil.gov) ; For the Record Court Reporter, (850) 222-5491;
Kav@TahahasseeCourtReporting.com, Court Administration: (850) 606-4401;
dykeK @leoncou
nv. gov.
sy Inger M. Garcia
Inger M. Garcia, Esq.
Page 5 of 5