IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS LEY CIVIL DIVISION A O FOR REconp FANTASTIC FILMS, LLC i Nibeanppee 07 WASH : STOn vs. CASE NO. CV-2011-3606-2 erReuir G2. (in . ENO. CV-2011-3606~ S¥Lves ret TARGET DEVELOPMENT GROUP, INC., TRUMAN PRESS, INC., d/b/a HANNOVER HOUSE, and EMPIRE FILM GROUP, INC. DEFENDANTS MOTION FOR CONTEMPT Comes now the Plaintiff, FANTASTIC FILMS, LLC, by and through its attomey, Marshall Dale Evans, and pursuant to Rule 37 of the Arkansas Rules of Civil Procedure, moves this Court for an order for contempt. The Plaintiff states and alleges as follows: 1. That on December 22", 2016, the Plaintiff took the deposition of Fred Shefte in which the deponent agreed to produce the following information. 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 2. 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 the motion to compel filed herein. 3. That this Court ordered the Defendant deponent to answer the requested information fully and completely by its order dated March 2“, 2017. 4. That the order allowed the Defendant deponent 5 days to comply. A copy of the court’s order was emailed to the attorney for the Defendant deponent evidence by the Exhibit “1” attached hereto.5. That as of the date of the preparation of this motion no additional information or clarification or complete answers to the questions has been forth coming in direct defiance of the court’s order, Another email was sent to the attomey for the deponent on March 14 giving a final ‘amount of time for compliance or a motion for contempt would be filed as evidence by Exhibit “2”, 6. That the Court should Order the Defendant deponent to appear and show cause why he should not be held in contempt of this court’s order and the court should award the Plaintiff its costs and attomeys fees for having to file this motion. WHEREFORE, the Plaintiff prays that this Court enter an Order directing the Defendant deponent, Fred Shefte, to appear and show cause why he should not be held in contempt of this courts March 2 Order to answer the requested questions, Fantastic Films, LLC, Plaintiff, BY: THE EVANS LAWFIRM, P.A. 2333 North Green Acres Rd. P.O. Box 1986 Fayetteville, AR 72701 (479) 521-9998 Their Attomeys Mar yale Evans, P.A. ABA No|78050CERTIFICATE OF SERVICE I, Marshall Dale Evans, hereby certify that a true and correct copy of the foregoing Motion for Contempt was deposited in the U.S. Mail, postage prepaid, addressed to: George B. Morton Attorney at Law 217 E. Dickson, Ste 103 Fayetteville, AR. 72703 on this 2s of March, 2017. ‘MARSHAI LE EVANS.search Results >Message Detail FE f | Subject From: sstniactase Date: Thu, Mar 09, 2017 2:37 pm jomorton@amal.com | Folder Bo, Attached is the court order. The time has already past for compliance, but as I told you on the phone 1am willing to give Fred some additional time but I must insist on compliance. Thanks, Dale Marshall Dale Evans THE EVANS LAW FIRM, P.A. 2333 N. Green Acres Rd. P.O. Box 1986 Fayetteville, AR 72702-1986 (479) 521-9998 phone (479) 521-9995 facsimile Please be advised that this email and any files with it are covered by the Electronic communications Privacy Act, 18 U.S.C. client communication or may otherwise be privileged or confidential and are intended solely forthe individual or entity to w use of the individual or entity named above, if you are not the intended recipient, or the employee or agent responsible to del distribution or copying of this communication is strictly prohibited. Please do not read, copy or retransmit this communicatc please immediately notify us by telephone at (479) 521-9998, Any unauthorized dissemination, distribution or copying of th ‘Thank You Download EXHIBIT 4‘sear Results > Message Detail | Subject: [RE Graerto Gonpel x lorserts | [Compel From: winssezass Date: Tue, Mar 14, 2017 4:05 pm To: bomorton@amai.com | Foie Bo, ‘Do you know when Fred will comply with the court order? I emailed the order to you on March 9. It has been 5 days tomorrow. If I don't have the information by Friday, I will seek to hold Fred in contempt. Please advise as soon as possible. On another note, I have not received the information that Hannover house has paid the debt in full. You were going to send me something. I really don't believe it could be paid even if you have proof of a missed payment. No one has requested the additional costs that have occurred after the judgment ‘was entered. As you are aware, all post judgment costs are incorporated into the judgment. There has been ‘many writs issued at the tune of $20 each. There are over 40 issued. That is at least $800.00 more dollars and of course interest on it all. But I do want to be sure they have been given credit for all payments. Please send ‘me whatever you have to verify payments. Thanks, Dale Original Message Subject: Order to Compe! From: Date: Thu, March 09, 2017 2:37 pm To: bomorton@qmail.com Bo, Attached is the court order. The time has already past for compliance, but as I told you on the phone I am willing to give Fred some additional time but I must insist on compliance. Thanks, Dale Marshall Dale Evans THE EVANS LAW FIRM, P.A. 2333 N. Green Acres Rd. P.O. Box 1986 Fayetteville, AR 72702-1986 (479) 521-9998 phone (479) 521-9995 facsimile Please be advised that this email and any files with it are covered by the Electronic communications Privacy Act, 18 U.S.C. §§2510- 2521 and are legal privileged. They may also contain confidential attorney-client communication or may otherwise be privileged or confidential and are intended solely forthe individual or entity to whom they are addressed. The inforriation contained in this Email is intended only for use ofthe individual or entity named above, if you are not the intended recipient, or the employee or agent responsible to deliver itt the intended recipient, you are hereby notified that any dissemination, distribution or copying of this ‘communication is stritly prohibited. Please do not read, copy or retransmit this communication, but destroy it immediately. If you have received this communication in error, please immediately notify us by telephone at (479) 521-9998, Any unauthorized EXHIBIT 2