Electronically Filed - Cole Circuit - February 14, 2019 - 01:55 PM

IN THE 19TH JUDICIAL CIRCUIT COURT

COLE COUNTY
STATE OF MISSOURI
Elad Gross, )
)
Plaintiff, )
)
v. ) No. 18AC-CC00422
)
Missouri Governor )
Michael Parson, et al. )
)
Defendants. )

UNITED STATES SENATOR JOSHUA HAWLEY’S MOTION

FOR A PROTECTIVE ORDER AND TO QUASH

The judicial process does not exist to harass public servants or further the political

ambitions of litigants. Whenever a party abuses that process to transform the courts into political

weapons, the party does serious injury to both the target of the abuse and the judiciary itself.

Heedless of these fundamental principles, Plaintiff issued a subpoena to United States Senator

Joshua Hawley, who represents the People of Missouri, in a transparent attempt to bolster his

own political prospects and harm the Senator. Regardless of whether Plaintiff’s political

machinations will succeed, his exploitation of the judicial process must not.

Plaintiff’s subpoena—which, while issued by the clerk of this Court, has never been

approved by any judge of this Court—must be quashed for at least three independent reasons.

First, because the subpoena was never properly served, it is invalid and void. Second, even if the

subpoena had been properly served, Plaintiff has offered no basis whatsoever for believing that

the Senator has relevant evidence to provide via a subpoena. To the contrary, the filings in this

case demonstrate that Senator Hawley has nothing to contribute to Plaintiff’s case. Third, it is a

bedrock principle of discovery that depositions of high-ranking public officials are improper

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unless they are truly necessary. That rule exists for good reason: otherwise, public servants

would be subject to continuous and serial harassment via the judicial process. Yet, Plaintiff

cannot possibly demonstrate the necessity of deposing the Senator, and he has not even tried.

This Court cannot and should not establish a rule whereby sitting U.S. Senators are hauled into

the deposition room at the whim of any politically ambitious litigant.

BACKGROUND

In an attempt to uncover information that he hoped would “affect the electability” of

Governor Parson and Senator Hawley, Petition ¶ 90 (Oct. 17, 2018), Plaintiff submitted a

Missouri Sunshine Law request for 54 separate categories of documents, see Pet. Ex. 1. Plaintiff

was told that complying with his sweeping requests would require state employees to review

over 13,000 documents—a monumental task that would take six months—and that Defendants

would not start until Plaintiff paid a $3,618.40 fee. Pet. Ex. 3. Plaintiff then submitted a second,

narrower Sunshine Law request seeking information relevant to the processing of his first

request. Pet. Ex. 7. Defendants responded to the second request by producing emails and other

materials that identify the state employees who handled Defendants’ first request. Pet. Ex. 11,

12. None of the materials produced to Defendant in response to the second request show that

Senator Hawley—who at the time was Missouri’s Attorney General—had any personal

involvement in this matter. Rather than attempting to narrow his first Sunshine Law request in a

manner that would have enabled the Defendants to respond more quickly and at lower cost,

Plaintiff filed this lawsuit.

The Attorney General ordinarily represents the Governor and other state officials when

they are sued in their official capacities, and Senator Hawley previously represented the

Defendants in this case. On February 11, 2019—without first taking any discovery from the

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Defendants or deposing any of the individuals who he knows actually processed his Sunshine

Law requests—Plaintiff obtained a subpoena directed to Senator Hawley. The subpoena instructs

Senator Hawley to sit for a deposition and to produce documents and other materials concerning

“application and/or enforcement of Missouri’s Sunshine law, regarding Elad Gross’s Sunshine

Requests made to the Missouri Governor in 2018.” Subpoena Duces Tecum at 1 (Feb. 11, 2019).

Shortly after obtaining the subpoena, Plaintiff emailed it to a group of reporters with a

note stating that “the Cole County Circuit Court issued a subpoena at my request to Senator Josh

Hawley to answer questions under oath.” Exhibit A. In an accompanying press release, Plaintiff

stated that Senator Hawley “will have to answer questions under oath about his involvement in

violating Missouri’s public records law during his time as Missouri’s Attorney General.” Exhibit

B. Issuance of a subpoena by the Court is a ministerial act that does not require approval by a

judge or any assessment of whether the subpoena is proper. Yet the obvious aim of Plaintiff’s

artfully worded statements to the press was to mislead reporters into thinking that the Court had

in some manner approved of Plaintiff’s decision to commence discovery in this public records

case by attempting to depose the Defendants’ former attorney, who is now a sitting United States

Senator.

On February 13, 2019, Plaintiff’s agent left a copy of the subpoena at Senator Hawley’s

office in Washington, D.C. Senator Hawley was not personally served.

ARGUMENT

“Upon motion by a party or by the person from whom discovery is sought, and for good

cause shown, the court may make any order which justice requires to protect a party or person

from annoyance, embarrassment, oppression, or undue burden or expense, including . . . that the

discovery not be had.” MO. R. CIV. P. 56.01(c). “A protective order should issue if annoyance,

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oppression, and undue burden and expense outweigh the need for discovery.” State ex rel. Ford

Motor Co. v. Messina, 71 S.W.3d 602, 607 (Mo. 2002).

I. The Subpoena Should Be Quashed Because It Was Improperly Served.

The subpoena should be quashed for the threshold reason that it was not properly served

upon Senator Hawley, as required by MO. R. CIV. P. 57.09(d). Rule 57.09 requires that

subpoenas must be served “upon a person named therein . . . by delivering a copy thereof to such

person . . . .” (emphasis added). But Plaintiff did not deliver a copy of the subpoena to Senator

Hawley; instead, his agent merely left it with a member of Senator Hawley’s staff. That does not

comport with the requirements of Rule 57.09.

Unlike the rules governing service of a summons, Rule 57.09 contains no provision for

leaving a copy of a subpoena at the individual’s place of abode or with an appointed agent.

Compare id. with MO. R. CIV. P. 54.13(b)(1). For this reason, the federal courts—whose

interpretations of the similarly worded Federal Rule of Civil Procedure 45(b)(1) “provide some

guidance in determining what methods of ‘delivery’ should be considered proper service,”

Mehrer v. Diagnostic Imaging Ctr., P.C., 157 S.W.3d 315, 321 (Mo. Ct. App. 2005)—have long

held that “personal service of a subpoena is required when an individual is subpoenaed,” and that

leaving the subpoena with the individual’s agent or at his abode “does not fulfill the requirement

for personal service.” Application of Johnson & Johnson, 59 F.R.D. 174, 177 (D. Del. 1973); see

also Scarpa v. Saggese, 16 F.3d 401 (1st Cir. 1994) (table); Ilinca v. Bd. of Coop. Educ. Servs.,

Nassau, 2015 WL 8490979, at *1 (E.D.N.C. Dec. 10, 2015); Gowan v. Mid Century Ins. Co.,

309 F.R.D. 503, 514 (D.S.D. 2015). Indeed, the Western District has on this basis concluded that

neither service by “facsimile transmission nor regular mail” is sufficient, “given that neither

method provided a means by which delivery of the subpoena to the witness could be assured.”

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Mehrer, 157 S.W.3d. at 321. Because the subpoena was not personally served upon Senator

Hawley in compliance with Rule 57.09(d), it is invalid and should be quashed. See id. (circuit

court correctly quashed improperly served subpoena).

II. The Subpoena Should Be Quashed Because Senator Hawley

Has No Relevant, Discoverable Testimony or Documents.

“Rule 56.01 defines what may be obtained under all methods of discovery,” State ex rel.

Day v. Patterson, 773 S.W.2d 224, 227 (Mo. Ct. App. 1989), including by means of deposition

or subpoena, see State ex rel. State Farm Mut. Auto. Ins. Co. v. Keet, 601 S.W.2d 669, 672 (Mo.

Ct. App. 1980). Rule 56.01 requires that the testimony or materials sought be “relevant to the

subject matter involved in the pending action.” MO. R. CIV. P. 56.01(b)(1). “The party seeking

discovery shall bear the burden of establishing relevance.” Id.; State ex rel. Ford Motor Co. v.

Westbrooke, 151 S.W.3d 364, 367 (Mo. 2004) (brackets omitted). Thus, Missouri courts have

repeatedly protected individuals and entities against subpoenas seeking irrelevant information.

See e.g., State ex rel. Pooker ex rel. Pooker v. Kramer, 216 S.W.3d 670, 671–72 (Mo. 2007);

State, ex rel. Horenstein v. Eckelkamp, 228 S.W.3d 56, 57 (Mo. Ct. App. 2007); State ex rel.

Williams v. Lohmar, 162 S.W.3d 131, 134 (Mo. Ct. App. 2005); State ex rel. Wright v.

Campbell, 938 S.W.2d 640, 644 (Mo. Ct. App. 1997).

The subpoena is plainly improper under these precedents and should be quashed. First,

while it is apparent that Plaintiff hopes to obtain via his Sunshine Law requests information

about Senator Hawley, nothing in the Complaint or its exhibits provides any credible basis for

thinking that Senator Hawley was personally involved in the processing of the requests

themselves. Plaintiff simply cannot satisfy his burden to show that Senator Hawley has

information that is relevant to the reasonableness of Defendants’ handling of his Sunshine Law

requests. Under the circumstances, it is apparent that the subpoena is an improper effort to

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leverage litigation over the processing of Plaintiffs’ requests into a mechanism for deposing one

of the State’s highest elected officials and obtaining documents that are not otherwise available

under the Sunshine Law itself. This is a serious abuse of the discovery process, and if approved it

would establish a precedent that invites the filing of frivolous lawsuits under the Sunshine Law

aimed solely at taking discovery from current and former state officials.

Second, even assuming that Senator Hawley has information or knowledge that could be

relevant to Plaintiffs’ claims (a point that Senator Hawley does not concede), he obtained the

information solely by virtue of having previously served as the Defendants’ lawyer. Senator

Hawley’s obligations to his former clients, the attorney-client privilege, and attorney work

product doctrine would thus prevent Senator Hawley from answering any questions Plaintiff

could conceivably ask during a deposition that would have any relevance to the factual issues in

this case. Plaintiff’s attempt to depose the Defendants’ former lawyer strikes at the heart of the

attorney-client privilege, and it is especially improper in light of Plaintiff’s failure to first attempt

to obtain discoverable information from the Defendants themselves or through other sources. See

State ex rel. Missouri Highway & Transp. Comm’n v. Anderson, 735 S.W.2d 350, 356 (Mo.

1987) (quashing subpoena because, inter alia, materials sought via subpoena were “protected

from discovery either because they are ‘privileged’ . . . or because they are protected by . . . Rule

56.01(b)(3)”); Keet, 601 S.W.2d at 672 (quashing subpoena’s attempt to obtain privileged

information).

III. The Subpoena Should Be Quashed Because High-Level Officeholders

Cannot Be Deposed Unless Their Testimony Is Truly Necessary.

It is a well-established principle of discovery that the deposition of a high-level public

official is generally impermissible. See United States v. Morgan, 313 U.S. 409, 421–22 (1941);

In re USA, 624 F.3d 1368, 1376 (11th Cir. 2010) (courts “should rarely, if ever, compel the

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attendance of a high-ranking official in a judicial proceeding”). “[C]ourts have held

that depositions of high-ranking officials are not allowed ‘absent extraordinary circumstances.’ ”

S.L. ex rel. Lenderman v. St. Louis Metro. Police Dep’t Bd. of Comm’rs, 2011 WL 1899211, at

*2 (E.D. Mo. May 19, 2011) (collecting cases). That is why, for instance, Governor Kit Bond

was not required to submit to a deposition where plaintiffs could not show a “specific need” for

information “which could not be obtained” from lower-level officials or employees. Sweeney v.

Bond, 669 F.2d 542, 546 (8th Cir. 1982), abrogated on other grounds by O’Hare Truck Serv.,

Inc. v. City of Northlake, 518 U.S. 712 (1996).

The Missouri Supreme Court recognized these kinds of concerns in Messina, 71 S.W.3d

at 602. In that case, plaintiffs sought to depose high-level executives at Ford Motor Company. Id.

at 605. Ford moved for a protective order, but the circuit court denied it and ordered the

depositions to proceed. Id. at 606. The Missouri Supreme Court unanimously issued a writ of

prohibition blocking the depositions. 1 The Court began by observing that “top-level depositions

may be annoying, burdensome, expensive, and oppressive . . . . Persons lower in the organization

may have the same or better information. Other methods of discovery may make a top-level

deposition unnecessary.” Id. (citations omitted). Thus, “[f]or top-level employee depositions, the

court should consider: whether other methods of discovery have been pursued; the proponent’s

need for discovery by top-level deposition; and the burden, expense, annoyance, and oppression

to the organization and the proposed deponent.” Id. at 607. Applying these factors, the Court

held that, even though the Ford executives had relevant information, their depositions were

impermissible because there were less-burdensome methods that the plaintiffs could have

1
There were four proposed deponents, but the claims of one of the deponents became
moot during the litigation, while Ford effectively conceded that the deposition of another was
proper. Id. at 607. Thus, the Missouri Supreme Court’s writ of prohibition applied to the two
proposed deponents actually at issue. Id. at 609.

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pursued, the plaintiffs had not demonstrated a need for the discovery, and the deposition would

be “annoying, unduly burdensome and expensive, and oppressive” given the Ford executives’

high-level positions. Id. at 607–08.

The same principles apply to high-level government officials, such as United States

Senators. In Wilkins v. Office of the Missouri Attorney General, the plaintiff subpoenaed then-

Attorney General Chris Koster to compel his testimony at trial. 464 S.W.3d 271, 273–74 (Mo.

Ct. App. 2015). The circuit court granted the Attorney General’s motion to quash and for a

protective order, id. at 274, and the Court of Appeals unanimously affirmed, id. at 277. The

Court of Appeals began by holding that Messina’s clear teaching applied equally to high-level

government officials as it did to corporate officers. Id. at 276 & n.6. Applying Messina, the

Court of Appeals concluded that the Attorney General’s testimony “was of limited probative

value” and “Plaintiff was able to present [relevant] evidence by less burdensome and oppressive

means.” Id. at 277; see also id. at 276 (arguing that deposing the Attorney General “would

substantially impede his ability to perform his duties as Attorney General for the State of

Missouri”). The Court of Appeals therefore affirmed the order quashing the subpoena and

issuing a protective order. Id.

These cases require granting the Senator’s motion here. First, Plaintiff has not pursued

other means of obtaining the relevant information in this litigation before seeking to depose the

Senator. Rather, just three days after Plaintiff served his first round of discovery requests,

Plaintiff filed his motion to subpoena Senator Hawley. As in Messina, no one else has been

deposed in this case yet, and this deposition would be among the first discovery in the case. 71

S.W.3d at 608. Under those circumstances, the Missouri Supreme Court held that plaintiffs failed

to satisfy the first prong of the Messina test, and the same is true here. Id.

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Second, Plaintiff has completely failed to show any need for this discovery. Indeed, he

has fallen far short of what the plaintiffs in Messina put forward, which the Missouri Supreme

Court held was insufficient. Id. Rather, as demonstrated above, the Senator has no relevant, non-

privileged evidence to offer. As in Wilkins, the evidence in the record shows that the Senator

“had no involvement in or knowledge of” the issues in the case. 464 S.W.3d at 276.

Third, as with the Attorney General in Wilkins, the deposition of a sitting United States

Senator obviously imposes burdens that “would substantially impede his ability to perform his

duties . . . for the State of Missouri.” Id. “Unnecessarily deposing [a U.S. Senator] is annoying,

unduly burdensome and expensive, and oppressive.” Messina, 71 S.W.3d at 608.

Indeed, we respectfully submit that it would absurd to permit this deposition to go

forward. Plaintiff filed his petition opening this case less than four months ago. During that time,

no substantive testing of his claims has occurred, no documents have been produced, and no

other depositions have been taken. To allow this deposition would be to say that any person in

Missouri can depose a United States Senator just by filing a petition, no matter how vacuous or

politically motivated the petition might be. That cannot be the law anywhere, and as the

foregoing makes clear, that is not the law in Missouri.

CONCLUSION

Senator Hawley respectfully requests that this Court issue an order quashing the

subpoena and enter a protective order preventing further discovery directed toward Senator

Hawley.

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Respectfully submitted,

HUSCH BLACKWELL LLP

By: /s/ Lowell D. Pearson

LOWELL D. PEARSON #46217
R. RYAN HARDING #52155
235 East High Street, Suite 200
Post Office Box 1251
Jefferson City, Missouri 65102
Phone: (573) 635-9118
Fax: (573) 634-7854
Email:lowell.pearson@huschblackwell.com
ryan.harding@huschblackwell.com

David H. Thompson*
Brian W. Barnes*
J. Joel Alicea*
COOPER & KIRK, PLLC.
1523 New Hampshire Ave. NW
Washington D.C., 20036
Telephone: 202-220-9600
Fax: 202-220-9601
Email: dthompson@cooperkirk.com

*Pro hac vice applications forthcoming

Attorneys for Non-Party United States Senator Joshua Hawley

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CERTIFICATE OF SERVICE

I do hereby certify that a true and correct copy of the foregoing document has been

served by means of electronic filing to counsel listed below this 14th day of February, 2019:

Elad Gross
5653 Southwest Avenue
St. Louis, MO 63139

Scott Snipkie
Daryl Hylton
Assistant Attorney General
Supreme Court Building
207 West High Street
P.O. Box 899
Jefferson City, MO 65102

/s/ Lowell Pearson

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EXHIBIT A
 Electronically Filed - Cole Circuit - February 14, 2019 - 01:55 PM
From: Elad Gross <elad@elad4mo.org<mailto:elad@elad4mo.org>>
Date: February 12, 2019 at 7:12:53 AM CST
To: news@kfvs12.com<mailto:news@kfvs12.com>, semissourian <news@semissourian.com<mailto:news@semissourian.com>>,
newsdesk@wsiltv.com<mailto:newsdesk@wsiltv.com>, newstip@wpsdlocal6.com<mailto:newstip@wpsdlocal6.com>,
news@darnews.com<mailto:news@darnews.com>, news@standard-democrat.com<mailto:news@standard-democrat.com>,
editor@columbiatribune.com<mailto:editor@columbiatribune.com>, news@columbiamissourian.com<mailto:news@columbiamissourian.com>,
news@kbia.org<mailto:news@kbia.org>, Jeff Huffman <news@kmiz.com<mailto:news@kmiz.com>>, Stacey Woelfel
<news@komu.com<mailto:news@komu.com>>, KRCG News <news@krcg.com<mailto:news@krcg.com>>,
bwatson@newstribune.com<mailto:bwatson@newstribune.com>, times@vernonpublishing.com<mailto:times@vernonpublishing.com>,
news@cubafreepress.com<mailto:news@cubafreepress.com>, elsberrydemocrat@sbcglobal.net<mailto:elsberrydemocrat@sbcglobal.net>,
JoplinGlobeVideo <news@joplinglobe.com<mailto:news@joplinglobe.com>>, tips@fox14tv.com<mailto:tips@fox14tv.com>,
news@koamtv.com<mailto:news@koamtv.com>, info@zrgmail.com<mailto:info@zrgmail.com>, Clara Reyes
<creyes@dosmundos.com<mailto:creyes@dosmundos.com>>, jhancock@kcstar.com<mailto:jhancock@kcstar.com>,
tporter@kcstar.com<mailto:tporter@kcstar.com>, JoeArce@kchispanicnews.com<mailto:JoeArce@kchispanicnews.com>,
newsdesk@kctv5.com<mailto:newsdesk@kctv5.com>, news@kcur.org<mailto:news@kcur.org>, KMBC News
<news@kmbc.com<mailto:news@kmbc.com>>, 980KMBZ <news@kmbz.com<mailto:news@kmbz.com>>,
desk@kshb.com<mailto:desk@kshb.com>, news@wdaftv4.com<mailto:news@wdaftv4.com>, rdnnews@gmail.com<mailto:rdnnews@gmail.com>,
TSDNews@civitasmedia.com<mailto:TSDNews@civitasmedia.com>, Chris Reeves <tmservo433@gmail.com<mailto:tmservo433@gmail.com>>,
staff@progressnow.org<mailto:staff@progressnow.org>, Celeste Lavin <lavin.celeste@gmail.com<mailto:lavin.celeste@gmail.com>>,
joanne.denyeau@nbcuni.com<mailto:joanne.denyeau@nbcuni.com>, christine.kim@nbcuni.com<mailto:christine.kim@nbcuni.com>,
emily.erotas@nbcuni.com<mailto:emily.erotas@nbcuni.com>, naureen@sambee.com<mailto:naureen@sambee.com>,
alli_maloney@condenast.com<mailto:alli_maloney@condenast.com>, news7@khqa.com<mailto:news7@khqa.com>, Kerry Barrington
<news@ktvo.com<mailto:news@ktvo.com>>, news@kolr10.com<mailto:news@kolr10.com>,
ksmu@missouristate.edu<mailto:ksmu@missouristate.edu>, news@kspr.com<mailto:news@kspr.com>, news@ktts.com<mailto:news@ktts.com>,
news@ky3.com<mailto:news@ky3.com>, Webeditor@news-leader.com<mailto:Webeditor@news-leader.com>,
news@knpn.com<mailto:news@knpn.com>, news@kq2.com<mailto:news@kq2.com>, news@abcstlouis.com<mailto:news@abcstlouis.com>,
desk@kmov.com<mailto:desk@kmov.com>, tips@kmov.com<mailto:tips@kmov.com>, kmoxnews@kmox.com<mailto:kmoxnews@kmox.com>,
newstips@ksdk.com<mailto:newstips@ksdk.com>, news@ktrs.com<mailto:news@ktrs.com>, joe lamie
<ktvinews@tvstl.com<mailto:ktvinews@tvstl.com>>, Tony Messenger <tmessenger@post-dispatch.com<mailto:tmessenger@post-dispatch.com>>,
sarah.fenske@riverfronttimes.com<mailto:sarah.fenske@riverfronttimes.com>, cking@stlamerican.com<mailto:cking@stlamerican.com>,
mgriffin@stlpublicradio.org<mailto:mgriffin@stlpublicradio.org>, Jo Mannies <jomannies@gmail.com<mailto:jomannies@gmail.com>>,
sballentine@ap.org<mailto:sballentine@ap.org>, pressreleases@themissouritimes.com<mailto:pressreleases@themissouritimes.com>,
jsuntrup@post-dispatch.com<mailto:jsuntrup@post-dispatch.com>, dave@moscout.com<mailto:dave@moscout.com>,
lippmannr@umsl.edu<mailto:lippmannr@umsl.edu>, sekgy6@mail.missouri.edu<mailto:sekgy6@mail.missouri.edu>,
barry.mangold@kmiz.com<mailto:barry.mangold@kmiz.com>, Micheal Mahoney <mmahoney@hearst.com<mailto:mmahoney@hearst.com>>,
lucas.geisler@kmiz.com<mailto:lucas.geisler@kmiz.com>, dlieb@ap.org<mailto:dlieb@ap.org>,
rchoma@motherjones.com<mailto:rchoma@motherjones.com>, scoops@huffpost.com<mailto:scoops@huffpost.com>,
steven.ginsberg@washpost.com<mailto:steven.ginsberg@washpost.com>,
lori.montgomery@washpost.com<mailto:lori.montgomery@washpost.com>, hey@crooked.com<mailto:hey@crooked.com>, Jason Rosenbaum
<jrosenbaum9@gmail.com<mailto:jrosenbaum9@gmail.com>>, anne@endcitizensunited.org<mailto:anne@endcitizensunited.org>,
news@chillicothenews.com<mailto:news@chillicothenews.com>, editor@thehill.com<mailto:editor@thehill.com>
Subject: Missouri Senator Josh Hawley Subpoenaed in Sunshine Law Case

Hi,

Last night, the Cole County Circuit Court issued a subpoena at my request to require Senator Josh Hawley to answer questions under oath about his
involvement in violating Missouri's public records law during his time as the state's Attorney General.

The case is also connected to my investigation into dark money's influence on Missouri.

A press release explaining the subpoena and background is attached. I have also attached a redacted copy of the subpoena. I redacted only Senator
Hawley's home address to protect his privacy.

I intend to have Senator Hawley served with the subpoena shortly.

If you have any questions, please feel free to contact me here or at 314-753-9033.

Thank you for your time.

 Electronically Filed - Cole Circuit - February 14, 2019 - 01:55 PM
Sincerely,
Elad

Elad Gross
Candidate for Missouri Attorney General
www.EladGross.org<https://urldefense.proofpoint.com/v2/url?u=http-
3A__www.EladGross.org&d=DwMFaQ&c=UCja3IwhyjPGYeHcG7oIbg&r=gbNupPxjqgsLNuFr00BJExUGAGtjWK9zJY7reKoYp_0&m=BadKttHggW0qfpgd-
M0Q2zohLTkUuDcr9-e9KRDb9BA&s=migwXqMKjeuypZUrzBDhGFys3FC-jT4eyYP_hk24aC4&e=>
314-753-9033
Elad@Elad4MO.org<mailto:Elad@Elad4MO.org>
Electronically Filed - Cole Circuit - February 14, 2019 - 01:55 PM
EXHIBIT B
 Electronically Filed - Cole Circuit - February 14, 2019 - 01:55 PM























 


 



  






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