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First MOTION for Protective Order To Terminate Rule 30(b)(6) Deposition by SYNOVUS BANK — Agent Fee Litigation (Dkt. 52)

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                   IN THE UNITED STATES DISTRICT COURT
                  FOR THE NORTHERN DISTRICT OF FLORIDA
                           PENSACOLA DIVISION
 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x
                                                                :
 SPORT & WHEAT CPA PA, a Florida                                :
 corporation, individually and on behalf of                     :
 a class of similarly situated businesses and                   :   Case No. 3:20-cv-05425-
 individuals,                                                   :   TKW-HTC
                                                                :
                                                                :
                        Plaintiff,                              :
                                                                :
                                                                :
              v.                                                :
                                                                :
 SERVISFIRST BANK INC.; SYNOVUS                                 :
 BANK; THE FIRST, A NATIONAL                                    :
 BANKING ASSOCIATION; and                                       :
 TRUIST BANK,                                                   :
                        Defendants.                             :

 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -x


            MOTION TO TERMINATE RULE 30(b)(6) DEPOSITION

                                          INTRODUCTION

        Plaintiff Sport & Wheat (“S&W”) rushed to file suit against Synovus over a

claim of $1,633, despite neither Plaintiff nor its counsel having made any demand

for payment of that claim upon Synovus. Then Plaintiff’s counsel insisted on an

immediate Rule 30(b)(6) deposition, despite the fact that responses to Plaintiff’s

interrogatories and requests for documents were not due, which responses and

documents are ordinarily the subject matter of a Rule 30(b)(6) interrogation.
Counsel for Synovus accommodated the insistence by Plaintiff’s counsel for a

30(b)(6) deposition, and presented a witness for interrogation just three weeks after

Plaintiff’s Amended Complaint was filed.

      Before the deposition, Plaintiff’s counsel agreed to identify the Synovus

borrower for whom S&W claimed to have acted as “agent,” so that Synovus could

research its dealings with that borrower to prepare the 30(b)(6) witness for the

deposition upon which Plaintiff’s counsel insisted. But then Plaintiff’s counsel

refused to identify the borrower.

      Before the deposition, Synovus counsel asked Plaintiff’s counsel to provide

any communications S&W had had with Synovus, including “texts between Sport

& Wheat, or someone at Sport & Wheat, and someone at Synovus” – again to

prepare the 30(b)(6) witness. See 6/15/20 Email of P. Bates to B. Cash, attached

hereto as Ex. 2. Plaintiff’s counsel ignored those requests, and provided no such

documents.

      When the deposition took place, Plaintiff’s counsel sought to interrogate the

30(b)(6) witness about texts that had been exchanged between one of S&W’s

principals and a Synovus employee in Florida. The two were apparently good

friends, and embodied in the texts about multifarious personal matters were some

references to the federal Paycheck Protection Program (“PPP”), the lending

program that is at issue in this case. Ordinarily for a 30(b)(6) deposition the parties

                                          2
know what documents are going to be discussed; that is essential to prepare a

30(b)(6) witness to speak for a corporation. But Plaintiff’s counsel did not provide

any documents to Synovus counsel in advance; instead he ignored the request by

Synovus counsel for any communications S&W claimed to have had with

Synovus.

      The witness could not have known anything about the texts or learned

anything about them in preparing for the 30(b)(6) deposition, both because

Plaintiff’s counsel refused to provide them and because it is contrary to bank

policy for employees to discuss bank business via text message.1

      Ordinarily at any deposition before a lawyer interrogates a witness about a

document, the lawyer gives both the witness and opposing counsel a copy of the

document. That is basic professional and common courtesy, a rule universally

followed in the collective experience of Synovus counsel – until this deposition in

this case. Plaintiff’s counsel had insisted on taking the deposition by Zoom rather


1
  6/18/20 Synovus 30(b)(6) Deposition Rough Transcript at 65:15-23. Also,
Synovus does not issue company cellphones to its employees; cellphones are the
personal property of Synovus’ employees. Id. at 65:1-5. Additionally, as a
practical and technological matter, Synovus would have no way of searching the
text messages of all of its nearly 5,000 employees even if it had the legal authority
to do so.

Relevant excerpts from the “rough” deposition transcript from the Court Reporter
are Exhibit 1 to this Motion. Because a Protective Order has not yet been entered
in this case, Synovus is not filing the entire transcript on the docket.

                                          3
than in person,2 so he was not present to hand out copies of documents, and he

refused to show the entirety of a document to the witness and Synovus counsel

before interrogating the witness about parts of the document.3

      Then, after some three hours of deposition, Plaintiff’s counsel sought to

interrogate the witness about a text which he, the lawyer, had redacted – from

which he had removed content. See, e.g., 6/18/20 Synovus 30(b)(6) Deposition

Rough Transcript at 132:10-12 (Plaintiff’s counsel admitted that he had “grayed

out the areas [of the text messages] that I’m just not interested in asking about,”

not because he was asserting some alleged privilege).4

      Plaintiff’s counsel even refused to provide the witness and Synovus counsel

the complete, unredacted, document about which Plaintiff’s counsel sought to

interrogate the 30b6 witness.5 That was way beyond the pale. See Fed. R. Civ. P.


2
  Synovus counsel Philip Bates and Ramsey Prather were present in person, with
the witness and the Court Reporter.
3
  See, e.g., 6/18/20 Synovus 30(b)(6) Deposition Rough Transcript at 42:3-11
(“[Synovus counsel]: Mr. Cash, why don’t you go ahead and email [the
documents] to us and I can print out copies and we’ll have copies available here in
the room with the witness? [Plaintiff’s counsel]: Well, I'm not going to do that
because I don’t know which exhibits I do and don't need to use, and I don't want to
tip my hand on what the exhibits are before the time comes.”).
4
  Plaintiff’s counsel has not contended that the redactions were made on the basis
of any privilege, nor could he given that the redacted text messages are between an
S&W principal and a third party.
5
  See, e.g., 6/18/20 Synovus 30(b)(6) Deposition Rough Transcript at 132:7-133:8
(“[Synovus counsel]: Again, I object to your producing part of a document to ask a
witness questions where the witness doesn’t have the opportunity to examine the
context in which the comments are made. [Plaintiff’s counsel]: No. I disagree.”)
                                           4
30(c); Fed. R. Evid. 106. Synovus counsel had allowed the 30(b)(6) deposition to

go forward, despite Plaintiff’s counsel having obstructed preparation of the

witness, despite Plaintiff’s counsel having failed to provide information he had

promised to provide that was needed to fully prepare the witness, and had even

allowed Plaintiff’s counsel to continue his interrogation despite refusing to provide

copies of documents to the witness or Synovus counsel. Synovus counsel did that

because they believed Plaintiff’s counsel was merely trying to gin up a dispute so

he could claim Synovus was being uncooperative. But attempting to interrogate a

30(b)(6) corporate representative witness about partial, redacted documents was

too much: that was unfair to the witness, unfair to Synovus, and made a complete

direct examination of the witness impossible. It was also a breach of all

professional courtesies.

      As a result of the misconduct by Plaintiff’s counsel, counsel for Synovus had

no choice but to terminate the deposition pending an Order of the Court. Because

Plaintiff’s tactics were unfair, unlawful, and reflect bad faith, Synovus respectfully

asks that the Court enter an Order that the deposition is terminated.

                                 BACKGROUND

      A. Plaintiff’s Meritless Amended Complaint

      This lawsuit over a $1,633 claim (see Am. Compl. ¶ 112, ECF 21) never

communicated to Synovus before Plaintiff’s counsel rushed to file suit has already

                                          5
cost Synovus enormously – in lost time for Synovus employees who should be

attending to customers, trouble, and legal expenses. The claim has no merit. See

See Synovus’ Motion to Dismiss the Amended Complaint, ECF 46. The reason for

the conduct of Plaintiff’s counsel seems clear. Last week they filed a brief with the

Judicial Panel on Multidistrict Litigation (“JPML”) seeking to join this lawsuit

with other similar lawsuits filed around the country in an MDL. Plaintiff’s counsel

obviously rushed to be the ‘first to file’ and ‘first’ to take a “30(b)(6) deposition”

so they could seek a seat on an MDL committee, in the unlikely event an MDL is

created. In an obvious attempt to make this lawsuit as expensive for Synovus as

possible and in order to try to extract a settlement, Plaintiff’s counsel told the

JPML that they wanted the case heard not by this Court, before whom they had

filed the lawsuit, but by the Western District of Washington. That is 2,200 air

miles and 2,700 road miles from Pensacola. Plaintiff’s excuse stated to the MDL

was that this Court “continues to suffer from courthouse construction problems in

Pensacola.”

      As explained in Synovus’s Motion to Dismiss the Amended Complaint, this

case involves the Paycheck Protection Program (“PPP”), created as part of the

Coronavirus Aid, Relief, and Economic Security Act, Pub. L. 116-136 (the

“CARES Act” or “the Act”). The CARES Act is part of the Federal government’s

response to the economic hardship caused by the COVID-19 pandemic. To

                                           6
provide emergency assistance to small businesses affected by the pandemic, the

PPP significantly expanded the Small Business Administration’s (“SBA”) 7(a)

loan program for small businesses and provided a mechanism by which borrowers

could receive funds to cover payroll and other expenses and, in certain

circumstances, have their loans forgiven by the government. PPP loans are

processed and disbursed through private lenders such as Synovus, and those

lenders receive a statutory processing fee from the government for each approved

loan.

        Plaintiff S&W is an accounting firm. S&W claims it assisted a client with

an application to Synovus for a PPP loan. S&W does not allege that Synovus

authorized any such work; in fact S&W admits Synovus did not authorize such

work and stated that it would not pay agent fees. Instead, S&W alleges that the

CARES Act and SBA regulations thereunder create an absolute entitlement to fees

for any agent who claims to have assisted a PPP borrower in preparing an

application. S&W insists that lenders must pay those fees even where, as here, the

lender in no way authorized the agent’s activities. As explained in Synovus’s

motion to dismiss the amended complaint, the CARES Act created no such

entitlement and does not even provide a private right of action. For these and other

reasons under Florida law, all of Plaintiff’s claims are meritless.



                                           7
      On May 17, 2020, Synovus promptly moved to dismiss Plaintiff’s initial

complaint. Ten days later, on May 27, 2020, Plaintiff rendered its initial complaint

a nullity by filing an amended complaint which, among other things, added two

defendants and attempted to remedy multiple blatant pleading deficiencies.

Synovus promptly moved to dismiss Plaintiff’s amended complaint, which is based

on the same flawed legal theory as Plaintiff’s initial complaint. Because of this

Court’s order requiring that discovery go forward despite the pending motion to

dismiss, ECF No. 16, the parties proceeded with discovery.

      B. The Rule 30(b)(6) Deposition

      Plaintiff’s gamesmanship with respect to the Rule 30(b)(6) deposition of

Synovus began late on Friday afternoon, May 29 when, just two days after filing

the amended complaint, Plaintiff’s counsel emailed a Rule 30(b)(6) deposition

notice stating Plaintiff’s intention to depose Synovus on Friday, June 5—a mere

five business days later. The 30(b)(6) deposition notice included 15 topics.6

Plaintiff’s counsel did not call or email Synovus’s counsel in advance of serving

the Rule 30(b)(6) deposition notice to determine whether Synovus was available to



6
  The 30(b)(6) deposition notice served by Plaintiff’s counsel contained “topics”
which were overbroad and irrelevant to this lawsuit over a claim of $1,633 in
which no class has been certified. For example, Plaintiff’s counsel wanted to
interrogate Synovus’ corporate representative about all PPP loans – not just the
one application submitted by the unidentified borrower for whom S&W claimed to
have been an “agent.” Synovus has processed some 20,000 PPP applications.
                                         8
sit for a corporate deposition on that date. Plaintiff’s counsel even admitted that he

was “spring[ing]” the Rule 30(b)(6) notice on Synovus. See 5/29/20 Email from B.

Cash, attached here to as Ex. 3.

      In an effort to avoid burdening the Court with a Motion for Protective Order

with respect to the Rule 30(b)(6) deposition, counsel for Synovus emailed

Plaintiff’s counsel on Sunday, May 31, 2020, stating that although it “is

exceedingly odd for a plaintiff’s lawyer to send a 30(b)(6) notice before he has

seen any documents other than [the defendant’s] motion to dismiss,” Synovus was

willing to meet and confer to try to reach a resolution regarding the Rule 30(b)(6)

deposition. The parties met and conferred on June 1, 2020. During that call,

counsel for Synovus again noted the oddity of proceeding with a 30(b)(6)

deposition prior to the onset of document discovery. Yet Plaintiff’s counsel

insisted on proceeding with the deposition. Later that week, Synovus offered

Tuesday, June 16, 2020 as an available date for the deposition, subject to

Synovus’s objections to the Rule 30(b)(6) notice. Plaintiff’s counsel agreed that

the deposition would take place two days later on June 18, 2020.

      Synovus agreed to proceed with the Rule 30(b)(6) deposition at this early

juncture in the case based largely on Plaintiff’s representation that it would

voluntarily make information available to Synovus that Synovus would need to

prepare for the deposition. For example, on May 29, 2020—the same day that

                                          9
Plaintiff served the Rule 30(b)(6) notice—Plaintiff’s counsel promised that “on

request, Plaintiff will supply the Bank with sufficient information to identify all

[PPP] Borrowers” for which S&W contends it served as a PPP agent. See 5/29/20

Pltf.’s Consolidated Discovery Requests to Defendant Synovus Bank at n. 1,

attached hereto as Ex. 4. On June 2, 2020, Synovus counsel sent Plaintiff’s

counsel an email requesting “the names and other identifying information for the

persons firms, or corporations for whom your client contends it acted as an agent . .

. as contemplated by footnote #1” to Plaintiff’s Requests for Production so that

Synovus counsel could identify the borrower for which S&W contended in its

Amended Complaint it had served as an “agent” and further investigate. See

6/2/20 Email from P. Bates to B. Cash, attached hereto as Ex. 5. On June 15,

2020, counsel for Synovus sent Plaintiff’s counsel an additional email specifically

requesting that Plaintiff’s counsel provide any “texts between Sport & Wheat, or

someone at Sport & Wheat, and someone at Synovus” before the deposition. See

6/15/20 Email of P. Bates to B. Cash, attached hereto as Ex. 2.

      Plaintiff’s counsel did not respond to any of those requests. Plaintiff’s

counsel did not do what he had promised to do. The result was that Synovus had

no way to identify the borrower for which S&W contended in its Amended

Complaint it had served as an “agent.” Synovus also had no way to search for

email messages specific to that borrower or to consult with Synovus employees

                                          10
who may have worked on the loan application for that borrower, which might have

possibly allowed Synovus to try to find out whether text messages between

Synovus employees and S&W existed. The purpose of Plaintiff’s counsel seems

clear: he broke his promise and ignored requests which were obviously intended to

get the 30(b)(6) witness prepared because he did not want the witness to know

about and be prepared to testify about the text messages Plaintiff’s counsel

intended to “spring” on the witness and Synovus. Plaintiff’s counsel was intent on

sandbagging, so that he could then complain that Synovus’ 30(b)(6) witness was

not prepared.

      During the deposition Synovus counsel still attempted to resolve the issues

caused by Plaintiff’s counsel’s conduct without seeking Court intervention.

During the deposition, counsel for Synovus requested the basic professional and

common courtesy of being provided with copies of documents about which

Plaintiff’s counsel sought to interrogate the witness. Plaintiff’s counsel refused.

Counsel for Synovus also objected to the use by plaintiff’s counsel of heavily

redacted text messages and requested copies of the unredacted documents as

required by law. Plaintiff’s counsel refused. See, e.g., 6/18/20 Synovus 30(b)(6)

Deposition Rough Transcript at 132:7-133:8; see also Fed. R. Civ. P. 30(c); Fed.

R. Evid. 106. Synovus had an absolute right to be provided with unredacted copies

of the text messages. Plaintiff’s counsel was trying to attribute statements therein

                                         11
by a bank employee in Pace, Florida to the corporation. The refusal by Plaintiff’s

counsel to provide unredacted copies was unfathomable bad faith. These facts,

coupled with Plaintiff’s failure to identify the borrowers as Plaintiff previously

represented it would, gave Synovus no choice but to terminate the deposition

pending an Order of the Court.

       It is hard to imagine worse conduct; indeed, none of Synovus counsel have

ever experienced anything like it. Plaintiff’s counsel promised to provide the name

of the Synovus borrower, then refused; insisted on taking the deposition by Zoom

so he would not be present with Synovus counsel and would not have to show

them or the witness complete documents before interrogating the witness about

them; refused to show Synovus counsel and the witness the complete documents;

and then, by his own overt admission, sought to interrogate the witness about a

document he had himself redacted so it was not complete. Asked later that day to

provide all the documents he had used so Synovus counsel could finally see them,

he compounded the misconduct by sending redacted versions the next day.7

      Now, Plaintiffs’ counsel complains of the consequences of his own conduct:

he has accused Synovus and its counsel of not having the witness properly

prepared – after being told taking a 30(b)(6) deposition before any document



7
  The day after the deposition, plaintiffs’ counsel recanted and said he would send
the unredacted documents. Those have not been sent.
                                           12
exchange had occurred seemed foolish, and after reneging on his promise to

provide the name of the Synovus borrower for which S&W claimed to be an agent,

knowing full well not doing so would mean Synovus could not research that claim

and fully prepare the 30(b)(6) witness to discuss it. See 6/19/20 & 6/20/20 Emails

between J. Butler and B. Cash attached hereto as Ex. 6.)

                       ARGUMENT AND AUTHORITY

      A. Federal Rule of Civil Procedure 30(d)(3)(A).

      This Court has authority to terminate the Rule 30(b)(6) deposition of

Synovus. Rule 30(d)(3)(A) provides that “[a]t any time during a deposition, the

deponent or a party may move to terminate or limit it on the grounds that it is being

conducted in bad faith or in a manner that unreasonably annoys, embarrasses, or

oppresses the deponent or party.” Fed. R. Civ. P. 30(d)(3)(A). “The Rule

expressly allows counsel to terminate the deposition pending the Order of the

Court.” Buckley Towers Condominium, Inc. v. QBE Ins. Corp., 2008 WL2645680,

at *9 (S.D. Fla. June 26, 2008).

      B. The Court should terminate the deposition because of the entirety of
         the misconduct by Plaintiff’s counsel.

      Synovus counsel Mr. Bates finally terminated the 30(b)(6) deposition

specifically because Plaintiff’s counsel sought to not only use documents he had

refused to provide to Synovus in advance and which he refused to provide to the

witness and Synovus counsel during the deposition, but then sought to interrogate
                                       13
the witness about documents which he, Plaintiff’s counsel, had redacted. But the

entirety of Plaintiff’s counsel’s misconduct referenced above warrants an Order

that the deposition is terminated.

      C. The Court should also terminate the deposition because Plaintiff’s
         counsel violated Synovus’ right to present the witness with complete,
         unredacted copies of the text messages.

      Plaintiff counsel’s decision to attempt to examine Synovus with text

messages which he had heavily redacted without first providing complete,

unredacted copies of the text messages to the witness and to Synovus counsel

violated federal law. Federal Rule of Evidence 106, sometimes referred to as the

“rule of completeness,” states that “if a party introduces all or part of a writing or a

recorded statement, an adverse party may require the introduction, at that time, of

any other part—or any other writing or recorded statement—that in fairness ought

to be considered at the same time.” (Emphasis added.) Therefore when Synovus

counsel requested the complete document, Plaintiff’s counsel was obligated to

provide it – then and there. That is simple fairness, to the witness, and to Synovus.

By refusing to provide Synovus with unredacted copies of the text messages,

Plaintiff’s counsel deprived Synovus of its right to determine which portions of the

text messages should be considered by the witness, in both his responses to

questions on cross-examination and on later direct examination.



                                          14
      Additionally, Federal Rule of Civil Procedure 30(f)(2) requires that

“documents and tangible things produced for an inspection during a deposition

must, on a party’s request, be marked for identification and attached to the

deposition. Any party may inspect and copy them.” (Emphasis added.) Plaintiff’s

counsel violated this Rule during the deposition by refusing to permit Synovus to

inspect unredacted copies of the text messages, and Plaintiff’s counsel continues to

violate this Rule.

      Plaintiff’s counsel’s tactics had immediate prejudicial consequences.

Without unredacted copies of the text messages, Synovus’ 30(b)(6) witness could

not fully respond to questions posed to him on cross-examination. Without

unredacted copies, Synovus counsel could not conduct a complete direct

examination of its Rule 30(b)(6) corporate representative. That prejudice was

explicitly intended by Plaintiff’s counsel. The purpose was to sandbag Synovus

and the witness, and to try to leave the factfinder with the impression that Synovus

had no response to the text messages Plaintiff had used during the deposition.

      The fact that Plaintiff’s counsel elected to conduct his examination of the

30(b)(6) witness by Zoom video conference does not change the law. Counsel was

still obliged to conduct a “fair examination of the deponent” and to refrain from

conducting the deposition “in bad faith.” See Fed. R. Civ. P. 30(d)(2), (d)(3)(A).



                                         15
       D. The Court should terminate the deposition because Synovus was
          entitled to be provided with the statements Plaintiff’s counsel
          attempts to attribute to Synovus.

       Plaintiff’s counsel’s tactical decision to sandbag Synovus’ corporate

representative with text messages Plaintiff contends are statements attributable to

Synovus establishes a clear violation of Federal Rule of Civil Procedure

26(b)(3)(C). That Rule provides that “any party or other person may, on request . .

. obtain the person’s own previous statement about the action or its subject matter.”

       Synovus counsel requested any such text messages from Plaintiff’s counsel

before the Rule 30(b)(6) deposition, but Plaintiff’s counsel failed to provide them.

Indeed, on Monday, June 15, 2020, counsel for Synovus sent an email to plaintiff’s

counsel requesting “texts between Sport & Wheat, or someone at Sport & Wheat,

and someone at Synovus” before the deposition. Plaintiff’s counsel failed to

respond. See 6/15/20 Email of P. Bates to B. Cash, attached hereto as Ex. 2.

Rather than complying with its obligation to provide these text messages to

Synovus before the deposition occurred, Plaintiff’s counsel chose to sandbag

Synovus’ corporate representative during the deposition in violation of both the

text and spirit of the rule.




                                         16
                                 CONCLUSION

      Synovus respectfully requests that the Court terminate its Rule 30(b)(6)

deposition in light of the bad faith manner in which that deposition was conducted.

      Respectfully submitted, this 22nd day of June, 2020.

                                By: /s/Philip A. Bates
                                       Philip A. Bates
                                       Florida Bar #228354
                                       PHILIP A. BATES, P.A.
                                       25 West Cedar Street, Suite 550 (32502)
                                       Post Office Box 1390
                                       Pensacola, FL 32591
                                       pbates@philipbates.net
                                       (850) 470-0091

                                      James E. Butler, Jr.
                                      Georgia Bar #099625
                                      Ramsey B. Prather
                                      Georgia Bar #658395
                                      BUTLER WOOTEN & PEAK LLP
                                      105 Thirteenth Street
                                      P.O. Box 2766
                                      Columbus, GA 31902
                                      jim@butlerwooten.com
                                      ramsey@butlerwooten.com
                                      (706) 322-1990

                                      Paul J. Nathanson
                                      Columbia Bar #982269
                                      DAVIS POLK & WARDWELL LLP
                                      901 15th Street, N.W.
                                      Washington, D.C. 20005
                                      paul.nathanson@davispolk.com
                                      (202) 962-7000

                                      Antonio M. Haynes
                                      New York Bar #5151816
                                       17
DAVIS POLK & WARDWELL LLP
450 Lexington Ave.
New York, NY 10017
antonio.haynes@davispolk.com
(212) 450-4000

Attorneys for Defendant Synovus Bank




 18
      CERTIFICATE PURSUANT TO LOCAL RULE 7.1(B) AND (C)

      Pursuant to Local Rule 7.1(B) & (C), undersigned counsel certify that they

attempted in good faith to resolve the issue through a meaningful conference with

plaintiff’s counsel during the deposition, but were unsuccessful.

                                By: /s/Philip A. Bates
                                       Philip A. Bates
                                       Florida Bar #228354
                                       PHILIP A. BATES, P.A.
                                       25 West Cedar Street, Suite 550 (32502)
                                       Post Office Box 1390
                                       Pensacola, FL 32591
                                       pbates@philipbates.net
                                       (850) 470-0091




                                         19
            LOCAL RULE 7.1(F) WORD LIMIT CERTIFICATION

      Pursuant to Northern District of Florida Local Rule 7.1(F), I certify that this

Motion to Terminate Rule 30(b)(6) Deposition is in compliance with the Court’s

word limit. According to the word processing program used to prepare this motion,

the document contains 3,700 words, exclusive of the case style, signature block,

and this certification.

                                By: /s/Philip A. Bates
                                       Philip A. Bates
                                       Florida Bar #228354
                                       PHILIP A. BATES, P.A.
                                       25 West Cedar Street, Suite 550 (32502)
                                       Post Office Box 1390
                                       Pensacola, FL 32591
                                       pbates@philipbates.net
                                       (850) 470-0091




                                         20


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