IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT

IN AND FOR PINELLAS COUNTY, FLORIDA

CIVIL DIVISION

JAMES MCLYNAS

Plaintiff, Case Number: 16-006722-CI

vs.

PINELLAS COUNTY SHERIFF’S OFFICE

and BOB GUALTIERI, IN HIS OFFICIAL
CAPACITY AS SHERIFF OF PINELLAS
COUNTY, FLORIDA,

Defendants.
_____________________________________/

SUBPOENA DUCES TECUM FOR DEPOSITION

THE STATE OF FLORIDA

TO: TAMMY T. DRIVER
c/o Della Connolly Cope, Esq.
PINELLAS COUNTY SHERIFF’S OFFICE
GENERAL COUNSEL’S OFFICE
10750 Ulmerton Road
Largo, FL 33778

You are commanded to personally appear before Anderson Court Reporting, a person
authorized by law to take the deposition of TAMMY T. DRIVER at the Summit Executive
Center, 13575 58th Street, North, Ste. 200, Clearwater, FL 33760 on Wednesday, July 18,
2018 at 2:00 p.m. for the taking of your deposition in this action and to have with you at that
time and place the following:

1. Any and all responses of any kind, including email responses from the Pinellas
County Sheriff’s Office to James McLynas and/or his email address of
karguy12@yahoo.com, in your possession or in the possession of the Pinellas County
Sheriff’s Office with regards to Exhibits I, M, N, O, P, Q, R, S, T, U, V, W, and Y,
attached to Plaintiff’s First Amended Complaint and copies of which are hereby
attached to this Subpoena Duces Tecum for reference.

If you fail to appear, you may be held in contempt of court.

 You are subpoenaed to appear by GERASIMOS “JERRY” THEOPHILOPOULOS and unless
excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as
directed.

Dated on June 11, 2018.

For the Court

/s/ Jerry”Theophilopoulos
______________________________
Gerasimos “Jerry” Theophilopoulos
THEOPHILOPOULOS LAW
attorneyjerryt@gmail.com
Attorney for Plaintiff, James McLynas
649 E. Tarpon Avenue
Tarpon Springs, FL 34689
Phone: (727) 945-1112
FBN: 0068380

FOR PROCEEDINGS BEFORE THE COURTS OF PINELLAS COUNTY

IF YOU ARE A PERSON WITH A DISABILITY WHO NEEDS ANY ACCOMMODATION IN ORDER TO PARTICIPATE IN THIS
PROCEEDING, YOU ARE ENTITLED, AT NO COST TO YOU TO THE PROVISION OF CERTAIN ASSISTANCE. WITHIN TWO (2)
WORKING DAYS OF YOUR RECEIPT OF THIS SUBPOENA PLEASE CONTACT THE OFFICE OF HUMAN RIGHTS, PINELLAS
COUNTY, 400 SOUTH FT. HARRISON AVENUE, SUITE 300, CLEARWATER, FLORIDA 33756; (727) 464-4062. IF YOU ARE HEARING
IMPAIRED, PLEASE CONTACT 1-800-955-8771.

PROPER DRESS IS REQUIRED, OR YOU MAY BE HELD IN CONTEMPT OR REFUSED ADMITTANCE, NO SHORTS, UNDERSHIRTS,
TANK TOPS, ETC.