Exhibit A

,,

CAUSE NO. PR-11-3238-1 IN RE: ESTATE OF MAX D. HOPPER, DECEASED

JON. HOPPER Plaintiff,

v. .JPMORGAN CHASE BANK, N.A. STEPHEN B. HOPPER and LAURA S. WASSMER Defendants.

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IN THE PROBATE COURT

N0.1

DALLASCOUNTY,TEXAS

THE STATE OF TEXAS SUBPOENA DUCES TECUM FOR NON-PARTY PRODUCTION OF DOCUMENTS PURSUANT TO TEXAS RULES OF CIVIL PROCEDURE 176 AND 205.3 To any Sherifr'or Constable of the State of Texas or other person authorized to serve and executed Subpoenas as provided in Rule 176 T.R.C.P. Greetings: You are hereby commanded to subpoena and summon the following witness who may be served as follows: J.P. Morgan Securities, LLC through its registered agent C.T. Corporation System, 1999 Bryan St., Ste. 900 Dallas, Texas 75201-3136 FAX TO INPUT DEPARTMENT 317-757-7421 Produce for inspection and copying the documents and tangible things in its possession, custody or control that are listed in Exhibit "A" of the attached Notice of Subpoena for Non-Party Production of Documents on or after the tenth (1Oth) day from the date of service of this subpoena, at the offices of Fee, Smith, Sharp & Vitullo, LLP, 13155 Noel Road, Suite 1000, Dallas, Texas 75240,972-934-9100, no later than July 21,2016. DO NOT FAIL to return this writ to said Court, with return thereon, showing the manner of execution. WITNESS MY HAND this the 7TH day of July, 2016.

Respectfully submitted,

Taylor Horton State Bar No. 24086402 Three Galleria Tower 13155 Noel Road, Suite 1000 Dallas, Texas 75240 (972) 934-9100 . (972) 934-9200 [Fax] [email protected]

James S. Bell, PC James S. Bell 5942 Colhurst Dallas, Texas 75230 Tel: (214) 668-9000 Fax: (214) 594-9462 State Bar No. 24049314 i~:[email protected]

ATTORNEY FOR DEFENDANTS STEPHEN B. HOPPER AND LAURA WASSMER

SUBPOENA DUCES TECUM RETURN Came to hand the day of A.D. 20 at o'clock __.m., A.D. 20_ _ at _o'clock_ .m., by and executed on the day of delivering to the within named witness, in person, a true copy of this Subpoena and tendering him $10.00 which he accepted. FEES: Serving Subpoena Mileage TOTAL

$_ _ __ $_ _ __ $ _ _ __

----------------Process Server _ _ _ _ _ _ _ _ _ _ County, Texas ACCEPTANCE OF SERVICE OF SUBPOENA BY WITNESS PER RULE 176 T.R.C.P. I, the undersigned witness named in the Subpoena acknowledge receipt of a copy thereof, and hereby accept service of the attached subpoena, and will produce the documents requested as directed in this subpoena.

Rule 176.8(a) Contempt Failure by any person without adequate excuse to obey a subpoena served upon that person may be deemed a contempt of the court from which the subpoena is issued or a district court in the county in which the subpoena is served, and may be punished by fine or confinement, or both.

SIGNATIJRE OF WITNESS

DATE

**************************************************************************** Not executed as to the witness following _

for the -------------------- reasons:

CAUSE NO. PR-11-3238-1 IN RE: ESTATE OF MAX D. HOPPER, DECEASED

JO N.HOPPER

Plaintiff,

v. JPMORGAN CHASE BANK, N.A. STEPHEN B. HOPPER and LAURA S. WASSMER Defendants.

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IN THE PROBATE COURT

N0.1

DALLAS COUNTY, TEXAS

NOTICE OF INTENT TO ISSUE SUBPOENA FOR PRODUCTION OF DOCUMENTS TO: J.P. Morgan Securities, LLC through its registered agent C.T. Corporation System, 1999 Bryan St., Ste. 900 Dallas, Texas 75201-3136 Please take notice that under Texas Rules of Civil Procedure 205.3 and 621a, Stephen B. Hopper and Laura S. Wassmer intend to subpoena production of the documents described in the attached Exhibit A. Responsive documents are to be produced at the offices of Fee, Smith, Sharp & Vitullo, LLP, 13155 Noel Road, Suite 1000, Dallas, Texas 75240. Under Rule 205.2 of the

Texas Rules of Civil Procedure, you will be receiving a subpoena, not less than ten (10) days after service of this notice, requesting production of the documents set forth in Exhibit A to this notice on or before July 10, 2016.

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Respectfully submitted,

Anthony L. Vitullo State Bar No. 20595500 Taylor Horton State Bar No. 24086402 Three Galleria Tower 13155 Noel Road, Suite 1000 Dallas, Texas 75240 (972) 934-9100 (972) 934-9200 [Fax] [email protected]

James S. ~ell, PC James S. Bell 5942 Colhurst Dallas, Texas 75230 Tel: (214) 668-9000 Fax: (214) 594-9462 State Bar No. 24049314 [email protected] ATTORNEY FOR DEFENDANTS STEPHEN B. HOPPER AND LAURA WASSMER

CERTIFICATE OF SERVICE THIS WILL CERTIFY that a true and correct copy of the foregoing instrument has been

mailed, emailed, telecopied or hand delivered to all attorneys of record in this cause of action on the 15th of June, 2016. John C. Eichman Hunton & Williams, LLP 1445 Ross Avenue, Suite 3700 Dallas, Texas 75202 Alan S. Loewinsohn Loewinsohn Flegle Deary LLP 12377 Merit Dr., Suite 900 Dallas, Texas 75251 ANTHONY L. VITULLO NOTICE OF INTENT TO ISSUE SUBPOENA FOR PRODUCTION OF DOCUMENTS

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REQUESTS FOR PRODUCTION INSTRUCTIONS Any reference to "document" or "documents" shall mean all written, printed, typed, recorded, or graphic matter of every kind and description, both originals and copies, and all attachments and appendices thereto, including but not limited to all agreements, contracts, communications, correspondence, letters, telegrams, telexes, messages, e-mail, .memoranda, records, reports, books, summaries or other records of telephone conversations or interviews, summaries or other records of personal conversations, minutes or summaries or other records of meetings and conferences, summaries or other records of negotiations, diaries, diary entries, calendars, appointment books, visitor records, time records, instructions, work assignments, forecasts, statistical data, statistical statements, worksheets, work papers, drafts, graphs, maps, charts, tables, analytical records, consultants' reports, appraisals, notes, marginal notations, notebooks, statements, records of obligation in expenditure, lists, recommendations, files, printouts, compilations, tabulations, confirmations, analyses, studies, surveys, transcripts of hearings, transcripts of testimony, microfilm, microfiche, articles, speeches, tape or disk ·recordings, sound recordings, video recordings, film, tape, photographs, data compilations from which information can be obtained (including matter used in data processing typewritten, recorded, stenographic, computer-generated, computer-stored, or electronically stored matter, however, and by whomever reduced, prepared, reproduced, disseminated, or made), as well as· any and all destroyed electronic communications, in your possession, custody, or control. A non-identical draft or copy is a separate document within the meaning of this term. All documents are to be producedunedited and as they are kept in the usual and ordinary course of business, and organized/labeled to correspond with the categories in these Requests for Production. Unless otherwise stated, _these Requests call for all documents within your possession, custody, or control. These requests are intended to include all electronically stored information, including emails and electronic drafts of documents (including any and all destroyed electronic communications). Please produce all electronically sto~ed data in its native format on electronic media.

•

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EXHIBIT A DEFINITIONS AND INSTRUCTIONS "Document" or "documents" means any written or recorded material, whether typed, reported, handwritten, printed or otherwise, (or any photograph, photostat, microfilm, tape recording or other reproduction thereof) including, without limitation, each note, memorandum, work paper, letter, telegram, telex, circular, release, article, wire transmission, facsimile, report, prospectus, recording or memorandum of telephone or personal conversation (either in writing or upon any mechanical, electrical or electronic recording device), analysis, chart, account, book, draft, summary, diary, transcript, agreement, contract, order, electronic mail with any and all attachments, spreadsheet, tape, computer diskette, and other data compilation from which information can be obtained or translated through detection devices into reasonable usable form, including the original and any non-identical copy (whether different from the original because of handwritten notes, or underlining on the copy or otherwise). The terms shall include data or information in the electronic or magnetic form, including but not limited to emails with any and all attachments, databases and spreadsheets. The term "documents" includes all non-identical (for whatever reason) copies, versions, and drafts of other documents. Electronically stored information should be produced as Tiff image files in a searchable electronic format. Specifically, the Tiff images should be produced as a single-page Group IV TIFF format and accompanied by a Ringtail or any MDB load file. The full extracted or OCR text should be included and produced at a document level and located in the same folder as their respective document image. Metadata information should be produced in Ringtail or any MOB file format. The Ringtail or MDB file should provide the following meta-data fields: custodian name, filename or subject line, original path or inbox folder path, To, From, CC, BCC, create date, modify or sent date, beginning and ending bates numbers, page count, attachment range. Notwithstanding the above, spreadsheets (typically Excel files) should be produced in their native format. If a spreadsheet includes information requiring redaction, it will be acceptable to remove such information from the spreadsheet in its native format (such as deleting a column or row) instead of producing it in TIFF format with redacted OCR. While the redacted information may be removed from the spreadsheet, the spreadsheet formatting and header information is not to be altered or removed from the file. Defendant will clearly identify any native document that has undergone this process to perform such redactions. In any event, the original file will be preserved with all original data. "Communication" means all written or verbal communications and includes, without limitation, correspondence and memoranda, face-to-face conversations, e-mail transmissions and telephone conversations. With respect to each document covered by this Request for Production which you presently contend that you are not required to disclose because of any privilege or exemption, a. b.

identify the document by date, title, authors, recipients, and addresses; state the nature of the privilege asserted (e.g., attorney-client, self-incrimination, work-product, etc.); and

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c.

briefly describe the nature of the document (a statement that the document is a letter, a memorandum, a set of notes, or similar description should suffice).

The requests for production of documents herein require you to gather and produce all responsive documents within your possession, custody or control. To the extent that you reasonably believe that any of the following requests for production are objectionable, you should respond, and produce any responsive documents that are not, in your view, objectionable. If you state an objection to a request for production, state the portion of the request which you believe is objectionable, specify every ground for your objection, and state whether any documents are being withheld from production based on your objection. The requests for production below are continuing in nature. In construing these Requests: (i) the singular shall include the plural and the plural shall include the singular;· (ii) the masculine, feminine or neuter pronoun shall not exclude other genders; (iii) the connectives "and" and "or" shall be read either disjunctively or conjunctively as necessary to bring within the scope of the discovery request all responses that might otherwise be construed to be outside its scope; (iv) the terms "any," "all" and "each" shall be read to mean any, all and each; and (v) the word "including" shall be read to mean including without limitation.

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DOCUMENTS REQUESTED 1. Any and all documents relating to Todd Alan Baird's separation from employment with J.P. Morgan Securities, LLC, insofar as such separation related in any way to Jo N. Hopper, JP Morgan Chase Bank, N.A.'s administration of the estate of Max D. Hopper, or the management of JoN. Hopper's funds as part of JP Morgan Chase, N.A.'s Private Banking Group. 2. Any and all documents containing or evidencing communication occurring from January 25, 2010 to June 31, 2015 between Todd Alan Baird and JP Morgan Chase Bank, N.A., as independent administrator of the estate of Max D. Hopper, relating to Jo N. Hopper's managed accounts.

3. Any and all documents containing or evidencing communication between Todd Alan Baird and Susan Novak occurring from January 25, 2010 to June 31, 2015 relating to Jo Hopper or to JP Morgan Chase Bank, N.A.'s administration of the estate of Max D. Hopper. 4. Any and all documents bearing Jo Hopper's signature, whether such signature is handwritten or electronic. 5. Any and all documents containing or evidencing JP Morgan Chase Bank, N.A.'s desire to retain Jo Hopper as a client.

6. Any and all documents containing or evidencing J.P. Morgan Securities, LLC's desire to retain Jo Hopper as a customer. 7. Any and all documents created between January 25, 2010 and June 31, 2015 referencing Laura S. Wassmer. 8. Any and all documents created between January 25, 2010 and June 31,2015 referencing Stephen B. Hopper.

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