H TLLMAN YaTES & TIS DALE ATTERNEYS AND COUNSELORS AT LAW

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1 H TLLMAN YaTES & TIS DALE ATTERNEYS AND COUNSELORS AT LAW THOMAS S. TISDALE D RECT VOICE A Tsr@H ELLMA NYATEs.coM HELLMAN YATES & TISDALE, PA I05 BROAD STREET, THIRD FLOOR CHARLESToN, SoUTH CARoLI N A 294cl 1 v F I aa April r, zor4 Via U.S. Mail The Honorable Cheryl L. Graham Dorchester County Clerk of Court 5zoo East Jim Bilton Boulevard St George, S.C RE: The Protestant Episcopal Church in the Diocese of South Carolina, et al. v. The Episcopal Church, et al. Dorchester County Court of Common Pleas Case No.: zo13-cp-18-ooo13 Dear Ms. Graham Enclosed please find one original and one copy of Defendant The Episcopal Church in South Carolina's Notice and Motion to Quash Subpoenas Issuedby The Protestant Episcopal Church In The Diocese Of South Carolina and the Trustees of The Protestant Episcopal Church in South Carolina and to Hold Them in Contempt of Court, the Certificate of Service, and a check in the amount of $z5.oo, in regards to the above-referenced case. Please return one, file-stamped copy to our office. I have enclosed a stamped, selfaddressed envelope for your convenience. Thank you for your assistance. Ifyou have any questions, please do not hesitate to contact me at your convenience. Thomas S. Tisdale TST:asb w/enclosures cc: All Counsel of Record (via and U.S. Mail

2 STATE OF SOUTH CAROLINA COUNTY OF DORCHESTER The Protestant Episcopal Church In The Diocese Of South Carolina; The Trustees of The Protestant Episcopal Church in South Carolina, a South Carolina Corporate Body, et al., PLAINTIFFS, The Episcopal Church (alua,the Protestant Episcopal Church in the United States of America; The Episcopal Church in South Carolina, v DEFENDANTS IN THE COURT OF COMMON PLEAS FOR THE FIRST rudicial CIRCUIT Case No.: 2013-CP-l TECSC'S NOTICE AND MOTION TO QUASH SUBPOENAS ISSUEI BY THE PROTESTANT EPISCOPAL CHURCH IN THE DIOCESE OF SOUTH CAROLINA AND THE TRUSTEES OF TIIE PROTESTANT EPISCOPAL CHURCH IN SOUTH CAROLINA AI\D TO HOLD THEM IN CONTEMPT OF COURT TO: ALL COUNSEL OF RECORD PLEASE TAKE NOTICE that Defendant The Episcopal Church in South Carolina ("TECSC", will move before the Honorable Diane S. Goodstein of the First Judicial Circuit in Dorchester County, on the tenth (10th day after service or as soon thereafter as counsel may be heard, to quash subpoenas issued by two of the Plaintiffs, The Protestant Episcopal Church In The Diocese of South Carolina and The Trustees Of The Protestant Episcopal Church In South Carolina, and to hold them in contempt of court. The grounds for this motion are as follows: As the Plaintiffs know: an appeal is pending; the Court of Appeals has not issued a remittitur and this Court lacks jurisdiction over all matters affected by the appeal pursuant to Rules 205,221,240, and 241, SCACR; this Court has already ruled that the stay should not be lifted for the purpose of proceeding with discovery or other matters in the scheduling order; and the Plaintiffs' redundant second motion to lift the stay for that exact same purpose was served I

3 only days ago and has not yet been heard. In disregard and contempt for all of the above, The Protestant Episcopal Church In The Diocese of South Carolina and The Trustees Of The Protestant Episcopal Church In South Carolina have recently noticed many depositions starting as early as next week, and their counsel have issued many subpoenas, wrongfully abusing their powers as officers of this Court in matters for which this Court lacks jurisdiction and has declined to lift the stay. WHEREFORE, respectfully, TECSC requests that the subpoenas issued by The Protestant Episcopal Church In The Diocese of South Carolina and The Trustees Of The Protestant Episcopal Church In South Carolina be quashed and that they be held in contempt of this Court and that appropriate sanctions be imposed upon their counsel. Dated: March 31,2014 Re spectfu lly submitted, rr'l /ØrU4'1/ Thomas S. Tisdale (S.C. Bar #: Jason S. Smith (S.C. Bar #: HELLMAN YATES & TISDALE, PA 105 Broad Street, Third Floor Charleston, South Carolina Telephone: ( Facsimile: ( Counselfor Defendant The Episcopal Church in South Carolina 2

4 STATE OF SOUTH CAROLINA COUNTY OF DORCHESTER The Protestant Episcopal Church In The Diocese Of South Carolina; The Trustees of The Protestant Episcopal Church in South Carolina, a South Carolina Corporate Body, et al., PLAINTIFFS, The Episcopal Church (alwa,the Protestant Episcopal Church in the United States of America; The Episcopal Church in South Carolina, V DEFENDANTS IN THE COURT OF COMMON PLEAS FOR THE FIRST rudicial CIRCUIT Case No.: 2013-CP-l CERTIFICATE OF SERVICE This is to certifr that a copy of the foregoing, The Episcopal Church in South Carolina's ("TECSC" Notice and Motion to Quash Subpoenas Issued by The Protestant Episcopal Church In The Diocese Of South Carolina and The Trustees of the Protestant Episcopal Church in South Carolina has been served upon the following counsel of record by U.S. hrst-class mail and electronic mail as shown below this the 1't day of April AMANDA A. BAILEY, ESQ. ATTORNEY FOR PLAINTIFFS THE PROTESTANT EPISCOPAL CHURCH IN THE DIOCESE OF SOUTH CAROLINA; SAINT LUKE,S CHURCH, HILTON HEAD; AND THE TRUSTEES OF THE PROTESTANT EPISCOPAL CHURCH IN THE DIOCESE OF SOUTH CAROL]NA McNair Law Firm Post Ofhce Box 336 Myrtle Beach, S.C ( SAUNDERS M. BRIDGES, JR., ESQ. ATTORNEY FOR PLAINTIFF ST. JOHN'S EPISCOPAL CHURCH OF FLORENCE, S,C. Aiken Bridges Elliott Tyler & Saleeby, PA Post Office Drawer 1931 Florence, S.C

5 (843 66e-8787 WILLIAM A BRYAN, ESQ. ATTORNEY FOR PLAINTIFF CHURCH OF THE RESURRECTION, SURFSIDE Bryan &IIazr Post Office Box Surfside Beach, S.C ( C. PIERCE CAMPBELL, ESQ. ATTORNEY FOR PLAINTIFFS ALL SAINTS PROTESTANT EPISCOPAL CHURCH, INC.; CHURCH OF THE HOLY CROSS; AND ST. BARTHOLOMEWS EPISCOPAL CHURCH Turner, Padget, Graham & Laney Post Office Box 5478 Florence, S.C ( e008 DAVID S. COX, ESQ. ATTORNEY FOR PLAINTIFFS THE PROTESTANT EPISCOPAL CHURCH IN THE DTOCESE OF SOUTH CAROLINA AND THE TRUSTEES OF THE PROTESTANT EPISCOPAL CHURCH IN THE DIOCESE OF SOUTH CAROLINA V/omble, Carlyle, Sandridge & Rice, LLP Post Office Box 999 Charleston, S.C ( THOMAS C. DAVIS, ESQ. ATTORNEY FOR PLAINTIFF CHRIST ST. PAUL'S EPISCOPAL CHURCH Harvey & Battey, PA 1001 Craven Street Beaufort, S.C (843 s DAVID L. DEVANE, ESQ. ATTORNEY FOR PLAINTIFF THE CHURCH OF ST. LUKE AND ST., PAUL, RADCLIFFBORO 110 N. Main Street Summerville, S.C (843 28s-7100 BESS JONES DURANT, ESQ. ATTORNEY FOR PLAINTIFF CHURCH OF THE HOLY COMFORTER Sowell Gray Stepp &Laffitte,LLC Post Office Box Columbia, S.C.292ll (803 e29-r400 2

6 HARRY R. EASTERLING, JR., ESQ. ATTORNEY FOR PLAINTIFFS ST. DAVID'S CHURCH AND ST. PAUL'S EPISCOPAL CHURCH OF BENNETTSVILLE, INC. Goldberg & Easterling, PA Post Ofhce Drawer 655 Bennettsville, S.C ( MARK V. EVANS, ESQ. ATTORNEY FOR PLAINTIFF ST. JAMES' CHURC, JAMES ISLAND, SOUTH CAROLINA 147 Wappoo Creek Drive, Suite 202 Charleston, S.C ( W. FOSTER GAILLARD, ESQ. ATTORNEY FOR PLAINTIFF THE PROTESTANT EPISCOPAL CHURCH, OF THE PANSH OF SAINT PHILIP, IN CHARLESTON, IN THE STATE OF SOUTH CAROLINA V/omble Carlyle Sandridge & Rice, LLP Post Office Box 999 Charleston, S.C ( EMILY R. GIFFORD, ESQ. ATTORNEY FOR PLAINTIFF THE VESTRY AND CHURCH TryARDENS OF THE EPISCOPAL CHURCH OF THE PARISH OF ST. MATTHEW Richardson, Plowden & Robinson, P.A Barnwell Street Columbia, 5.C (803 s HENRIETTA U. GOLDING, ESQ. ATTORNEY FOR PLAINTIFFS THE PROTESTANT EPISCOPAL CHURCH IN THE DIOCESE OF SOUTH CAROLINA; SAINT LUKE'S CHURCH, HILTON HEAD; AND THE TRUSTEES OF THE PROTESTANT EPISCOPAL CHURCH IN THE DIOCESE OF SOUTH CAROLINA McNair Law Firm Post Off,rce Box 336 Myrtle Beach, S.C ( t107 HENRY E. GRIMBALL, ESQ. ATTORNEY FOR PLAINTIFF THE PROTESTANT EPISCOPAL CHURCH, THE PARISH OF SAINT MICHAEL, IN CHARLESTON, IN THE STATE OF SOUTH CAROLINA Womble, Carlyle, Sandridge & Rice, LLP Post Office Box 999 J

7 Charleston, S.C ( EDV/ARD P. GUERARD, JR., ESQ. ATTORNEY FOR PLAINTIFF VESTRY AND CHURCH-WARDøNS OF THE EPISCOPAL CHURCH OF THE PANSH OF CHNSTCHURCH Post Office Box3l924 Charleston, S.C (843 8s2-4s30 ROBERT R. HORGER, ESQ. ATTORNEY FOR PLAINTIFF CHURCH OF THE REDEEMER Horger, Barnwell & Reid, LLP Post Office Drawer 329 Orangeburg, S.C (803 s OANA D. JOHNSON, ESQ. ATTONNEY FOR PLAINTIFF ST. ANDREWS CHURCH-MT. PLEASANT AND THE ST. ANDREWS CHURCH- MT. PLEASANT LAND TRUST George J. Kefalos, PA 464 State Street Charleston, S.C ( GEORGE J. KEFALOS, ESQ. ATTORNEY FOR PLAINTIFF ST. ANDREWS CHURCH-MT. PLEASANT AND THE ST. ANDREWS CHURCH- MT. PLEASANT LAND TRUST George J. Kefalos, PA 464 State Street Charleston, S.C ( JAMES K. LEHMAN, ESQ. ATTORNEY FOR PLAINTIFF TNNITY CHURCH OF MYRTLE BEACH Nelson Mullins Riley & Scarborough, LLP Post Office Box Columbia, S.C.292ll (803 7e E. HOPE LUMPKIN, ESQ. ATTORNEY FOR PLAINTIFF THE VESTRY AND WARDENS OF ST. PAUL'S CHURCH, SUMMERVILLE Shelbourne Law Firm 131 East Richardson Avenue Summerville, S.C ( t0 4

8 SUSAN P. MACDONALD, ESQ. ATTORNEY FOR PLAINTIFF TNNITY CHURCH OF MYRTLE BEACH Nelson Mullins Riley & Scarborough, LLP Post Office Box 3939 Myrtle Beach, S.C ( s00 FRANCIS M. MACK, ESQ. ATTORNEY FOR PLAINTIFF THE VESTRY AND CHURCH WARDENS OF THE EPISCOPAL CHURCH OF THE PANSH OF ST. MATTHEW 656 Fort Motte Road Saint Matthews, S.C DAVID B. MARVEL, ESQ. ATTORNEY FOR PLAINTIFF THE CHURCH OF ST. LUKE AND ST., PAUL, RADCLIFFBORO Prenner Marvel, P.A. 636 King Street Charleston, S.C ( s0 I. KEITH MCCARTY, ESQ. ATTORNEY FOR PLAINTIFF CHNST ST. PAUL'S EPISCOPAL CHURCH McCarty Law Firm, LLC Post Office Box Charleston, S.C ( STEVEN S. MCKENZIE, ESQ. ATTORNEY FOR PLAINTIFF ST. MATTHIAS EPISCOPAL CHURCH, INC. Coffey, Chandler, Kent & McKenzie, P.A. 2 North Brook Street Manning, 5.C (803 43s-8847 LAWRENCE B. ORR, ESQ. ATTORNEY FOR PLAINTIFFS ST. JOHN'S EPISCOPAL CHURCH OF FLORENCE, S.C, AND SAINT MATTHETTS CHURCH Orr Elmore & Ervin, LLC Post Office Box2527 Florence, S.C (

9 HARRY A. OXNIER, ESQ. ATTORNEY FOR PLAINTIFFS CHNST THE KING, WACCAMAW AND THE I/ESTRY AND CHURCH WARDENS OF THE EPISCOPAL CHURCH OF THE PANSH OF PNNCE GEORGE I44NYAH Oxner & Stacy 235 Church Street Georgetown, S.C (843 s G. MARK PHILLPS, ESQ. ATTORNEY FOR PLAINTIFF THE PROTESTANT EPISCOPAL CHURCH, THE PARISH OF SAINT PHILIP, IN CHARLESTON, IN THE STATE OF SOUTH CAROLINA Nelson Mullins Riley & Scarborough, LLP Post Office Box 1806 Charleston, S.C (843 s ANDREW S. PLATTE, ESQ. ATTORNEY FOR PLAINTIFFS THE CHURCH OF OUR SAVIOUR OF THE DIOCESE OF SOUTH CAROLINA; CHURCH OF THE CROSS, INC. AND CHURCH OF THE CROSS DECLARATION OF TRUST; THE PROTESTANT EPISCOPAL CHURCH, THE PANSH OF SAINT MICHAEL, IN CHARLESTON, IN THE STATE OF SOUTH CAROLINA AND SAINT MICHAEL'S CHURCH DECLARATION OF TRUST; THE PROTESTANT EPISCOPAL CHURCH, THE PANSH OF SAINT PHILIP, IN CHARLESTON, IN THE STATE OF SOUTH CAROLINA; THE PROTESTANT EPISCOPAL CHURCH IN THE DIOCESE OF SOUTH CAROLINA; ST. DAVID'S CHURCH; THE VESTRY AND CHURCH WARDENS OF THE EPISCOPAL CHURCH OF THE PANSH OF ST. HELENA AND THE PANSH CHURCH OF ST. HELENA TRUST; THE I/ESTRY AND CHURCH WARDENS OF ST. JUDE'S CHURCH OF WALTERBORO; TNNITY EPISCOPAL CHURCH, EDISTO ISLAND; AND I/ESTRY AND CHURCH WARDENS OF THE EPISCOPAL CHURCH OF THE PANSH OF ST. JOHN'S CHARLESTON COUNTY; AND THE CHURCH OF THE EPIPHANY Speights & Runyan 2015 Boundary Street, Suite 239 Beaufort, 5.C ( C. ALAN RI.INYAN, ESQ. ATTORNEY FOR PLAINTIFFS THE CHURCH OF OUR SAVIOUR OF THE DIOCESE OF SOUTH CAROLINA; THE CHURCH OF ST. LUKE AND ST., PAUL, RADCLIFFBORO; CHURCH OF THE CROSS, INC. AND CHURCH OF THE CRO,SS DECLARATION OF TRUST; THE PROTESTANT EPISCOPAL CHURCH, THE PANSH OF SAINT MICHAEL, IN CHARLESTON, IN THE STATE OF SOUTH CAROLINA AND SAINT MICHAEL'S CHURCH DECLARATION OF TRUST; THE PROTESTANT EPISCOPAL CHURCH, THE PANSH OF SAINT PHILIP,IN CHARLESTON,IN THE STATE OF SOUTH CAROLINA; THE PROTESTANT EPISCOPAL CHURCH IN THE DIOCESE OF SOUTH CAROLINA; ST. DAVID'S CHURCH; TNNITY EPISCOPAL CHURCH, EDISTO ISLAND; THE I/ESTRY AND CHURCH WARDENS OF ST. JUDE'S CHURCH OF WALTERBORO; THE I/ESTRY AND CHURCH WARDENS OF THE EPISCOPAL CHURCH OF THE PARISH OF ST. HELENA AND THE PANSH CHURCH OF ST. HELENA TRUST; AND VESTRY AND CHURCH WARDENS OF THE EPISCOPAL CHURCH OF THE PANSH OF ST. JOHN'S CHARLESTON COUNTY; OLD SAINT ANDREWS PARISH CHURCH; AND THE CHURCH OF THE EPIPHANY Speights & Runyan 2015 Boundary Street, Suite 239 Beaufort, 5.C (803 e

10 WILLIAM A. SCOTT, ESQ. ATTORNEY FOR PLAINTIFF HOLY TNNITY EPISCOPAL CHURCH Rogers, Townsend & Thomas, PC 775 St. Andrews Boulevard Charleston, S.C (843 ss6-s6s6 P. BRANDT SHELBOURNE, ESQ. ATTORNEY FOR PLAINTIFF THE VESTRY AND WARDENS OF ST. PAUL'S CHURCH, SUMMERVILLE Shelbourne Law Firm 131 East Richardson Avenue Summerville, S.C ( t0 ROBERT S. SHELTON, ESQ. ATTORNEY FOR PLAINTIFF ST. PAUL'S EPISCOPAL CHURCH OF CONWAY The Bellamy Law Firm Post Office Box 357 Myrtle Beach, S.C ( ALLAN P. SLOAN, III, ESQ. ATTORNEY FOR PLAINTIFF I/ESTRY AND CHURCH-WARDENS OF THE EPISCOPAL CHURCH OF THE PANSH OF CHNST CHURCH Pierce, Herns, Sloan & Wilson, LLC Post Office 8ox22437 Charleston, S.C ( THORNWELL F. SOWELL, III, ESQ. ATTORNEY FOR PLAINTIFF CHURCH OF THE HOLY COMFORTER Sowell Gray Stepp &,Laffitte,LLC Post Oflrce BoxlI449 Columbia, S.C.292Il (803 e2e-1400 STEPHEN A. SPITZ, ESQ. ATTORNEY FOR PLAINTIFF ST. ANDREWS CHURCH-MT. PLEASANT AND THE ST. ANDREWS CHURCH. MT. PLEASANT LAND TRUST ll34 Clearspring Drive Charleston, S.C ( s4 7

11 JOHN FURMAN WALL, III, ESQ. ATTORNEY FOR PLAINTIFF CHURCH OF THE GOOD SHEPHERD 140 Wando Reach Court Mt. Pleasant, S.C CHARLES H. WILLIAMS, ESQ. ATTORNEY FOR PLAINTIFFS THE PROTESTANT EPISCOPAL CHURCH IN THE DIOCESE OF SOUTH CAROLINA AND THE TRUSTEES OF THE PROTESTANT EPISCOPAL CHURCH IN SOUTH CAROLINA, A SOUTH CAROLINA CORPORATE BODY Williams & V/illiams Post Ofhce Box 1084 Orangeburg, S.C (803 s JOHN B. WILLIAMS, ESQ. ATTORNEY FOR PLAINTIFF TRINITY EPISCOPAL CHURCH, PINOPOLIS Williams & Hulst, LLC Post Office Box 1288 Moncks Corner, S.C. 2946I ( JOSEPH C. \ULSON IV, ESQ. ATTORNEY FOR PLAINTIFF VESTRY AND CHURCH-WA, RDE ús OF THE EPISCOPAL CHURCH OF THE PARISH OF CHRIST CHURCH Pierce, Herns, Sloan & Wilson, LLC Post Office 8ox22437 Charleston, S.C ( Ann Skipper Paralegal to Thomas S. Tisdale, Jr., Esq., and Jason S. Smith, Esq. HELLMAN YATES & TISDALE, PA 105 Broad Street, Third Floor Charleston, South Carolina Telephone: ( Facsimile: ( asb@helþqnfates.qem 8