The first thing we need to understand is whether we can issue a summons. That's the one thing we are going to park, because if we can't issue summonses, we will have to call the witnesses and say here are the dates we are suggesting. If moving to summon is not the right motion, then she can present one saying here are the dates.
Let's just park it while the clerk is looking for a precedent as to whether we can summon them. Procedurally that may or may not be possible.