McMillian, Judge. William T. Heard, III, appeals the trial court’s order holding him in contempt for failing to appear at a postjudgment deposition, ordering him to pay attorney fees and costs as sanctions for contempt, and ordering him to appear for a deposition in Georgia. This case raises an issue of first impression as to whether the geographical limits for depositions under OCGA § 9-11-45 (b) (3) apply to nonresident judgment debtors during postjudgment discovery. We find that because the trial court retained jurisdiction over Heard in connection with the judgment and OCGA § 9-11-45 (b) (3) does not apply to parties to a litigation such as Heard, the trial court was authorized to compel Heard to appear for a deposition in Georgia. However, we reverse the trial court’s award of sanctions because a finding of contempt was not authorized in the absence of a court order directing Heard to appear for the deposition.In September 2008, Andrea Ruef brought suit against Heard asserting claims for fraud, unjust enrichment, and breach of contract in connection with real estate held by the parties through their jointly owned limited liability company. Heard filed a timely answer to the complaint, denying liability. The parties ultimately reached a settlement of the claims and on April 5, 2010, entered into a consent judgment awarding Ruef damages against Heard in the principal amount of $1,270,570.77, plus $272,705.71 in accrued interest. After Heard failed to satisfy this judgment, Ruef obtained a writ of fieri facias, which was filed as of record on October 18, 2012. Over four years later, on December 29, 2016, Ruef caused Heard to be personally served with a subpoena and notice of a deposition at a business address in Alabama through a private investigator licensed to serve process there. The notice set the deposition for January 25, 2017, in Atlanta, Georgia. After Heard failed to appear at the appointed place and time, Ruef filed a “Motion to Hold Defendant Heard in Contempt or in the Alternative to Compel,” asking for an evidentiary hearing on the motion for contempt, an order compelling Heard to provide discovery, and an award of attorney fees and costs for the bringing of the motion. Ruef served the motion on Heard by mail at the same Alabama business address and later caused the Rule Nisi setting the hearing on the motion to be personally served on Heard on that address. Heard responded by entering a special appearance to contest the trial court’s jurisdiction over him and to argue, alternatively, that the subpoena was unenforceable under state and federal law. In support of this argument, Heard submitted an affidavit stating that he moved to Florida in 2008 and established legal residency there in 2009 and that Ruef had served him with the subpoena and notice of deposition at his work address in Alabama. Following a hearing, the trial court granted Ruef’s motion, finding that Heard was subject to the court’s jurisdiction and directing him to appear at any properly noticed deposition within the State of Georgia within 30 days. The trial court further ordered that Heard “be held in contempt and subject to pay [Ruef's] attorney fees and costs in an amount of $18,460.78 as sanctions.” On appeal, Heard argues that the trial court erred in finding him in contempt, fining him in an amount exceeding the statutory limit for criminal contempt under OCGA § 15-6-8 (5), and determining that it continued to have personal jurisdiction over him more than seven years after entry of the consent judgment[1] such that he could be compelled to attend a postjudgment deposition in Georgia. 1. We turn first to Heard’s argument that he cannot be compelled to come to Georgia for a deposition and begin our analysis with a review of Georgia’s postjudgment discovery procedures. OCGA § 9-11-69 provides: Process to enforce a judgment for the payment of money shall be a writ of execution unless the court directs otherwise. In aid of the judgment or execution, the judgment creditor, or his successor in interest when that interest appears of record, may do any or all of the following:
(1) Examine any person, including the judgment debtor by taking depositions or propounding interrogatories;
