Nick,
Please find attached the proposed order extending scheduling order
dates 60 days. Please let me know if you have any concerns. If there
are none, please execute and return to my office for filing with the
USDC.
I also want to confirm our conversation yesterday regarding your
unilateral selection of depositions dates. During our conversation,
you agreed that the unilateral selection of dates was simply to
preserve your request to take the deposition of the individual
contained on the notice, and that depositions would proceed on
mutually convenient dates for all parties. If my understand
regarding our conversation is wrong, please let me know.
Thanks for your cooperation regarding this.
Sincerely,
Patrick
On 12/14/2011 12:46 PM, Nick Hadous wrote:
Dear Mr. Sturdy:
Please find attached our cover letter and notices of
deposition.
Cordially,
Nick
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