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Haytham, I spoke with Larry Carver this
morning. He said that he feels he already answered all the questions he
needs to answer at his earlier deposition. He is not willing to cooperate
with us to get his deposition scheduled unless we tell him in advance both (i)
what we plan to ask him in the deposition and (ii) provide him with copies of
the documents that we plan to ask him about during the deposition. I told him
that we are not obliged to preview either our questions or the documents we are
going to show him. He said that, if we are not willing to work with him
in this manner, then we will need to get a court order to compel him to appear
for his deposition. I told him that if we are forced to get a court order
compelling him to appear for his deposition, then we will seek costs as well. He said he will send me an email later
today regarding the foregoing. As a result, you should get him served without
delay with a subpoena issued by a Kevin Kevin B. Duff Rachlis Durham Duff & Adler, LLC phone: 312-733-3390 fax: 312-733-3952 mobile: 312-218-8620 RACHLIS This transmission may be: (1) subject to
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