Re: Cynowa v. CSSS, et al. -- Carver deposition

["William F. Slater, III" <slater@billslater.com>]

Kevin,

That's what I'm talking about!!!

http://uncyclopedia.wikia.com/wiki/Whup-Ass

With great respect and admiration,

Best regards,

Bill
William F. Slater, III, PMP
Chicago, IL
United States of America
slater@billslater.com
http://billslater.com
http://billslater.com/career
773 - 235 - 3080 - Home
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On Mon, February 21, 2011 11:18 am, Kevin Duff wrote:
> 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 Virginia court that can be enforced if he fails to show.  Let us know
> what you need from the Illinois court in order to get the Virginia court
> to
> issue the subpoena.
>
>
>
> Kevin
>
>
>
>
>
>
>
> Kevin B. Duff
>
> Rachlis Durham Duff & Adler, LLC
>
> 542 South Dearborn Street, Suite 900
>
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>
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>
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>
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>
>
>
>
>
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