[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
RE: Motion to Quash Carver Dep Re: (Cynowa v. CSSS) Notice of Deposition for the Continuation of Larry Carver's Evidence Deposition
Kevin,
How convenient!!!
Mr. Carver made blatant negative statements about me under oath that were
patently false. Chief among these was that I was on a Performance
Improvement Plan at CSSS and that I quit in lieu of being fired. Neither
of those statements have any basis in fact. They were uttered out of
sheer meanness in a deliberate effort to smear my character.
You can do what you want with this motion, but I thing the Judge and the
Court should well understand the lengths that these people would go to in
order to win their case.
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
312 - 758 - 0307 - Mobile
On Thu, February 10, 2011 4:27 pm, Kevin Duff wrote:
> It's only two pages plus exhibits. Predictably, it says: (i) the
> deposition
> was over, (ii) we had a chance to previously examine him, (iii) we did not
> move for ruling on questions certified at the deposition, (iv) it is
> prejudicial to them to let us proceed piecemeal, and (v) he is outside
> this
> court's jurisdiction and the subpoena is unenforceable.
>
>
>
> The hearing is Monday at 11:00 a.m. We will cover it. Let me know your
> schedule tomorrow, so we can discuss the motion and our response.
>
>
>
> _____
>
> From: Haytham [mailto:haytham@puckettfaraj.com]
> Sent: Thursday, February 10, 2011 4:13 PM
> To: Kevin Duff
> Cc: John Murray; Kathleen M. Pritchard
> Subject: Re: Motion to Quash Carver Dep Re: (Cynowa v. CSSS) Notice of
> Deposition for the Continuation of Larry Carver's Evidence Deposition
>
>
>
> I have it but haven't read it yet.
>
> Haytham Faraj
>
> Sent from my iPhone
>
>
> On Feb 10, 2011, at 5:09 PM, "Kevin Duff" <kduff@rddlaw.net> wrote:
>
> We just received their motion to quash. It was also faxed to you.
>
>
>
>
> _____
>
>
> From: Haytham [mailto:haytham@puckettfaraj.com]
> Sent: Thursday, February 10, 2011 12:50 PM
> To: Kevin Duff
> Cc: John Murray; Kathleen M. Pritchard
> Subject: Re: Motion to Quash Carver Dep Re: (Cynowa v. CSSS) Notice of
> Deposition for the Continuation of Larry Carver's Evidence Deposition
>
>
>
> Nothing yet.
>
> Haytham Faraj
>
> Sent from my iPhone
>
>
> On Feb 10, 2011, at 12:49 PM, "Kevin Duff" < <mailto:kduff@rddlaw.net>
> kduff@rddlaw.net> wrote:
>
> Haytham,
>
>
>
> Today is the day by which Carver is supposed to produce documents to your
> office in response to our subpoena. Please let me know whether or not you
> receive anything.
>
>
>
> Kevin
>
>
>
>
> _____
>
>
> From: Haytham Faraj [mailto:haytham@puckettfaraj.com]
> Sent: Wednesday, February 09, 2011 3:56 PM
> To: 'Kevin Duff'
> Subject: RE: Motion to Quash Carver Dep Re: (Cynowa v. CSSS) Notice of
> Deposition for the Continuation of Larry Carver's Evidence Deposition
>
>
>
> Kevin,
>
> If she is moved by your email I recommend we speak to her by telephone to
> coordinate an acceptable time for everyone. I liked the tone of your
> email.
>
>
>
>
> From: Kevin Duff [mailto:kduff@rddlaw.net]
> Sent: Wednesday, February 09, 2011 4:01 PM
> To: 'THERESA JOHNSON'
> Cc: 'Peter V. Bustamante'; 'Haytham Faraj'; 'John Murray'; 'Kathleen M.
> Pritchard'
> Subject: RE: Motion to Quash Carver Dep Re: (Cynowa v. CSSS) Notice of
> Deposition for the Continuation of Larry Carver's Evidence Deposition
>
>
>
> Theresa,
>
>
>
> We have provided a significant and reasonable amount of notice of the
> deposition. Mr. Carver's evidence deposition was not previously
> concluded.
> There has been additional discovery with respect to him since he was
> initially deposed. It is unreasonable for you to take the position that
> because you took an evidence deposition of him approximately 18 months
> before the close of discovery and 21 months before trial that we are
> foreclosed, for example, from completing his evidence deposition or
> examining him on areas where we did not previously have an opportunity to
> ask him questions.
>
>
>
> We are willing to attempt to reschedule this deposition to March 10 or 11,
> provided we are able to obtain confirmation that everyone is available
> that
> date. To this end, please let me know which of those dates you are
> available. If one of these dates is not mutually agreeable, or if we are
> not able to confirm that the witness is available one of those dates, then
> we will keep the current date and time as provided in our notice and
> subpoena.
>
>
>
> Kevin
>
>
>
>
> _____
>
>
> From: THERESA JOHNSON [mailto:theresavjohnson@prodigy.net]
> Sent: Wednesday, February 09, 2011 2:44 PM
> To: Kevin Duff
> Cc: Peter V. Bustamante; Haytham Faraj; John Murray; Kathleen M. Pritchard
> Subject: Motion to Quash Carver Dep Re: (Cynowa v. CSSS) Notice of
> Deposition for the Continuation of Larry Carver's Evidence Deposition
>
>
>
> Kevin,
>
> We're moving to Quash your intended dep of Carver. We will not be in
> attendance unless there is a court order granting you the right to depose
> Carver a second time.
>
> Sincerely,
>
>
> Theresa V. Johnson
> Attorney at Law
> Law Office of Theresa V. Johnson
> 200 East Chicago Ave. Suite 200
> Westmont, IL 60559
> Tel.: (630) 321-1330
> Fax: (630) 321-1185
>
>
>
>
>
>
> _____
>
>
> From: Kevin Duff < <mailto:kduff@rddlaw.net> kduff@rddlaw.net>
> To: THERESA JOHNSON < <mailto:theresavjohnson@prodigy.net>
> theresavjohnson@prodigy.net>
> Cc: Haytham Faraj < <mailto:haytham@puckettfaraj.com>
> haytham@puckettfaraj.com>; John Murray < <mailto:jmurray@rddlaw.net>
> jmurray@rddlaw.net>; Kathleen M. Pritchard <
> <mailto:kpritchard@rddlaw.net>
> kpritchard@rddlaw.net>
> Sent: Tue, February 8, 2011 4:11:07 PM
> Subject: RE: (Cynowa v. CSSS) Notice of Deposition for the Continuation of
> Larry Carver's Evidence Deposition
>
> Theresa,
>
>
>
> I am writing to confirm the Carver deposition on February 17 at noon EST.
> Please advise.
>
>
>
> Kevin
>
>
>
>
>
> P.S. I don't have Peter Bustamante's email address. Could you please
> provide it?
>
>
> _____
>
>
> From: John Murray [mailto:jmurray@rddlaw.net]
> Sent: Monday, January 31, 2011 4:05 PM
> To: 'THERESA JOHNSON'
> Cc: 'Kevin Duff'; 'Haytham Faraj'
> Subject: (Cynowa v. CSSS) Notice of Deposition for the Continuation of
> Larry
> Carver's Evidence Deposition
>
>
>
> Theresa:
>
>
>
> Attached please find a Notice of Deposition for the Continuation of Larry
> Carver's evidence deposition, as well as a copy of the subpoena and rider
> that was served upon Mr. Carver on January 30, 2011. Please see attached.
> Thanks.
>
>
>
>
>
> Regards,
>
>
>
> John E. Murray, Esq.
>
> Associate Attorney
>
> Rachlis Durham Duff & Adler, LLC
>
> 542 South Dearborn Street, Suite 900
>
> Chicago, IL 60605
>
> Office: (312) 733-3950
>
> Direct: (312) 275-0338
>
> Mobile: (810) 824-7197
>
> Fax: (312) 733-3952
>
> Email: <mailto:jmurray@rddlaw.net> <mailto:jmurray@rddlaw.net>
> jmurray@rddlaw.net
>
> Firm website: <http://www.rddlaw.net> <http://www.rddlaw.net>
> www.rddlaw.net
>
>
>
> RACHLIS DURHAM DUFF & ADLER, LLC E-MAIL CONFIDENTIALITY NOTICE
>
> This transmission may be: (1) subject to the Attorney-Client Privilege,
> (2)
> an attorney work product, or (3) strictly confidential. If you are not the
> intended recipient of this message, you may not disclose, print, copy or
> disseminate this information. If you have received this in error, please
> reply and notify the sender (only) and delete the message. Unauthorized
> interception of this e-mail is a violation of federal criminal law.
>
>
>
> n may be: (1) subject to the Attorney-Client Privilege, (2) an attorney
> work
> product, or (3) strictly confidential. If you are not the intended
> recipient
> of this message, you may not disclose, print, copy or disseminate this
> information. If you have received this in error, please reply and notify
> the
> sender (only) and delete the message. Unauthorized interception of this
> e-mail is a violation of federal criminal law.
>
>
>
>
--