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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] 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] 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] Kevin, Sincerely,
From: Kevin
Duff <kduff@rddlaw.net> 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] 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 Office: (312) 733-3950 Direct: (312) 275-0338 Fax: (312) 733-3952 Email: jmurray@rddlaw.net Firm website: www.rddlaw.net RACHLIS
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