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March 10 is the date out reply is due for
our summary judgment motion, but we’ll just need to account for that.
I’ll offer it with language that keeps the current date in case we don’t
get agreement on March 10 or 11. From: Haytham Faraj
[mailto:haytham@puckettfaraj.com] I am available March
10 and 11. From: Kevin Duff
[mailto:kduff@rddlaw.net] Haytham, I want to appear reasonable in case we end
up in court on a motion to compel this deposition or a motion for a protective
order by them. If the track record with Theresa is any indication,
that’s where we are headed. The fact that you are unavailable
isn’t going to help, because they can readily say that I should be able
to take the deposition. Still, I want to do everything we can to
accommodate your schedule because Lisa wants you to take this deposition.
Do you have any alternate dates available between now and mid-March
(irrespective of my availability)? Kevin From: Haytham Faraj
[mailto:haytham@puckettfaraj.com] Kevin, I am unavailable on
any of those dates. I have to fly out to CA on the evening of the 17th
to litigate some pretrial motions, followed by an 8-12 day trial. From: Kevin Duff
[mailto:kduff@rddlaw.net] Haytham, You should have seen Theresa
Johnson’s response by now. I suggest we show a willingness to
reschedule to another date between now and the end of the first week of March,
provided we are available, and we are able to obtain confirmation that the
witness is available, and it would not result in undue delay. Otherwise,
we should keep the current date. To that end, please let me know which the
following dates would work for you (all of which currently work for me): February 18 or 28 March 1, 2 or 3 Kevin From: Haytham Faraj
[mailto:haytham@puckettfaraj.com] I hadn’t
thought about this. Glad you thought to confirm. From: Kevin Duff
[mailto: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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