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RE: (Cynowa v. CSSS) Notice of Deposition for the Continuation of Larry Carver's Evidence Deposition



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]
Sent: Wednesday, February 09, 2011 2:25 PM
To: 'Kevin Duff'
Cc: 'Kathleen M. Pritchard'
Subject: RE: (Cynowa v. CSSS) Notice of Deposition for the Continuation of Larry Carver's Evidence Deposition

 

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]
Sent: Wednesday, February 09, 2011 2:57 PM
To: 'Haytham Faraj'
Cc: 'Kathleen M. Pritchard'
Subject: RE: (Cynowa v. CSSS) Notice of Deposition for the Continuation of Larry Carver's Evidence Deposition

 

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]
Sent: Tuesday, February 08, 2011 4:23 PM
To: 'Kevin Duff'
Subject: RE: (Cynowa v. CSSS) Notice of Deposition for the Continuation of Larry Carver's Evidence Deposition

 

I hadn’t thought about this.  Glad you thought to confirm.

 

From: Kevin Duff [mailto:kduff@rddlaw.net]
Sent: Tuesday, February 08, 2011 5:11 PM
To: 'THERESA JOHNSON'
Cc: 'Haytham Faraj'; 'John Murray'; 'Kathleen M. Pritchard'
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: jmurray@rddlaw.net

Firm website: www.rddlaw.net

 

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