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Haytham: Attached please find the email and regular correspondence as
they relate to interviewing, deposing and/or trial appearances of VA
employees. On January 19, 2011, Robert Vega, counsel for the VA,
responded to Plaintiff’s requests for interviews and depositions and
appearances at trial of several VA employees. The letter is included in
this package. In short, we are mainly concerned about the possibility
that Plaintiff may be able to conduct an evidence deposition of Neil Piper, as Plaintiff
intends to potentially use him to testify that he heard the allegedly
defamatory statements published beyond simply being made by Bill Slater to
Officer Adrowski. However, despite these concerns, Vega notified
Plaintiff that Mr. Piper is located at a different government facility
involving another Office of Regional Counsel, and so basically he left it to
Plaintiff to follow-up with them and make her request as it relates to Piper
with them. I plan to follow-up with Vega to determine if Plaintiff has
communicated with this other Office of Regional Counsel. Vega informed me
that he hasn’t heard from Plaintiff since her January 5, 2011 request
letter. Let us know if you have any additional questions relating to
the attached correspondence. 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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Attachment:
Correspondence between RDDA and VA Counsel and Plaintiff (sent to Haytham 1-26-11).pdf
Description: Adobe PDF document
Attachment:
Email correspondence between RDDA and Va Counsel (sent to Haytham 1-26-11).pdf
Description: Adobe PDF document