Do you know what day you would like to depose Larry Carver? I need to get back to the attorney from Rachlis Durham Duff & Adler, LLC so they can finish up the Illinois portion of the process.
Thanks,
Bethany
Bethany N. Trujillo
Office Manager/Legal Secretary
1800 Diagonal Road, Suite 210
Alexandria, Va. 22314
bethany@puckettfaraj.com
(703) 706-9566 Phone
(202) 318-7652 Fax
DC × CA × MI × VA
www.PuckettFaraj.com
Practice is limited to matters and proceedings before special courts - federal courts - agencies. Confidentiality / Privilege Notice: This transmission, including attachments, is intended solely for the use of the designated recipient(s). This transmission may contain information that is confidential and/or privileged or otherwise protected from disclosure. The use or disclosure of the information contained in this transmission for any purpose other than that intended by its transmittal is strictly prohibited. If you are not an intended recipient of this transmission, please immediately destroy all copies received and notify the sender.
From: John Murray [mailto:jmurray@rddlaw.net]
Sent: Tuesday, March 01, 2011 4:38 PM
To: 'Bethany Trujillo'
Cc: 'Haytham'; kduff@rddlaw.net
Subject: RE: (Cynowa v. CSSS) Subpoena for Larry Carver
Thanks Bethany. We are working with the clerkâs office here in Chicago to obtain the written statement concerning reciprocity between Illinois and Virginia for purposes of discovery, but we need to know from Haytham what date we should put on the Illinois subpoena that we will send to you for filing with the Virginia court. This date needs to be sufficiently far in advance in order to provide for reasonable notice and adequate time for service upon Mr. Carver. Let me know what date works as soon as you can. 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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From: Bethany Trujillo [mailto:bethany@puckettfaraj.com]
Sent: Tuesday, March 01, 2011 2:14 PM
To: jmurray@rddlaw.net
Cc: 'Haytham'; kduff@rddlaw.net
Subject: (Cynowa v. CSSS) Subpoena for Larry Carver
Mr. Murray,
Mr. Faraj asked me to send this information to you regarding what we will need to subpoena Larry Carver in Alexandria, VA. Please let me know if you need any further information.
 8.01-412.10. Issuance of subpoena.
A. To request the issuance of a subpoena under this article, a party shall submit to the clerk of court in the circuit in which discovery is sought to be conducted in the Commonwealth (i) a foreign subpoena and (ii) a written statement that the law of the foreign jurisdiction grants reciprocal privileges to citizens of the Commonwealth for taking discovery in the jurisdiction that issued the foreign subpoena.
B. When a party submits a foreign subpoena to a clerk of court in the Commonwealth, the clerk, in accordance with that court's procedure, shall promptly issue a subpoena for service upon the person to which the foreign subpoena is directed.
C. A subpoena under subsection B shall:
1. Incorporate the terms used in the foreign subpoena; and
2. Contain or be accompanied by the names, addresses, and telephone numbers of all counsel of record in the proceeding to which the subpoena relates and of any party not represented by counsel.
D. A request for the issuance of a subpoena under this article does not constitute an appearance in the courts of the Commonwealth, and no civil action need be filed in the circuit court of the Commonwealth.
E. The provisions of this article shall be in addition to other procedures authorized in the Code of Virginia and the rules of court for obtaining discovery.
(2009, c. 701.)
Bethany N. Trujillo
Office Manager/Legal Secretary
1800 Diagonal Road, Suite 210
Alexandria, Va. 22314
bethany@puckettfaraj.com
(703) 706-9566 Phone
(202) 318-7652 Fax
DC × CA × MI × VA
www.PuckettFaraj.com
Practice is limited to matters and proceedings before special courts - federal courts - agencies. Confidentiality / Privilege Notice: This transmission, including attachments, is intended solely for the use of the designated recipient(s). This transmission may contain information that is confidential and/or privileged or otherwise protected from disclosure. The use or disclosure of the information contained in this transmission for any purpose other than that intended by its transmittal is strictly prohibited. If you are not an intended recipient of this transmission, please immediately destroy all copies received and notify the sender.