Thanks. This is good. The alternative is to subpoena him to the trial which means he’ll miss 4-5 days. From: Kevin Duff [mailto:kduff@rddlaw.net] FYI – see below. Peter Bustamante gave me Carver’s phone number today and I spoke with Carver this afternoon. Carver said he is in New Mexico for a funeral. He complained to me that his deposition was already taken and that he would need to miss work to be deposed again. He wanted to know what we planned to ask him. I told him that we are willing to reasonably accommodate his schedule within the limitations of our schedule. I also declined to tell him what we would ask him, except to say that it would be on matters related to the lawsuit that we deem necessary. We’ll follow up with him on Monday. From: Kevin Duff [mailto:kduff@rddlaw.net] Mr. Carver, This confirms that your deposition will not be going forward this Thursday, February 17, 2011. As I mentioned on the telephone this afternoon, we would prefer to find a mutually agreeable date to reschedule your deposition. March 10 and March 11 are dates that work for us. I understand from our conversation that you are away from home until Monday and did not bring your calendar with you. I will follow up with you on Monday. In the meantime, if you can confirm that you are available either March 10 or 11, please do so by responding to this email. Kevin Kevin B. Duff Rachlis Durham Duff & Adler, LLC 542 South Dearborn Street, Suite 900 Chicago, Illinois 60605 phone: 312-733-3390 fax: 312-733-3952 |