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 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 RACHLIS DURHAM DUFF & ADLER, LLC E-MAIL CONFIDENTIALITY NOTICE This transmission may be: (1) subject to the Attorney-Client Privilege, (2) an attorney work product, or (3) strictly confidential. If you are not the intended recipient of this message, you may not disclose, print, copy or disseminate this information. If you have received this in error, please reply and notify the sender (only) and delete the message. Unauthorized interception of this e-mail is a violation of federal criminal law. |