Thanks John, Do you have any contact information on Mr. Piper? Nothing prevents us from asking him questions without notifying his local counsel, if we think that it benefits us. Do you know what he’ll say? Mr. Piper is not a represented party. Government counsel represent their own agencies and not members of their agencies. I go through this all the time. In any event, the VA is not a party to the action. From: John Murray [mailto:jmurray@rddlaw.net] 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 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. |