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I fashioned a 30b6 notice to read: ....Defendant shall designate to testify on the following
matters one or more officers directors managing agents, or other persons who
consent to testify on its behalf: HERE's the AWESOME PART (Not an original idea) "All facts or opinions bearing on the accuracy or
inaccuracy of defendant's denials in its Answer to the Complaint, of the
averments of (insert paragraphs here) of the Complaint and the identity of and
or content of all documents constituting or memorializing each such fact or
opinion." My point is to get them admit that these denials are
contested facts on important issues to oppose a SJM that I can smell coming! I get an email back stating that requesting that I get
someone to support their denials is "vague, overbroad etc" and they
cite a case In re
Independent Service Organizations Antitrust Litigation".... Haytham Faraj, Esq. PUCKETT & FARAJ, PC _______________________ WASHINGTON DC METRO 1800 Diagonal Road Suite 210 Alexandria, VA 22314 703-706-0442 Phone DETROIT METRO 6200 Schaefer Road Suite 202 Dearborn, MI 48126 313-457-1390 Phone 202-280-1039 Fax The information
contained in this electronic message is confidential, and is intended for the
use of the individual or entity named above. If you are not the intended
recipient of this message, you are hereby notified that any use, distribution,
copying of disclosure of this communication is strictly prohibited. If you
received this communication in error, please notify Puckett & Faraj, P.C.
at 888-970-0005 or via a return the e-mail to sender. You are
required to purge this E-mail immediately without reading or making any copy or
distribution. |