Case 1:00-cv-03717-AMD Document 150 Filed 03/23/2005 Page 1 of 4 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND IN RE: PERSONAL INJURY * ASBESTOS LITIGATION (No. VI) * * * * * * * * * * * * * * This Document Related To: * Law Offices of Peter G. Angelos * Transferred to United States District Court for the * Civil Action No. MDL 875 Eastern District of Pennsylvania * Linkenhoker, C.A. No. 00-3717 * * * * * * * * * * * * * * NOTICE TO TAKE DEPOSITION DUCES TECUM TO: All Counsel of Record FROM: John Crane Inc. You are hereby notified that John Crane Inc. will, in accordance with the Federal Rules of Civil Procedure, take the deposition on oral examination of the following named person on the date and time indicated below, before a Notary Public, or any other duly qualified officer who may be selected to act in his or her place, at the Millennium Hotel Durham, 2800 Campus Walk Avenue, Durham, NC, USA 27705-4479, to be continued from day to day until completed: NAME DATE AND TIME Dr. Victor Roggli Wednesday, March 30, 2005 2:00 p.m. The deponent is requested to bring with him to the deposition the documents that are listed on the attached Schedule A. Case 1:00-cv-03717-AMD Document 150 Filed 03/23/2005 Page 2 of 4 ROBINSON WOOLSON, P.A. By:/s/ Genevieve Marshall Deborah L. Robinson Federal Bar No. 02201 Peter A. Woolson Federal Bar No. 04448 Genevieve Marshall Federal Bar No. 27591 217 East Redwood Street, Suite 1500 Baltimore, Maryland 21202 410.625.0000 Attorneys for Defendant, John Crane Inc. Case 1:00-cv-03717-AMD Document 150 Filed 03/23/2005 Page 3 of 4 SCHEDULE A As used herein, the words "documents, records and/or files" mean writings, pictures, drawings, or diagrams of any nature, whether transcribed by hand or some mechanical, electronic, photographic or other means, as well as recordings and all other sound reproductions, oral statements and/or conversations, by whatever means made, that are in the deponent's possession, custody or control, or in the possession, custody or control of the deponent's agents, representatives or attorneys. If a document has been prepared in multiple drafts or additional copies have been made, and the draft or copies are not identical, each non-identical draft or copy is to be considered a separate document and should be brought to the deposition. DOCUMENTS A. All writings, photographs, letters, correspondence, tape recordings, movies, moving pictures, slides, sketches, blue prints, drawings, specifications, invoices, labels, instrument tapes, slides, charts, x-rays, reports and all other documents or writings of every sort or description that the deponent has seen, reviewed or to which he has referred in any way receiving information about the named plaintiff, and/or in evaluation and/or reviewing the named plaintiff’s medical condition. B. All photographs, drawings, sketches, pictures, diagrams, movies, moving pictures, and all other documents of every kind or description, made by or for the deponent with reference to the Plaintiff’s case. C. All demonstrative exhibits of every character, sort and description that the deponent expects to use and/or make use of or otherwise refer to during his testimony at the trial of this matter. D. If the deponent expects to express any opinion concerning the existence of an asbestos related malignancy (i.e. cancer of any sort or mesthelioma) existing in the names plaintiff, then all documents, records, x-rays, charts, correspondence, reports, instrument tapes, slides, tissue specimens, and every other document and/or tangible thing of every kind or description which the deponent has reviewed, seen, and/or to which the deponent has referred in any way in receiving information about this condition and/or in considering, testing for and/or reaching a conclusion concerning such malignancy. E. All reports, notes, records, x-rays, charts, graphs, tapes, instrument recordings, slides, tissue specimens, photographs and every other document or description of every sort or description generated by the deponent or at the deponent’s request or direction or supervision relating to every physical examination, evaluation and/or tests of the named plaintiff that the deponent has conducted. Case 1:00-cv-03717-AMD Document 150 Filed 03/23/2005 Page 4 of 4 F. All reports, notes, records, x-rays, charts, graphs, tapes, instrument recordings, slides, tissue specimens, photographs and every other document or description of every sort or description generated by the deponent or at the deponent’s request or direction or supervision relating to every physical examination of the named plaintiff that the deponent has observed and/or requested and/or watched and/or directed and/or supervised. G. If the deponent expects to express an opinion at trial concerning the cause(s) of death of the named plaintiff, all medical records, charts, slides, test results, instrument tapes, instrument records, photographs, correspondence, notes, other visual depictions, medical articles, tissue specimens and/or every other document of every sort or description that the deponent used, received, reviewed, has seen and/or to which the deponent intends to make reference in any way reaching or expressing such conclusion. H. A current Curriculum Vitae. I. A current listing of all publications and works in progress. J. A listing of all articles, treaties, and/or references to which the deponent expects to make reference during this trial testimony in this case. K. A listing of all cases in which the deponent has testifies in depositions and trials, including date(s) and identify parties, attorneys, court, and subject matter.
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