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					      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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