Subject: RE: Mitchell v. Wachovia ‘ .
Date: Tue, 22 Apr 2008 10:22:01 -0500
From: "Mishra, Devjani"
To: "Steve Mones"
Cc:
"Williams, Tara"
l—li Steve,
Let’s go with May 7 for the deposition, subject to the pending motion. When do you expect to provide the exhibits
from last week's deposition and the documents requested during the deposition?
As to Amini and Oonsalo, we will be producing them voluntarily. Given that both sides are calling many of the
same witnesses, can we agree to waive the normal limits on the scope of cross tor witnesses called by both
sides, so that each witness only needs to appear once?
Devjani Mishra
Seyfaith Shaw LLP
620 Eighth Avenue
New York, NY 10018-1405
212-218-5510 phone
917-344-1223 fax
[email protected]
Please consider the environment before printing this message. · .
——--— Original Message ——·—·
From: Steve Mones [mailto:[email protected]]
Sent: Friday, April 18, 2008 11:42 AM .
To: Mishra, Devjani
Cc: [email protected]
Subject: Mitchell v. Wachovia
Dear Devjani-
Would you be available during the afternoon of either May 7 or May 8 for a videotaped
trial deposition of Dr. Minnehan? That would be about 2 weeks after the surgery, and
we understand that he would be up to testifying at that point. Given that the surgery is
next Thursday, a trial deposition beforehand does not appear feasible.
On another note, we expect to call Ms. Amini and Mr. Consalo as witnesses at trial. Both
are current Wachovia employees, but not parties. Will you agree to produce them at trial
voluntarily (as with the discovery depositions), or must I have subpoenas issued for their
attendance?
Thank you for your consideration of these matters.
Steve
Steven F. Mones
Biggs and Battaglia
921 N. Orange Street
P.O. Box 1489
Wilmington, DE 19899-1489
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