Free Memorandum in Opposition - District Court of Delaware - Delaware

Case 1 :06-cv—00027-SLR Document 44-2 Filed 03/15/2007 Page1 012
EXHIBIT “A"

Case 1 :06-cv—00027-SLR Document 44-2 Filed 03/15/2007 Page 2 of 2
Fauvre, Lon L. ._.1 E, I
From: Fauvie, Lori L. I
Sent: Friday, February 02, 2007 5:05 PM I
To: Jason Ehrenberg '“’ `“"‘ ‘i""“‘“““‘““"’“‘ ;
Cc: Campbell, David A. *
Subject: Paula Pagonakis I
Dear Jason:
I write regarding the depositions you requested in the above-referenced matter. Our 30(b)(6) witness, Rosie Rock, is
available on February 22, 2007 at 1 p.m. for her deposition. Ms. Rock is located in Columbus, Ohio and, based on your E
correspondence, it is our understanding that you will take her deposition via telephone. I will provide you with the phone Q
number for Ms. Rock's deposition closer to the date. Would you like us to secure a court reporter? How long do you i
anticipate Ms. Rock's deposition lasting?
I will provide you with Ms. O'Neill's (Zapp) availability for her deposition the beginning of next week.
Additionally, please provide us with Plaintiffs availability for her continued deposition (which we agreed upon during her I
deposition in November). I
Thank you,
Lori Fauvie
Lori L. Fauvie
Vorys, Sater, Seymour and Pease LLP I
1375 East Ninth Street
2100 One Cleveland Center i
Cleveland, Ohio 44114-1724 _ I
Telephone: 216/479-6141
Facsimile: 216/937-3759 '
[email protected] I
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