Free Notice to Take Deposition - District Court of Delaware - Delaware

Case 1:88-cv-00263-SLR Document 362 Filed 08/02/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
NATURAL RESOURCES DEFENSE )
COUNCIL, INC. and DELAWARE )
AUDUBON SOCIETY, )
) Civ. Action No. 88-263-SLR
Plaintiff )
)
v. )
)
TEXACO REFINING AND )
MARKETING, INC., )
)
Defendant. )
)
DEFENDANTS’ NOTICE TO TAKE DEPOSITION
OF DR. ROBERT J. LIVINGSTON
PLEASE TAKE NOTICE that, pursuant to Rule 30 of the Federal Rules
of Civil Procedure, Defendant Texaco Refining and Marketing, Inc., ("Texaco") will take
the oral deposition of Dr. Robert Livingston. The deposition will commence at 8:30 am.
on Thursday, August 9, 2007 and at 8:30am on Friday, August 10, 2007 at the offices of
the Natural Resources Defense Council, 40 West 20th Street, New York, NY 1001 l. You
are invited to attend.
The oral examination will be recorded by stenographic and/or
videographic means, and will be conducted before a notary public or other person
authorized by law to administer oaths. In addition, the deponent is directed to identify,
bring with him, and make available for inspection and copying: 1) all documents
reviewed or utilized by the deponent to prepare for this deposition; and 2) all documents
or writings utilized or relied on by the deponent for purposes of his July 7, 2005
declaration, his October 7, 2005 reply declaration, his July 2005 document entitled

Case 1:88-cv-00263-SLR Document 362 Filed 08/02/2007 Page 2 of 3
"Review of Motiva Study and Independent Analysis of Study Data," or his June 15, 2007
expert repoit, that were not specifically cited in these aforementioned documents.
Momus, NICHOLS, ARSHT & TUNNELL LLP
Richard Allen (#469)
Megan Ward Cascio (#3785)
1201 N. Market Street
P.O. Box 1347
Wilmington, Delaware 19899
(302) 658-9200
Attomeys for Defendant
Texaco Refining and Marketing, Inc.
OF COUNSEL:
WALLACE KH\IG DoM1KE & REISKIN, PLLC
Anthony F. King
Julie M. Domike
John W. Kampman
1050 Thomas Jefferson St., N.W.
Washington, DC 20007
(202) 204-1000
August 2, 2007
2

Case 1:88-cv-00263-SLR Document 362 Filed 08/02/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I, Megan Ward Cascio, hereby certify that on August 2, 2007, I
electronically filed DEFENDANTS’ NOTICE TO TAKE DEPOSITION OF DR.
ROBERT J. LIVINGSTON with the Clerk of Court using CM/ECF, which will send
notification of such filing(s) to the following:
C. Scott Reese, Esquire
Cooch & Taylor
824 N. Market Street, Suite 1000
P.O. Box 1680
Wilmington, DE 19899-1680
I also certify that copies were caused to be served on August 2, 2007 upon
the following in the manner indicated:
BY HAND DELIVERY:
C. Scott Reese, Esquire
Cooch & Taylor
824 N. Market Street, Suite 1000
P.O. Box 1680
Wilmington, DE 19899-1680
BY FEDERAL EXPRESS
Mitchell S. Bemard, Esquire
Nancy S. Marks, Esquire
Amelia Toledo, Esquire
Natural Resources Defense Council
40 West 20m Street
New York, New York 10011
Megan igard Cascio (#3785)
1201 North Market Street
P. O. Box 1347
Wilmington, DE 19899-1347
302-351-9364
[email protected]
Attorneys f0r Defendant