Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

30(b)<6)Ghwem1ev-00644-CFD Document 137-2 Filed 1 1/15/2005 Page 1 ogalgc 1 OH
Peter Nolin
From: William Tong [[email protected]]
Sent: Thursday, October 20, 2005 11:00 Al\/l
To: Peter Nolin; l\/lario DiNatale- Silver Golub & Teitell
Cc: James Hawkins
Subject: 30(b)(6) Deposition
Peter, l\/lario:
Unfortunately, we need to reschedule the 30(b)(6) deposition of AIGTS scheduled for next week on October 25th
and 27th. Jim has has to attend to some medical issues and needs to see doctors again next Tuesday the 25th.
Further, while our client is working diligently to prepare for the 30(b)(8) depositions, the listed topics of
examination are very extensive. Specifically, there are sixty-six (66) topics for examination detailed in the Ryan
Plaintiffs' 30(b)(6) notice (not including the Gwynn Plaintiffs' 30(b)(6) notice regarding document collection), and
the witness simply needs more time to review and analyze this information in order to provide meaningful
testimony consistent with Rule 30(b)(6).
We recognize that November is a difficult month for scheduling. The witness is available on November 18 and
28, as well as December 1, 2, 8, and 9. We understand the November 18 may not be good for Mario, but I
included that date just in case.
Please let us know if any of these dates work for you. Thank you for your consideration.
William
E A
11/ 14/2005