Free Response - District Court of Connecticut - Connecticut

“ ' Case 3:03-cv-00978FD Document 21-3 Filed 068/2005 Page 1 of 3
Kone, Carolyn
From; John R. Wiiiiams §[email protected]]
Sent; Wednesday, May 25, 2005 8:iQ F’l\/1
To: Kona, Carolyn
Subject: Re: Wendell Harp' s deposition
Motion for
totective Order.p<;l..
I will check with Wendell tomorrow if I can about dates. Don’t understand
how I could have screwed up the attachment, but here’s another try.
A ~~—~ Original Message ——e—v
From: ”Kone, Carolyn" ·
To; "‘John R. Williams’"
sent; wednesday, May 25, 2005 7:26 QM
Subject: RE: Wendell Harp' s deposition
s John — attached were two copies of a letter from you to me and no motion
> for .
s protective order. Could you please resend the motion for protective order.
s Also let me know about the continued date for the deposition. Thank you.
> Carolyn
>
s ~~~~ -Original Message ~~~—~
> From: John R. williams {mailto [email protected]
s Sent: Wednesday, May 25, 2005 6:58 PM
> Toe Kone, Carolyn
s Cc: Rodger Lehr
> Subject: Re: Wendell Harp' s deposition
>
I
s Please see attached.
s ————— Original Message W~~——
s From; "Kone, Carolyn" s To; "'John R. Williams*"
s Sent; Wednesday, May 25, 2005 5:49 QM
> Subject: RE: Wendell Harp* s deposition
>
>
ss John e Thank you for being accommodating about Memorial Day. Eefore I
>> call
>> the court reporter off, can you please give me the date that you and
ss Wendell
ss are available in June. and I will renotice the deposition for then. With
ss respect to the documents, I am not sure that I have all of them and don't
ss want any surprises. Please have Wendell produce the documents requested
>> EVER
ss if he thinks that I might have them. Also, I need the tax returns because
ss they are relevant to the issue of damages. I will certainly agree to a
ss reasonable protective order. Carolyn
>>
ss ————— Original Message ——~— W
ss From: John R. Williams {mailto:[email protected]]
ss Sent: Wednesday, May 25, 2005 2:21 PM
ss To: Kone, Carolyn
>> Subject: Re: Wendell Harp' s deposition
>>
>>
ss I spoke to Wendell about the documents. He says you have almost all of
ss them. There a few, like tax returns, that we will not produce
1

' ` Case 3:03-cv-0097wFD Document 21 -3 Filed O6w2005 Page 2 of 3
as voluntarily.
ss eee~M original Message »eee—
>> From: “Kone, Carolyn"
>> To: "'John R. Williams’"
>> Sent: Tuesday, Mdy 24, EGGS 12:01 PM
>> Subject: RE: Wendell Harp' s deposition
>>
>>
>>>I don't know if I can get a court reporter for Monday. I will check. What
>>> about the documents? Carolyn
>>>·
>>> ~~»——Original Message ~~~~—
>>> From: John R. Williams [mailto:[email protected]}
>>> Sent; Monday, May 23, 2005 5:42 PM
>>> TO: Kone, C&IOlyH
>>> Subject: Re; Wendell Harp' s deposition
>>>
>>>
>>> You told me you were scheduling the deposition tor Friday and MONDAY.
>>> We
>>> are not available on Tuesday, which is the first court day of the week.
>>> we
>>> WILL be available Monday if you don*t finish on Friday.
>>> veee» Original Message ————~
>>> From: "Kone, Carolyn"
>>> To; "John R. Williams (E—mail)"
>>> Sent: NOHGQY, May 23, ZGOE 3:14 PM
>>> Subject: Wendell Harp’ s deposition
>>>
>>>
>>>>I am just writing to confirm that Wendell Harp*s deposition will go
>>>>forward
>>>> this Friday, May 27th and Tuesday, May Bist as noticed. Also, it would
>>>> probably make the deposition go a lot faster if I could look at the
>>>> materials requested in his notice of deposition before Friday. Please
>>>> let
>>>> me
>>>> know. Thank you. Carolyn
>>>>
>>>> Carolyn Kone
>>>>
>>>> Brenner,5altzman & Wallman LLP
>>>> 27l Whitney Ave.
>>>> New Haven, Connecticut 06511
>>>>
>>>>
>>>> Email .... : CKOH€@BSWLAW.COm
>>>> TelEphOH€: {203}772·26OO
>>>> Facsimile: {203l562·2098
>`D>>
>>>>
>>>> The information contained in this communication may be Confidential, is
>>>> intended only for the use of the recipient named above, and may be
>>>> legally
>>>> privileged. If you are not the intended recipient, you are hereby
>>>> Hotified
>>>> that any dissemination, distribution, or copying of this communication,
>>>> Of
>>>> any of its contents, is strictly prohibited. Nothing in this
>>>> COmmuRiC&CiOH
>>>> is intended to constitute a waiver of any privilege or the
>>>> confidentiality
>>>> of this message. lf you have received this communication in error,
>>>> please
>>>> notify the sender immediately by return e—mail or telephone and delete
>>>> the
>>>> original message and any copy of it from your computer system.
2

‘ I' Case 3:03-cv-0097wFD Document 21 -3 Filed 06%/2005 Page 3 of 3
>>>> ?nenk you.
>>>>
ZZ?
3