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

Case 1:04-cv—01422-Gl\/IS Document 81 Filed 04/20/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JEROME K. HAMILTON, a/k/a :
ELOHIM CHEIKH AHMED, :
Piamarr, l I
: C.A. No. 04-1422 (GMS)
v. :
: JURY TRLAL DEIVIANDED
CATHY L. GUESSFORD, REBECCA :
MCBRIDE, ROBERT F. SNYDER, THOMAS :
L. CARROLL, and STANLEY W. TAYLOR, :
JR.
Defendants
NOTICE OF 30(bI(6) DEPOSTION DUCES TECUM*
TO: Eileen Kelly, Esquire
Department of Justice
820 N. French Street, 6th Floor
Wilmington, DE 19801
PLEASE TAKE NOTICE, that pursuant to Rule 30(b)(6), Federal Rules of Civil
Procedure, the defendants are to designate the person most knowledgeable with how
s medical records are recorded, maintained, and stored for prisoners, including the plaintiff,
and with reference to records created by Prison Health Services, Inc. for a deposition on
Wednesday, April 25, 2007 at 1:00 p.m. in the oftices of Aber, Goldlust, Baker & Over, 702
King Street, Suite 600, Wilmington, DE 19801.
ABER, GOLDLUST, BAKER & OVER
/s/ Gag W. Aber
GARY W. ABER (DSB #754)
702 King Street, Suite 600
P.O. Box 1675
· Wilmington, DE 19899
302-472-4900
DATED: April 20, 2007 Attorney for Plaintiff
*The deponent is to produce all medical records of the plaintiff from January 1, 1999 to the
present, including all records created and/or generated by Prison Health Services, Inc.

Case 1 :04-cv—01422-GIVIS Document 81 Filed 04/20/2007 Page 2 of 2
CERTIFICATE OF SERVICE
The undersigned hereby certities that the attached pleading was tiled via electronic tiling
on April 20, 2007 and was served on the following counsel:
Eileen Kelly, Esquire
Department of Justice
820 N. French Street, 6th Floor
Wilmington, DE 19801
/s/ Melissa A. Chionchio
Melissa A. Chionchio
Secretary to Gary W. Aber, Esquire
2