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

Case 1:04-cv-01339-SLR Document 104 Filed 11/20/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
IN RE ALH HOLDINGS, LLC ) Consol. C.A. N0. 04-1339 — SLR
)
NOTICE OF DEPOSITION OF SELK,LLC
TO: Sean J. Bellew
Cozen O’Connor
1201 North Market Street, Suite 1400
Wilmington, DE 19801
PLEASE TAKE NOTICE that, pursuant to Fed. R. Civ. P. 30(b)(6), counsel for
plaintiffs shall take the deposition by oral examination of SELK, LLC by the person most
knowledgeable regarding the topics set forth on Exhibit A on November 28, 2006 beginning at
9:00 a.m. at the offices of Morris, Nichols, Arsht & Tunnell LLP, 1201 North Market Street,
Wilmington, Delaware 19801 and continuing from day to day until completed. The deposition
will be recorded by stenographic means before a Notary Public or other officer authorized to
administer oaths. You are invited to attend and cross examine.
MORRIS, NICHOLS, ARSHT & TUNNELL LLP
A. Gilchrist Sparks, III (#467)
S. Mark Hurd (#3297)
Samuel T. Hirzel (#4415)
1201 N. Market Street
P.O. Box 1347
Wilmington, DE 19899-1347
Telephone: (302) 658-9200
Attorneys for Plaint%s and Counterclaim
Defendants Shamrock Holdings of Calfornia,
Inc., Shamrock Capital Advisors, Inc., Eugene I
Krieger, George J Buchler and Bruce J Stein,
November 20, 2006 and Third-Pnrzy Defendant ALH Holdings, LLC

Case 1:04-cv-01339-SLR Document 104 Filed 11/20/2006 Page 2 of 2
EXHIBIT A
1. The facts with respect to the Claims, Counterclaims and Defenses in this litigation.
2. The decision by SELK, LLC ("SELK") to invest in ALH Holdings, LLC or any of its
affiliates ("ALH"), including any communications regarding such investment, and
SELK’s investment horizons and knowledge of other investors’ investment horizons.
3. SELK’s Capital Account, Unrecovered Class B Capital and Membership Interest in
ALH.
4. The facts with respect to any capital contributions to ALH by the Class E Member, all
payments made with respect to that portion of the American Debt owed to Eugene
Elovic or that portion of the American Debt owed to Arbor National Commercial
Mortgage, and SELK’s perfomiance or non-perforrnance of its guarantee of the Class
E Capital Contribution.