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

Case 1 :04-cv-01306-GIVIS Document 45-2 Filed O9/30/2005 Page 1 of 1
EXHIBIT A
All documents, records and materials relating to the plaintiff in the above-captioned case
including, but not limited to, the following, shall be produced to defendants’ counsel 2 days
before the deposition:
1. All documents reviewed by deponent in preparation for his testimony in this case.
2. All documents, records and materials relating to plaintiff which you have
reviewed at any time including, but not limited to, correspondence, statements,
reports, handwritten notes, medical and hospital records, deposition transcripts,
and any other such document, record or tangible material relating this matter.
3. Copies of all materials and documents of any kind which you have received
concerning this case including, but not limited to, all records, reports,
correspondence and memorandum (if correspondence or documents requested in
this duces tecum are claimed as "privileged,” it should be brought to the
deposition for identification).
4. Copies of all books, records, articles, writing, publications, correspondence, notes,
documents or any other written materials or literature upon which you rely or will
rely on in preparation for presentation of your testimony and/or report in this
particular case.
5. A list of all articles, textbooks or other sources information or data upon which
you base the opinions you expect to give.
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