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

Case 1 :04-cv-01306-GIVIS Document 40-2 Filed O9/26/2005 Page 1 of 2
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 in preparation for your 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, questionnaires, 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 tecrun are claimed as "privileged," it should be brought to the
deposition for identification).
4. Copies of all books, records, translations, articles, writing, publications,
correspondence, notes, documents or any other written materials or literature upon
which you rely or will rely or have in the past relied 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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Case 1 :04-cv-01306-GIVIS Document 40-2 Filed O9/26/2005 Page 2 of 2
6. A list of or copies of any writing, publication, document, report, correspondence,
article, book, notes and/or material or literature you relied on or may rely on to
support your expected testimony or that you used for preparation of your report or
your testimony in this lawsuit.
7. Copies of any and all documents and correspondence between you and Kolsby,
Gordon, Robin, Shore & Bezar and all documents sent to you by Kolsby, Gordon,
Robin, Shore & Bezar.
8. All reports or documents you prepared containing your expected testimony,
including all draft reports.
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