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

- Case 1 :04-cv-01306-GIVIS Document 28-2 Filed O3/24/2005 Page 1 of 1 I
- EXHIBIT A
` _ Deponent shall bring with him the following:
. - - I 1. All documents relating to any conversations with any defendant or any employee of
. ‘ ` any defendant. ·
_ 2. Any and all documents, claims or records of any matter relating to the litigation or .
- Catherine Laag.
- 3. Any and all diaries or other types of documents recording the daily care of Catherine
Laag.
4.- Any and all documents, receipts, invoices and the like evidencing the costs of
_ extended hospital admissions and medical treatment which you claim would have
‘ ` been avoided but for the present condition of Catherine Laag.
. _ 5. Any and all documents, receipts, invoices and the like evidencing costs incurred in 1 *
the care of Catherine Laag. ‘
‘ 6. Any and all documents or reports evidencing the future costs that may be incurred in .
the care of Catherine Laag.
7. Any and all documents supporting your claim for loss of Catherine Laag’s earning
capacity.
- w1.1; 103301.01 _