UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
KARI (SMITH) PRILLER,
Plaintiff, suiaeoena IN A ctrvxt. case
v.
TOWN OF SMYRNA, et al., Civil Action No. :04-1286 (HF)
Defendant.
to : Records Custodian puces tecum
Kent General Hospital
640 S. State Street
Dover, DE 19901
Cl YOU ARE COMMANDED to appear in the United States District Court at the place,
date, and time specified below to testify in the above case.
peztce oe testnaony couateoon
pete Ann time
E] YOU ARE COMMANDED to appear at the place, date, and time specified below to
testify in the above case.
puree oe oeeosttzron Inte Ann time
M YOU ARE COMMANDED to produce and permit inspection and copying of the
following documents or objects at the place, date, and time specified below (list
documents or objects):
Deponent is to bring with him/her the complete file, including all medical records, reports, documents,
statements, notes, photographs, rape l
12/20/2002.
* Personal appearance is waived if clear, complete and legible copies of the requested records are received in this ofhce
by Tuesday, June 13, 2006.
PLACE DATE AND TIME
Schmittinger & Rodriguez, P.A. ‘:EI'0§O10· 2000
414 s. State Street · am .
Dover, DE 19901
I] YOU ARE COMMANDED to permit inspection of the following premises at the date
and time specified below.
peemtses lezate Ann time
Any organization not a party to this suit that is subpoenaed for the taking of a deposition shall
designate one or more officers, directors, or managing agents, or other persons who consent to testify
on its behalf, and may set forth, for each person designated, the matters on which the person will
testify. -
; Federal Rules of Civil Procedure 30(b) (6)
l Reouesttnc t¤Aety·s nztne, zmoeess Ann euone ntmeee
Schmittinger & Rodriguez, P.A. (302) 674-0140
414 S. State Street
Dover, DE 19901
tssu t;=A.tztY·s stcn one Ann titre (inet te te Attoeney mite —
eo ztnttee oe me · II
{ \ · (V May 31, 2006
1 /.. gr*W7$\ Af
Att r y for Plaintiff — ·
Case 1:04-cv-01286-JJF Document 67-2 Filed 06/01/2006 Page 2 of 2
I PROOF OF SERVICE l
SERVED DATE PLACE
SERVED ON (PRINT NAME) ' MANNER OF SERVICE
SERVED BY (PRINT NAME) TITLE
` DECLARATION OF SERVER I
I declare under penalty of perjury under the laws of the State of Delaware that the
foregoing information contained in the Proof of Service is true and correct.
Executed on
DATE SIGNATURE OF SERVER
ADDRESS OF SERVER
Rule 45, Federal Rulgs of eivil transacts business in person, except that,
_ subject to the provisions of clause
Pr¤¤¤d¤¢¤· Parts C & 1D' C(3)(b)(iii) of this Rule such a person may in
_ _ order to attend trial be commanded to travel
(C) Pr°tsst1°n °t Psrssns Sublsct t° from any such place within the state in which
subpoenas. _ the trial is held or
(1) A party or an attorney responsible (iii) requires disoiosure of
ts? the lssussss and ssfvlcs Ot s subPOs¤s_ privileged or other protected matter and no
shall take reasonable steps to avoid imposing exception or waiver enpliesl or
undue burden or expense on a person subject to (iv) subjects e person to undue
that subpoena. The Court on behalf of which burden_
the subpoena was issued shall enforce this duty (B) If e subpoena
and impose upon the party or attorney in breach (i) requires disoiosure of e rrede
ef thls duty an sPPtsPt}sts ssnctlsnl whlqh msY secret or other confidential research,
1¤Cl¤ds· but is not limited ts: lsst sstnlngs development, or commercial information, or
and a reasonable attorney's fee. (ii) requires disclosure of en
(2) _ {A) A Pstssn Csmmsnssd ts Ptssucs unretained expert's opinion or information not
and Pstmlt lnspsstlsn and CGPYIHQ Ot dsslgmstsd describing specific events or occurrences in
P°sks· Pspstsl dsssmsnts Ot tsnglbls thln9s_OY dispute and resulting from the expert's study
inspection of premises need not appear in made not er the request of eny perry, or
person at the place of production or inspection (iii) requires e person who is nor e
unless commanded to appear for d€DOSiCi01'l, party 0;: an Qfficéf gf a party 130 incur
hssflng st tYlsl· _ substantial expense to travel more than 100
_ (B) sublsct t0 Psfsgfsph (dll?} Ot miles to attend trial, the Court may, to
th1s_tu}s» s Pstsss ¤¤mm¤¤Qed ts Ptssuss and protect a person subject to or affected by the
Psfmlt lnspsstlsn ssd C0PYl¤9 msY· within 14 subpoena, quash or modify the subpoena or if
days efver S¤>liv;<=¤ ¤f the S¤¥>z=>¤¤¤¤_¤>¤ b¤f¤re the party in whose semis the subpoena is
the time specified for compliance if such time issued shows e subsrenriei need for the
ls lsss than 14 dsYs sttst sstvlssr sstvs upsn testimony or material that cannot be otherwise
thé P¤ftY 0¥ stt0¥¤sY dsslgnstsd In the met without undue hardship and assures that the
subpoena written objection to 1H§P€CtlOU Of person to whom the subpoena is addressed will
‘ CGPYIEQ st snY st B11 °t_ths dsslgnstsd _ _ be reasonably compensated, the Court may order
materials Of of the QIQHIILSES. If Ob]€ClZ101’l ILS appearance ey pjygdugtjgn Only upon specific
made, the party serving the subpoena shall not oondirions_
be entitled to inspect and copy the materials
or inspect the premises except pursuant to an (d) Duties in Responding to subpoena.
order of the Court by which the subpoena was (1) A person responding to a subpoena to
issued. If objection has been made, the party produce documents shall produce them as they
serving the subpoena may, upon notice to the are kept in the usual course of business or
R person commanded to produce, move at any time shall organize and label them to correspond
i for an order to compel the production. Such an with the categories in the demand.
i order to compel production shall protect any (2) when information subject to a subpoena
\ person who is not a party or an officer of a is withheld on a claim that it is privileged or
Â¥ party from significant expense resulting from subject to protection as trial preparation
the inspection and copying commanded. materials, the claim shall be made expressly
(3) (A) On timely motion, the Court and shall be supported by a description of the
shall by which the subpoena was issued quash or nature of the documents, communications, or
modify the subpoena if it things not produced that is sufficient to
(i) fails to allow reasonable time enable the demanding party to contest the
for compliance, claim.
(ii) requires a person who is not a
party or an officer of a party to travel to a
place more than 100 miles from the place where
that person resides is employed or regularly
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