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

Case 1 :04-cv-01286-JJF Document 67 Filed 06/O1/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
KARI M. (SMITH) PRILLER, *
>l<
Plaintiff, *
it
v. *
* C.A. No. 04-1286 (ITF)
TOWN OF SMYRNA; DAVID S. *
HUGG, III, individually and in *
his official capacity as Town Manager; *
BEVERLY A. I—IIRT, individually *
and in her official capacity as * TRIAL BY JURY DEMANDED _
Director of the Smyrna Public *
Library; and HARVEY LEGGETT, *
individually and in his official capacity as *
Supervisor of Streets/Foreman *
of Public Works, *
vi
Defendants. *
NOTICE OF DEPOSITION
TO: Bruce C. Herron, Esq.
Akin & Herron, P.A.
1220 N. Market Street, #300
P.O. Box 25047
Wilmington, DE 19899
PLEASE TAKE NOTICE that the undersigned attorney will take the deposition
of the Records Custodian for Bayhealth Medical Center, Inc., Kent General Hospital
campus (*), on Friday, June 16, 2006, at 11:00 a.m. at the offices of Schmittinger and Rodriguez,
P.A., 414 South State Street, Dover, Delaware 19901.
SAID CUSTODIAN IS COMMANDED to produce and permit inspection and
copying of the following documents or objects at the place, date, and time specitied above:
i The complete tile, including all medical records, reports, documents, statements,

Case 1:04-cv-01286-JJF Document 67 Filed 06/O1/2006 Page 2 of 2
notes, photographs, rape kit(s), records by SANE nurses, and any other
. information relating to all care, treatment and evaluations of Kari M. Smith that
Bayhealth Medical Center, Inc. provided on or about 12/20/2002.
* SUBPOENA DUCES TECUM: Personal appearance is waived if clear,
complete and legible copies of the requested records are received in this office by Tuesday, June
13, 2006.
SCHMITT ER AND RODRIGUEZ, P.A.
BY: i / I
.6: LLIAM D. FLE ER, JR. p
Bar ID #362
414 S. State Street
· P.O. Box 497
Dover, DE 19903-0497
DATED: hu\\\DKi Attomeys for Plaintiff
W'DF:tcl
cc: Cheryl Anthony, Court Reporter
I