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

Case 1 :04-cv-01285-GIVIS Document 45 Filed 08/09/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ENZON PI-IARMACEUTICALS, INC.,
Plaintiff,
v. Civil Action No. 04-1285 (GMS)
PHOENIX PHARNIACOLOGICS, INC.,
Defendant.
NOTICE OF DEPOSITION OF DEFENDANT
PHOENIX PHARMACOLOGICS, INC.
PURSUANT TO FED. R. CIV. P. RULE 30gblg6{ {No. 123
TO: Joseph Lucci, Esq. Richard D. Kirk, Esq.
Woodcock Washburn, LLP The Bayard Firm
One Liberty Place, 46m Floor 222 Delaware Avenue, Suite 900
Philadelphia, PA 19103 Wilmington, DE 19801
PLEASE TAKE NOTICE that, pursuant to Ped. R. Civ. P. Rule 30(b)(6), Plaintiff Enzon
Pharmaceuticals, Inc. ("Enzon") will take the deposition upon oral examination of Defendant
Phoenix Pharmacologics, Inc. ("Phoenix"), commencing on August 25, at 9:30 am., and
continuing from day to day until completed, at the offices of Kenyon & Kenyon, One Broadway,
New York, New York, 10004, or such other time and location as agreed upon by counsel. The ~
deposition will he taken before a Notary Public or other officer duly authorized to administer
oaths, and will be recorded by stenographic and/or videotape means.
Your are invited to attend and cross·—exarnine.
The definitions and instructions set forth in Enzon’s interrogatories and document
requests shall apply to this notice of deposition.
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Case 1:04-cv-01285-GI\/IS Document 45 Filed 08/09/2005 Page 2 of 3
I Phoenix shall designate one or more knowledgeable persons to testify on its behalf as to
the following category:
12. Any and all agreements, by and between Phoenix and the Ludwig Institute for
Cancer Research related to PEG-ADI, including but not limited to, documents bearing Bates
numbers PI~I—03644 ·~·~ PH—03657, PH-03596 — PH-03629, the negotiation, preparation and
drafting of such agreements, all correspondence and communications related to such agreements,
the identity of all persons who contributed to the process of preparing and/or negotiating the
terms of such agreements, and the performance under such agreements by Phoenix.
i Y CONAWAY STARGATT & TAYLOR, LLP
Josy . Ingersoll (No.108S)
John W. Shaw (No. 3362)
Glenn C. Mandalas (No. 4432)
The Brandywine Building
1000 West Street, 17th Floor
P.O. Box 391
Wilmington, DE 19801—039l
(302) 571-6600
[email protected]
Attorneys for P/aintyf Erzzon P/icrmacerrricals, Inc.
OF COUNSEL:
Richard L. 1DeLucia
Charles A. Weiss
` Michael A. Siem
_ KENYON & KENYON
i One Broadway
New York, NY 10004
(212) 425-7200
Dated: August 9, 2005
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Case 1:04-cv-01285-Gl\/IS Document 45 Filed 08/09/2005 Page 3 of 3
CERTIFICATE OF SERVICE
1, Glenn C. Mandalas, Esquire, hereby certify that on August 9, 2005, 1 caused to be
electronically tiled a true and correct copy ofthe foregoing document with the Clerk ofthe Court
using CM/ECP, which will send notification that such filing is available for viewing and
downloading to the following counsel of record:
Richard D. Kirk, Esquire
THE BAYARD FIRM
222 Delaware Avenue, Suite 900
Wilmington, DE 19801
1 further certify that on August 9, 2005, 1 caused a copy ofthe foregoing document to be
; served by hand delivery on the above-listed counsel of record and on the following in the manner
indicated:
BY FEDERAL EXPRESS
Joseph Lucci, Esquire
WOODCOCK WASHBURN, LLP
One Liberty Place, 46* Floor
Philadelphia, PA 19103 _
YO G CONAWAY STARGATT & TAYLOR, LLP
Jo Jngersoll (No. 1088)
John W. Shaw (No. 3362)
Glenn C. Mandalas (No. 4432)
The Brandywine Building
1000 West Street, 17th Floor
_ Wilmington, Delaware 19801
- (302) 57l··6600
[email protected]
Attorneys for P/.:rintw“Erzz0n Pharmaceuticals, Inc.
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