Free Notice (Other) - District Court of Delaware - Delaware

Case 1:04-cv-01275-KAJ

Document 64

Filed 07/14/2005

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) Plaintiff, ) ) v. ) ) COLONY INSURANCE COMPANY, ) TRUCK TECH INDUSTRIES, INC., ) and TIPCO TECHNOLOGIES, INC., ) ) Defendants. ) DON'S HYDRAULICS, INC.,

C.A. No. 04-1275 (KAJ)

RE-NOTICE OF DEPOSITION PURSUANT TO DELAWARE RULE OF CIVIL PROCEDURE 30(B)(6) DIRECTED TO DEFENDANT TRUCK TECH INDUSTRIES, INC. TO: Gary H. Kaplan, Esquire Goldfein & Hosmer 222 Delaware Avenue Suite 1110 P.O. Box 2206 Wilmington, DE 19899-2206 Cindy Beam, Esquire Reger & Rizzo, LLP 1001 Jefferson Plaza Suite 202 Wilmington, DE 19801 Joseph M. Toddy, Esquire Zarwin Baum DeVito Kaplan Schaer Toddy P.C. Suite 1200 1515 Market Street Philadelphia, PA 19102-1981 Anthony Figliola, Jr., Esquire Figliola & Facciolo 1813 Marsh Road Suite A Wilmington, DE 19810

Pursuant to Delaware Rule of Civil Procedure 30 (b) (6), defendant Truck Tech Industries, Inc. is required to produce for deposition one or more officers, directors, managing agents,

custodians of record and/or employees or other persons permitted to testify on their behalf, on Thursday, August 4, 2005 at 10:30 a.m. in the offices of Tighe, Cottrell & Logan, P.A., 704 N. King Street, Suite 500, Wilmington, DE 19801 and continuing thereafter until completed, to testify on their behalf as to matters known or reasonably subjects: available to their organization on the following

Case 1:04-cv-01275-KAJ

Document 64

Filed 07/14/2005

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1.

The

facts

supporting

the

defendant's Affirmative

Defenses. 2. 3. The matters covered in all the pleadings in this case. The design and manufacture of the hoses at issue in this case. 4. 5. All quality control measures taken in this case. All contracts among the parties involved in the

transactions that gave rise to this claim. 6. All facts discussed in the expert opinions of any of the parties' experts to date in this litigation. 7. All other claims, lawsuits or complaints made regarding products defendant. 8. All recalls regarding products manufactured, designed or sold by this defendant. 9. 10. The insurance coverage related to this claim. All conversations with Don Cathell or any other agent, servant, or employee of Don's Hydraulic's. 11. Information related to any investigations made related to this claim. 12. Information complaints related made to other this claims, lawsuits or manufactured, designed or sold by this

against

defendant

products

manufactured, designed or sold by this defendant. The person(s) so designated is to bring with them any and all documents which refer in any way to the above areas in which they are expected to testify.

Case 1:04-cv-01275-KAJ

Document 64

Filed 07/14/2005

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TIGHE, COTTRELL & LOGAN, P.A. /s/ Michael K. Tighe Michael K. Tighe (DE ID 29) First Federal Plaza, Suite 500 P.O. Box 1031 Wilmington, DE 19899-1031 (302) 658-6400 Attorneys for Plaintiff DATED: cc: July 14, 2005

Esquire Deposition Services