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

Case 1:04-cv-01026-KAJ Document 67-2 Filed 05/11/2006 Page1 of 3
EXHIBIT A‘
Pursuant to Federal Rule of Bankruptcy Procedure 7030(b)(6), the Defendant is
requested to designate one or nrore officers, employees or other persons who are most
knowledgeable about and will testify on its behalf with respect to the topics set forth
below.
TOPICS
1. All facts and circumstances that the Defendant maintain contradict the
allegations in the Amended Adversary Complaint to Avoid and Recover Preferential
Transfers Pursuant to ll U.S.C. §§ 547 and 550 (the "Complaint") in this proceeding.
2. All facts and circumstances that the Defendant maintain support the
affirmative defenses asserted in the Answer to the Complaint.
3. All facts and circumstances that that relate to, support, contradict or
substantiate the claims and defenses asserted in the Complaint and the Answer to the
Complaint.
4. All contracts and agreements, whether written or oral, between the
Debtors and the Defendant.
5. The business relationship between the Debtors and the Defendant prior to
and on the date that the Debtors tiled their bankruptcy petitions.
6. The transactions, course of business and/or financial affairs between the
Debtors and Defendant prior to and on the date that the Debtors filed their bankruptcy
petitions, including the manner and terms ofthe business transactions.
l All capitalized terms not otherwise defined herein shall have the meanings ascribed to them in the
Creditor Trust Trustee’s First Set of interrogatories Directed to Defendant and the Creditor Trust Trustee’s
First Request For the Production of Documents Directed to Defendant (collectively, the "Disc0very
Requests").

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7. The ordinary course of business or financial affairs between the Debtor
and the Defendant.
8. The ordinary course of business or financial affairs in the Defendant’s
industry.
9. The Defendant’s business transactions with the Debtors relating to goods
or services provided by the Defendant and received by the Debtors prior to and on the
date that the Debtors filed their bankmptcy petitions, including the manner in which the
goods or services were ordered, the manner in which the goods or services were
provided, the manner in which the goods or services were invoiced and the manner in
which the goods or services were paid.
10. The Defendant’s procedures, programs and systems for manually and/or
electronically receiving and processing business transactions with its customers prior to
and on the date that the Debtors filed their bankmptcy petitions, including the
information maintained by the Defendant, the location and accessibility of the
information and the manner in which it is kept.
ll. The current and former officers, directors, shareholders, owners,
employees, agents, or other representatives of Defendant Ingersoll—Rand Company and its
relationship to and interests in the Defendant.
l2. The current and former officers, directors, shareholders, owners,
employees, agents, or other representatives of the Defendant and their relationship to and
interests in the Defendant Ingersoll—Rand Company.
13. Defendant Ingersoll-Rand Company’s involvement with the business
relationship and transactions between the Debtors and the Defendant prior to and on the
date that the Debtors filed their bankruptcy petitions.

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14. Any documents produced in response to the Discovery Requests,
including the circumstances relating to their maintenance or preparation, and their context
and meaning.
15. The Defendant’s efforts to locate documents responsive to the Discovery
Requests.
l6. Any documents produced by the Defendant at the deposition, including
the circumstances relating to their maintenance or preparation, and their context and
meaning.
17, Witnesses, including experts, whom the Defendant intend to call at trial in
this adversary proceeding.
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