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

Case 1:04-cv—01026—KAJ Document 67 Filed 05/11/2006 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR TI~IE DISTRICT OF DELAWARE
IN RE:
NATIONSRENT, INc., ET AL.,] CASE Nos. 01-11628 THROUGH 01-11639 (PI W)
JOINTLY ADMIN ISTERED
DEETORS. CHAPTER; 11
NATIONSRENT UNSECURED CRED1TORS’
LIQUIDATING TRUST, PERRY MANDARINO,
NOT PERSONALLY, BUT AS TRUSTEE
CASE No. O4~CV- 1 026 (KAI)
PLAINTIEE,
V.
CLARK EQUIPMENT COMPANY D/E/A BOBCAT
COMPANY AND INGERSOLL-RAND COMPANY,
DEFENDANTS.
RE—NOTICE OF DEPOSIT ION AND REQUEST FOR
PRODUCTION OF DOCUMENTS PURSUANT TO FEDERAL
RULES OF BANKRUPTCY PROCEDURE 7030 AND 7034
TO: DEFENDANTS AND THEIR
ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE, that pursuant to Federal Rule of Bankruptcy Procedure
7030(b)(6), Perry Mandarino, Plaintiff and Trustee (the "T1ustee") of the NationsRent
Unsecured Creditors’ Liquidating Trust, by and through its counsel, will take the
deposition upon oral examination of Clark Equipment Company d/b/a Bobcat Company
(the "Defendant"), by the officer(s), director(s), employee(S) or other person(s), Inost
knowledgeable regarding the matters listed on Exhibit A hereto, at the offices of the
Defendant, 250 E. Beaton Drive, West Fargo, ND 58078, on the 18th day of May, 2006,
I NationsRent USA, Inc., Nati0nsRent Transportation Services, Inc., NR Delaware, Inc., NRGP, Inc.,
NationsRent West, Inc., Logan Equipment Corp., NR Dealer, Inc., NR Franchise Company, Inc.,
NationsRent of Texas, LP, and NationsRent of Indiana, LP
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Case 1:04-cv—01026—KAJ Document 67 Filed 05/11/2006 Page 2 of 2
at 11:15 a.m. (Eastern Time), or such other date and time mutually agreed to by the
parties and continuing from day to day until completed. The deposition will be taken
before an officer authorized by law to administer oaths, pursuant to Federal Rule of
Bankruptcy Procedure 7028 and Federal Rule of Civil Procedure 28, who will record the
deposition stenographically.
Pursuant to Federal Rule of Bankruptcy Procedure 7030(b)(6), the Defendant
shall designate one or more officers, directors, employees or other persons who will
testify on its behalf regarding the matters identified on Exhibit A attached hereto.
NOTICE IS FURTHER GIVEN, that pursuant to Federal Rules of Bankruptcy
Procedure 7030 and 7034, the Defendant is further requested to produce on or before
May 3, 2006, a copy of all of the documents described on Exhibit B attached hereto.
Dated: May 11, 2006 THE BAYARD FIRM
/ M .>
/
eil B. Glassnfa ,Esq. (No. 2 87)
Ashley B. S tiei.(1\Io. 3891)
Mary E. Au tine (No. A4, 7
222 Delaware Avenue, Suite 900
Wilmington, Delaware 19801
Telephone: (302) 655-5000
Attorneys for Perry Marzdczrino,
Trustee ofthe NdtionsRent Unsecured
Creditors ’ Liquidcztirzg Trust
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