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Case 1:04-cv—01026—KAJ Document 57 Filed 04/25/2006 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
IN RE:
NATIONSRENT, INC., ET AL.,] CASE Nos. O1-1 1628 TEROUO1-1 O1 -1 1639 (PJW)
JOINTLY ADMINISTERED
DEBTORS. CHAPTER: 11
NATIONSRENT UNSECURED CREDITORS°
LIQUIDATING TRUST, PERRY MANDARINO,
NOT PERSONALLY, BUT AS TRUSTEE
CASE No. 04-CV-1026 (KAJ)
PLATNTTEE,
V.
CLARK EQUIPMENT COMPANY D/B/A BOBCAT ’
COMPANY AND INGERSOLL-RAND COMPANY,
DEFENDANTS.
NOTICE OF DEPOSITION 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 "TruStee") 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), most
knowledgeable regarding the matters listed on Exhibit A hereto, at the offices of The
Bayard Firm, 222 Delaware Avenue, Suite 900, Wilmington, Delaware 19801, on the
I NationsRent USA, Inc., NationsRent 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 57 Filed 04/25/2006 Page 2 of 2
' 3rd day of May, 2006, at 10:00 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: April 25, 2006 THE BAYARD FIRM
it , <.
"
Neil B. Glassi si, Esq. (No. 087)
Ashley B. Sti (No. 3891)
Mary E. Augustine (N o.&l_77
222 Delaware Avenue, Suite 900
Wilmington, Delaware 19801
Telephone: (302) 655-5000
Attorneys for Perry Mczndczrino,
Trustee of the NcztionsRent Unsecured
Creditors ’ Liquidczting Trust
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