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Case 1:04-cv—01026—KAJ Document 56 Filed 04/25/2006 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
IN RE:
NATIONSRENT, INC., ET Ai..,‘ CASE NOS. 01-11628 THROUGH 01-11639 (PJ W)
IOINTLY ADMINTSTERED
DEETORS. CHAPTER: 11
NATTONSRENT UNSECURED CREDiTORS’
LIQUIDATING TRUST, PERRY MANDARINO,
NOT PERSONAELY, BUT AS TRUSTEE
CASE No. 04~CV—1026 (KAJ)
PLAINTIFF,
v.
CLARK EQUIPMENT COMPANY D/E/A BOEOAT
COMPANY AND INGERSOLL—RAND COMPANY,
DEPENDANTS.
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
703 0(b)(6), Perry Mandarino, Plaintiff and Trustee (the CCTIIISTCSM) of the NationsRent
Unsecured Creditors’ Liquidating Trust, by and through its counsel, will take the
deposition upon Oral examination of higersoll-Rand 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 3rd day of May, 2006, at
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 56 Filed 04/25/2006 Page 2 of 2
2:00 p.m. (Eastern Time), or such other date and time mutually agreed t0 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
Neil B. Glass n, Esq. (N . 2087)
Ashley B. St r (No. 389 )
Mary E. Augustine (No. 4477)
222 Delaware Avenue, Suite 900
Wilmington, Delaware 19801
Telephone: (302) 655—5000
Attorneysfor Perry Mandairino,
Yiustee ofthe Nczti0nsRent Unsecured
Creditors ’ Liquidczting Trust
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