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

Case 1 :04-cv—00943-KAJ Document 41 Filed 07/13/2005 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
DIN O G. PETROCELLI, )
Plaintiff, g
)
vs. )
) Case No. 04-CV-943-KAJ
CHRYSLER CORPORATION, MOPAR )
DIVISION, )
Defendant. g
THIRD NOTICE OF PLAINTIFF’S DEPOSITION AND
REQUEST FOR PRODUCTION OF DOCUMENTS
PLEASE TAKE NOTICE that the deposition of plaintiff Dino G.
Petrocelli shall take place on August 8 and 9, 2005, beginning at 4:00 p.m. on both days,
and continuing from day-to-day thereafter until completed, at the law offices of Potter
Anderson & Corroon LLP, Hercules Plaza, 1313 North Market Street, Wilmington,
Delaware 19801. The deposition shall be recorded steonographically, by a certified court
reporter, and by videotape, by Wilcox & Fetzer, 1330 King Street, Wilmington, DE
19801.
It is by agreement of the parties that the deposition is scheduled for a two-
day period during evening hours. This arrangement is made to accommodate plaintiffs
work schedule. Thus, the deposition will begin at 4:00 p.m. on August 8, 2005. If it is
not completed on August 8, 2005, it will continue on August 9, 2005, again beginning at
4:00 p.m.
Pursuant to Federal Rules of Civil Procedure 30(b)(5) and 34,
DaimlerChrysler hereby requests production of the following items from Mr. Petrocelli:
(1) all journals, diaries, calendars, notes, or records kept by Mr. Petrocelli conceming any
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Case 1 :04-cv—00943-KAJ Document 41 Filed 07/13/2005 Page 2 of 3
aspect of his employment with DaimlerChrysler or his legal claims; (2) all employment
or personnel records in Mr. Petrocelli’s possession related to his employment with
DaimlerChrysler; (3) all sound recordings or documents that concem any aspect of Mr.
Petrocelli’s employment with DaimlerChrysler or his legal claims; and (4) all other
documents and items that Mr. Petrocelli believes are relevant to his employment with
DaimlerChrysler or to his claims in the above-captioned lawsuit. Mr. Petrocelli is
requested to bring these items and documents to his deposition and produce them at 9:30
a.m. on Tuesday, July 12, 2005, at the offices of Potter Anderson & Corroon LLP,
Hercules Plaza, 1313 North Market Street, Wilmington, Delaware 19801.
POTTE ANDERSON & CORROON LLP
By *1 0/*@-/x Z LO
ennifer Gimler Brady (Bar I.D. 2874)
Sarah E. DiLuzio (Bar I.D. #4085)
Hercules Plaza, 6th Floor
1313 North Market Street
Wilmington, DE 19801
Tel: 302-984-6000
Fax: 302-658-1192
and
SHOOK, HARDY & BACON, LLP
William C. Martucci, Mo. #28237
Kristen Aggeler Page, Mo. #50852
2555 Grand Blvd.
Kansas City, Missouri 64108-2613
Tel: 816-474-6550
Fax: 8l6—421—5547
Attorneys For Daimlerchrjysler Corporation
Dated: July 13, 2005
- 2 -
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Case 1 :04-cv—00943-KAJ Document 41 Filed 07/13/2005 Page 3 of 3
CERTIFICATE OF SERVICE
I, Sarah E. DiLuzio, hereby certify this 13th day of July, 2005, that two (2)
true and correct copies of the foregoing THIRD NOTICE OF PLAINTIFF’S
DEPOSITION AND REQUEST FOR PRODUCTION OF DOCUMENTS were served
in the manner indicated on the following:
FIRST CLASS U.S. MAIL POSTAGE PREPAID
Dino G. Petrocelli
129 Emery Court
Newark, DE 19711
f · r '
,‘”` . (lcv ’
C ,·'”Sarah E. DiLuzio (#4085)
Potter Anderson & Corroon LLP
Hercules Plaza, Sixth Floor
1313 North Market Street
Wilmington, Delaware 19899-0951
(302) 984-6000 — Telephone
(302) 658-1192 — Facsimile
[email protected]
690239
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