Free Notice (Other) - District Court of Delaware - Delaware


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Case 1:04-cv-00910-GMS

Document 185

Filed 07/27/2006

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE INTEGRATED HEALTH SERVICES OF CLIFF MANOR, INC., INTEGRATED HEALTH SERVICES AT RIVERBEND, INTEGRATED HEALTH SERVICES AT SOMERSET VALLEY, INC., ALPINE MANOR, INC., BRIARCLIFF NURSING HOME, INC., INTEGRATED HEALTH GROUP, INC., SPRING CREEK OF IHS, INC., FIRELANDS OF IHS, INC., ELM CREEK OF IHS, INC., and IHS LONG TERM CARE SERVICES, INC., Plaintiffs, v. THCI COMPANY LLC, Defendant, v. ABE BRIARWOOD CORPORATION and JOHN DOES 1-10, Additional Counterclaim Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 04-910 (GMS)

NOTICE TO TAKE DEPOSITION OF A NON-PARTY CORPORATION PLEASE TAKE NOTICE that defendant THCI Company LLC will take testimony by deposition, upon oral examination, before a person authorized by the laws of the State of New York to administer oaths, on August 9, 2006, commencing at 2:00 p.m. at the office of Pitney Hardin LLP, 7 Times Square, New York, NY 10036-7311 and on any adjourned date thereof, and from day to day thereafter until completed, with respect to the subject matter of this action, at which time and place the deposition of a representative of Credit Suisse First Boston, Inc. ("CSFB") will

Case 1:04-cv-00910-GMS

Document 185

Filed 07/27/2006

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be taken in accordance with the attached Subpoena Duces Tecum. As counsel for Plaintiffs you are invited to attend and cross-examine. The person or persons that may be designated by CSFB in accordance with Fed. R. Civ. P. 30(b)(6) and 45 should have knowledge of the facts, circumstances, and background relating to (1) ABE Briarwood Corporation's ("Briarwood") acquisition of the shares of IHS Long Term Care Services, Inc. ("LTC"), (2) financing or lending provided to or on behalf of Briarwood or LTC, and (3) the transfer of any assets from Briarwood, LTC, and/or any of the other Plaintiffs in this case to any other party since August 2003. PLEASE TAKE FURTHER NOTICE that, on August 9, 2006, at the location above, CSFB has been directed to produce each of the documents specified in the attached Subpoena Duces Tecum. CONNOLLY BOVE LODGE & HUTZ LLP

____/s/ Kevin F. Brady________________ Collins J. Seitz, Jr. (Bar No. 2237) Kevin F. Brady (Bar No. 2248) 1007 North Orange Street Wilmington, DE 19801 Tel: (302) 658-9141 Fax: (302) 658-5614 Attorneys for Defendant THCI Company LLC OF COUNSEL: David S. Sager Paul R. Marino PITNEY HARDIN LLP P.O. Box 1945 Morristown, New Jersey 07962 Tel: (973) 966-6300 Fax: (973) 966-1015 DATED: July 27, 2006

Case 1:04-cv-00910-GMS

Document 185

Filed 07/27/2006

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CERTIFICATE OF SERVICE I, Kevin F. Brady, hereby certify that on the 27th day of July, 2006 a true and correct copy of the Notice to Take Deposition of a Non-Party Corporation was caused to be served by electronic mail on the attorney of record at the following address: Richard William Riley, Esquire Duane Morris LLP 1100 North Market Street Suite 1200 Wilmington, DE 19801

/s/ Kevin F. Brady Kevin F. Brady (Bar No. 2248)