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

Case 1:04-cv-00910-GMS

Document 176

Filed 06/15/2006

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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 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 July 20, 2006, commencing at 10:00 a.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

Case 1:04-cv-00910-GMS

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time and place the deposition of Uri Kaufman will be taken in accordance with the attached Subpoena Duces Tecum. As counsel for Plaintiffs you are invited to attend and cross-examine. PLEASE TAKE FURTHER NOTICE that, on July 20, 2006 at the location above, Uri Kaufman 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: June 15, 2006

Case 1:04-cv-00910-GMS

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CERTIFICATE OF SERVICE I, Kevin F. Brady, hereby certify that on the 15th day of June, 2006 a true and correct copy of the Notice to Take Deposition of a Non-Party 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)