Free Notice of Deposition - District Court of Arizona - Arizona

POTTS & ASSOCIATES

Staff Counsel for Travelers Insurance

2401 West Peoria Avenue Suite 100 Phoenix, Arizona 85029-4708 Telephone: (602) 861-8650 Roger M. Sherman, Esq. (SBN: 013407) Attorney for Defendant Market Finders Insurance Corporation UNITED STATE DISTRICT COURT DISTRICT OF ARIZONA ) ) ) Plaintiff, ) ) vs. ) ) Market Finders Insurance ) Corporation, a Kentucky corporation ) ) Defendant. ) Scottsdale Insurance Company, an Ohio corporation Case No. CV 04-118-PHX-SMM 4th NOTICE OF DEPOSITION DUCES TECUM (Assigned to the Judge McNamee)

PLEASE TAKE NOTICE that, pursuant to Arizona Rules of Civil Procedure, Defendant Market Finders Insurance Corporation will take the deposition of Kym Owens at the time and place indicated below, before a Notary Public or other officer duly authorized to administer oaths. PERSON TO BE EXAMINED: DATE & TIME OF DEPOSITION: Kym Owens May 10, 2006 at 9:30 a.m.

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PLACE OF DEPOSITION:

Potts & Associates 2401 W. Peoria Ave., Suite 100 Phoenix, AZ 85029

The deponent is requested to bring with her to the deposition her entire file relating to this matter, including, but not limited to: 1. All documents from or constituting the claims filed for Anesthesiology Consultants of Toledo, Inc., and any of its predecessors, successors and/or related entitled, including but not limited to Consultants in Anesthesiology. All documents from or constituting the file relating to the claim asserted by or on behalf of Anita Conyers against Anesthesiology Consultants of Toledo, Inc. and/or John Dinius. Any other documents relating to insurance coverage for Anesthesiology Consultants of Toledo, Inc and any of its predecessors, successors and/or related entities, including but not limited to Consultants in Anesthesiology and/or for John Dinius, that was placed by or through Market Finders. Any other documents relating to the claim file asserted by or on behalf of Anita Conyers against Anesthesiology Consultants of Toledo, Inc. and/or John Dinius. All documents evidencing, constituting or relating to the negotiation of, or agency agreement entered into by Scottsdale Insurance Company and Market Finders, including any actual or alleged oral or written modifications, amendments, addenda and/or exhibits thereto. All documents evidencing, constituting or relating to the enrollment, the decision not to enroll and/or the disenrollment of Anesthesiology Consultants of Toledo, Inc. and any of its predecessors, successors and/or related entities, including but not limited to Consultants in Anesthesiology and/or any of their agents, servants or employees, including John Dinius, in the Indiana Patient's Compensation Fund. All documents evidencing, constituting or relating to the Market Finders' practices and/or procedures regarding enrollment in the Indiana Patient's Compensation Fund for the 5-year period from 1998 and 2003. Dated this 24th day of April, 2006.

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POTTS & ASSOCIATES

By s/Roger M. Sherman Roger M. Sherman Attorney for Defendant Original of the foregoing e-filed this 24th day of April, 2006 with copies to: Kathleen L. Beiermeister, Esq. Meagher & Geer P.L.L.P. 8800 N. Gainey Center Drive #261 Scottsdale, AZ 85258 Brown & Toleu, Ltd Court Reporters 4500 S. Lakeshore Drive, Suite 280 Tempe, Arizona 85282 By s/Judy McAuley

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