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 NOTICE OF RULE 30(b)(6) DEPOSITION OF SCOTTSDALE INSURANCE COMPANY

(Assigned to the Judge McNamee)

PLEASE TAKE NOTICE that, pursuant to Arizona Rules of Civil Procedure, you are hereby requested to designate and produce for deposition your representative(s) most knowledgeable to testify about the following subjects: 1. Marketing agreements between Market Finders and Scottsdale Insurance or its subsidiaries. 2. Agency agreements and enforcement of said agreements; 3. Claims handling and guidelines for the managers, supervisors and handling claims representative on all claims, including the claim of Anita Conyers v. Anesthesiology consultants of Toledo, Inc et al.; 4. Underwriting guidelines for all agency agreements (written or oral) with Market Finders, including expectations, authority and limitations;

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5. Underwriting audits, performance requirements and guidelines, along with expertise required for enforcement; 6. State insurance statutory compliance with the State of Indiana and all associated documents 7. Claim file audits and authority reviews performed on the claim of Anita Conyers v. Anesthesiology Consultants of Toledo, Inc et al.) 8. Reinsurance agreements on the Medical Malpractice book of business that Scottsdale Insurance held with any other carrier and guidelines/reporting and program authority. The deposition will be taken at the time and place indicated below, before a Notary Public or other officer duly authorized to administer oaths. DATE & TIME OF DEPOSITION: PLACE OF DEPOSITION: March 31, 2006 at 8:30 a.m. Potts & Associates 2401 W. Peoria Ave., Suite 100 Phoenix, AZ 85029

Dated this 13th day of March, 2006. POTTS & ASSOCIATES

Original of the foregoing e-filed this 13th day of March, 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

By s/Roger M. Sherman Roger M. Sherman Attorney for Defendant

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