Free Reply in Support of Motion - District Court of Arizona - Arizona

EXHIBIT 1
Case 2:04-cv-OOO78-FJIVI Document 186-4 Filed O3/18/2008 Page1 0f2

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· Rima M. LaMont

From: Roger L. Cohen
Sent: Tuesday, March 18, 2008 2:15 PM
To: 'David A Welling Esq'; 'David A Welling ([email protected])'
Cc: 'Dick Ross ([email protected])'; '[email protected]'; Rima M. LaMont
Subject: Ross adv Shimko
David -
Regarding Mr. Shimko's deposition, I understand that you have agreed to assist in making the
necessary arrangements, including the attendance of a court reporter and reservation of a
conference room, through your contacts in the Caymans. I am still prepared to proceed
tomorrow at 3:30 p.m., EDT, as presently scheduled. If that date cannot work, the following
alternate dates are clear on my calendar and, to my knowledge, are acceptable to Mr. Goldfarb
and Mr. Woodcock's counsel: 3/24 (all day). 3/26 (until 3:30 EDT), 3/27 (from 1:30 EDT).
It is understood that, while the initial costs of the deposition will be borne by my client, we
reserve the right to apply to the Court for appropriate relief, including an Order that Mr. Shimko
be ordered to reimburse Mr. Ross or my tirm for the expenses, in connection with the pending
Motion to Compel or othenivise.
I look forward to hearing from you.
Roger
Myjlnz lllLe.b.site
f Roger L. Cohen
EI Attorney at Law
rei 602l24B-1040
Fax 602l24B-0522
3200 N. Central Ave.
..” K Suite 2000
Phoenix, AZ 85012
Prmenix · smieuaie
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Case 2:04-cv-00078-FJM

Document 186-4

Filed 03/18/2008

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Case 2:04-cv-00078-FJM

Document 186-4

Filed 03/18/2008

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