Free Notice to Take Deposition - District Court of Delaware - Delaware

Case 1 :07-cv—00478-IVIPT Document 35 Filed 05/14/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
CHRISTH\IA M. KROKOS, )
JAMES K. KROKOS, husband and wife, )
individually and collectively as the next friend )
and parents of K.I.K., a minor, ) C.A. No. 07-478-MPT
)
Plaintiffs, )
)
v. )
)
UNITED STATES OF AMERICA, )
)
Defendant. )
NOTICE OF DEPOSITION
DUCES TECUMI ANDAD TESTIFICANDUM
TO: Colm F. Comiolly
United States Attomey
c/0 Patricia C. Harmigan
Assistant U.S. Attorney
The Nemours Building
1007 Orange Street, Suite 700
Wilmington, DE 19801
PLEASE TAKE NOTICE that, by prior agreement of the parties, the undersigned
attomeys will take the oral deposition of STEVEN BRUMFIELD, M.D., at the United States
Attorney’s Office, 300 Virginia Street, East, Suite 4000, Charleston, WV 25301 beginning at
9:30 a.m. on Friday, July 18, 2008, and continuing until completed.
I Deponent is requested to bring with him/her to the deposition his/her entire file on this matter, including but not
limited to, the originals and all copies of (1) all documents, reports, notes and/or written materials of any nature
prepared by the witness or by any person at the wit11ess’ direction in connection with his/her work on the matter which is
the subject of this litigation and the witness' involvement in it; (2) all correspondence, reports, records, notes, and any
other materials in writing, and all iilms of any nature, reviewed by the witness; (3) the original patient records if in your
possession, custody or control; (4) all studies, medical literature, texts, authorities, medical policies and procedures
and/or any secondary sources consulted, considered and/or reviewed; (5) all other documents relied upon in fonnulating
any opinions; (6) any and all documents, models or tangible things which the deponent intends to use ir1 connection with
any testimony in this case; and (7) the original patient records if in the witness' possession, custody or control.
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Case 1 :07-cv—00478-IVIPT Document 35 Filed 05/14/2008 Page 2 of 2
You are invited to attend and cross-examine.
ASHBY & GEDDES
/s/ Randall E. Robbins
Randall E. Robbins (I.D. No. 2059)
500 Delaware Avenue
8th Floor
P.O. Box 1150
Wilmington, DE 19899
(302) 654-1888
Attorneys for Plaintyfs
Dated: May 14, 2008
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