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

Case 1 :07-cv—00478-IVIPT Document 32 Filed 05/01 /2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
CHRISTINA M. KROKOS, )
JAMES K. KROKOS, husband and wife, )
individually and collectively as the next iiiend )
and parents of K.I.K., a minor, ) C.A. No. 07-478-MPT
)
Plaintiffs, )
)
v. )
)
UNITED STATES OF AMERICA, )
)
Defendant. )
NOTICE OF SUBPOENA DIRECTED TO JAMIE KING, MSN, BSN
PLEASE TAKE NOTICE that Christina M. Krokos, James K. Krokos and K.I.K, a minor,
(collectively "Plaintiffs") will serve the attached subpoena upon Jamie King, MSN, BSN,
Delaware Technical & Community College, 100 Campus Drive, Dover, DE 19904.
ASHBY & GEDDES
/s/ Randall E. Robbins (#2059)
Randall E. Robbins (# 2059)
Joseph C. Handlon (# 3952)
500 Delaware Avenue
8th Floor
P.O. Box 1150
Wilmington, DE 19899
Tel: (302) 654-1888
Fax: (302) 654-2067
Attorneys for Plaintyjfs
Dated: May 1, 2008
{0021 3398;v1}

Case 1 :07-cv—00478-IVIPT Document 32 Filed 05/01 /2008 Page 2 of 3
Issued by the
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
CHRISTINA M. KROKOS, SUBPOENA IN A CIVIL CASE
JAMES K. KROKOS, husband and wife, CASE NUMBER: 07-478-MPT
individually and collectively as the next friend
and parents of K.I.K., a minor,
Plaintiffs,
V.
UNITED STATES OF AMERICA,
Defendant.
TO: Jamie King, MSN, BSN
Delaware Technical & Community College
100 Campus Drive
Dover, DE 19904
C] YOU ARE COMMANDED to appear in the United States District Court at the place, date, and time specified
below to testify in the above case.
PLACE OF TESTIMONY DATE AND TIME
E YOU ARE COMMANDED to appear at the place, date, and time specified below to testify on the topics set
forth in Schedule B at the taking of a deposition in the above case pursuant to Rule 30 of the Federal Rules of Civil
Procedure.
PLACE OF DEPOSITION Parkowski Guerke & Swayze, P.A. PROPOSED DATE AND DMD
116 west water sum, Dover, DE 19903 Wednesday, July 9, 2008 at
10:00 a.m.
lj YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or
objects at the place, date, and time specified below: See Schedule A.
PLACE PROPOSED DATE AND TIME
Cl YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below.
PREMISES DATE AND TIME
Any organization not a pany to this suit that is subpoenaed for the taking of a deposition shall designate one or
more officers, directors, or managing agents, or other persons who consent to testify on its behalf, and may set forth, for
each person designated, the matters on which the person will testify. Federal Rules of Civil Procedure, 30(b)(6).
ISSUING OFFICER SIGNATURE AND TITLE DATE
May 1, 2008
Attorney for Christina M. Krokos, James K. Krokos, husband and wife individually
and collectivel as the next friend and arent of K.I.K., a minor
ISSUING OFFICERS NAME, ADDRESS AND PHONE NUMBER
Randall E. Robbins, Ashby & Geddes, 500 Delaware Avenue, 8th Floor, P.O. Box 1150, Wilmington, DE 19899
302 654-1888
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Case 1 :07-cv—00478-i\/I PT Document 32 Filed 05/01 /2008 Page 3 of 3
PROOF OF SERVICE
DATE OF SERVICE PLACE OF SERVICE
SERVED ON (PRINT NAME) MANNER OF SERVICE
SERVED BY (PRINT NAME) TITLE
DECLARATION OF SERVER
I declare under enal of e ' the laws of the United States of America that the fore oin information
P i P UIHY S g
contained in the Proof of Service is true and correct.
Executed on
DATE SIGNATURE OF SERVER
ADDRESS OF SERVER
Rule 45, Federal Rules of Civil Procedure, Parts C & D:
(c) PROTECTION OF PERSONS SUBJECT TO SUBPOENAS. (iv) subjects a person to undue burden.
(B) If a subpoena
(I) A party or an attomey responsible for the issuance and service of a
subpoena shall take reasonable steps to avoid imposing undue burden or (I) requires disclosure of a trade secret or other confidential
expense on a person subject to that subpoena. The court on behalf of which research, development, or commercial information, or
the subpoena was issued shall enforce this duty and impose upon the party or
attorney inibreach of this duty and appropriate sanction, which may include, (ii) ioquiios disclosure of an umominod oxpoifs opinion oi
but ‘S mt h““t°d t°· lost cammgs md a ’°aS°“abl° a“°m°Y S f°°· information not describing specific events or occurrences in dispute and
resulting from the expert’s study made not at the request of any party, or
(2)(A) A person commanded to produce and pemiit inspection and
copying of designated books, papers, documents or tangible thmgs, or I (iii) ioquiios a poison who is not a pany oi, an ofiiooi ofa party to
inspccqon of Pmmlscs need not appear m P°rs°“ zitihc PIM'? <>f¤r<><1¤¤¤<>¤ °r incur substantial expense to travel more than 100 miles to attend trial, the
mSP€<>U0¤ unless cvmmandsd *0 aPP°al' fm d°P°$m°“· hcarmg °’ mal- court may, to protect a person subject to or affected by the subpoena, quash or
modify the subpoena or, if the part in whose behalf the subpoena is issued
(B) Subject to paragraph (d)(2) of this rule, a person commanded to shows a substantial need for the testimony or material that cannot be
produce and permit inspection and copying may, within I4 days after service otherwise met without undue hardship and assures that the person to whom
of the subpoena or before the time specified for compliance if such time is less the subpoena is addressed will be reasonably compensated, the court may
than 14 days after service, serve upon the party or attomey designated in the order appearance or production only upon specified conditions.
subpoena written objection to inspection or copying of any or all of the
designated materials or f the premises. If objection is made, the party sewing (d) DUTIES IN RESPONDING TO SUBPOENA'
the subpoena shall not be entitled to inspect and copy the materials or inspect
the premises except pursuant to an order of the court by which the subpoena .
was issued. rr objection has been mac, me party img me subpoena may, A pim *¢S¤¤¤d·¤¤ *03 S¤*>¤·>==¤¤ *0 time dsrumcnis Sha" _
upon notice to the person commanded to produce, move at any time for an produce them as they are kept in the usual courseiofbusrness or shall organize
order to compel the production. Such an order to compel production shall and mw] thcm t° °°"°sp°"d with the °at°g°n°S m thc d°m°"d‘
protect any person who is not a party or an officer of a party from significant
expense resulting from the inspection and copying commanded. (2) When information subject to a subpoena is withheld on a claim that it is
privileged or subject to a subpoena is withheld on a claim that it is privileged
GXA) On timely motion the com by which 3 subpoena was issued shan or subject to protection as trial preparation materials, the claim shall be made
quash or modify the Subpociia ifii expressly and shall be supported by a description of the nature of the
documents, communications, or things not produced that is sufficient to
_ A _ _ enable the demanding party to contest the claim.
(r) fails to allow reasonable time for compliance;
(ii) requires a person who is not a party or an officer of a party to
travel to a place more than 100 miles from the place where that person resides,
is employed or regularly transacts business in person, except that, subject to
the provisions of clause (c)(3)(B)(iii) of this rule, such a person may in order
to attend trial be commanded to travel from any such place within the state in
which the trial is held, or
(iii) requires disclosure of privileged or other protected matter and
no exception or waiver applies, or
{002 I 3406;vl}