Free Letter - District Court of Delaware - Delaware

Case 1:05-cv-00022-MPT Document 142-2 Filed 10/30/2007 Page 1 of 4

~ Case 1:05-cv-00022-MPT Document 142-2 Filed 10/30/2007 Page 2 of 4
IN THE UNITED STATES DISTRICT COURT y
Z FOR THE DISTRICT OF DELAWARE
I ST. PAUL MERCURY INSURANCE :
. COMPANY, and :
PACK & PROCESS, H\iC. :
_ Plaintiff,
3 : - Civil Action N0. 05-0022 (KAJ)
’ MALY YAN :
Defendant LEAD CASE
YAN THOU, Individually and as :
Administrator of the Estates of Oeurn :
Mam, Deceased and Navy Yan, Deceased : Civil Action No. 05-0513 (KAJ)
et al., :
Plaintiffs :
U VS. :
PACK & PROCESS, INC. :
‘ AND :
` ST. PAUL MERCURY INSURANCE :
-e COMPANY :
Defendants :
REVISED NOTICE OF DEPOSITION
TO: Francis J. Deasey, Esquire
I, Deasey, Mahoney & Bender, LTD
1800 John F . Kennedy Blvd.
Suite 1300
I Philadelphia PA 19103
g PLEASE TAKE NOTICE that Yan Thou will take the deposition of any Corporate
in Designee(s) on , 2006 starting at 10:00 a.m. at the law office of Kline &
* Specter, P.C., 1525 Locust Street, 19"‘ Floor, Philadelphia PA 19102.
Pursuant to Fed. R.C. P. 30(b)(6), St. Paul Insurance Company will produce deponent(s)
Q that have knowledge as to the matters known or information available to St. Paul Insurance
Company and will testify as to that information as well as the documents produced, relating to

Case 1 :05-cv-00022-M PT Document 142-2 Filed 10/30/2007 Page 3 of 4
1 the following: -
1, 1) Any and all records in their possession, custody and control that refer, relate and/or
i pertain to the incident described in Plaintiffs' Complaint including any and all documents
U requested in discovery regarding the employment of Yan Thou and Maly Yan and the insurance
polices relating to Pack & Process;
in 2) any insurance company documents, payments, invoices, contracts, or benefit plans listing
E employees covered by any insurance policies or plans of Pack and Process for 1997, 1998,1999, 2000,
2001, any property and/or automobile insurance covering vehicles for Pack and Process including
l vehicles parked on their property from 1997 through 2001.
7 3) any receipts for registration, insurance, repairs, gasoline and/or any costs relating to the van
used to transport workers to and from Pack and Process from 1997 through 2001, correspondences,
l memos to and from any insurance companies regarding any claims made by any of the Defendants while
at Pack and Process from 1997 through 2001.
7 4) any claims presented to andJor paid for by any insurance companies covering Pack and
Process for wage loss, medical bills, dental bills, funeral bills, unemployment, workers compensation,
property damage and/or life insurance benefits, made by any ofthe Defendants or anyone on behalf of
any of the Defendants from 1998 through 2002.
1 The oral examinations will continue from day to day until concluded. You are invited to
f attend and participate in this examination.
{ VVEISS AND SAVILLE, PA.
if BY: SfYvom1e Takvorian Saville, Esquire
P YVONNE TAKVORIAN SAVILLE, ESQUIRE
` 1220 North Market Street
1 Suite 604
P.O. Box 370
1 Wilmington DE 19801
(302) 656-0400

I Case 1:05-cv-00022-MPT Document 142-2 Filed 10/30/2007 Page 4 of 4
S DATED: and
i KLINE & SPECTER, P.C.
BY: S/Jo11atha11M. Cohen, Esquire! JC593
JONATHAN M. COHEN, ESQUERE
· JOSHUA VAN NAARDEN, ESQUIRE
1525 Locust Street, 19t" Floor
Philadelphia PA 19102
Q (215) 772-1000