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

Case 1 :05-cv-00879-SLR Document 28 Filed O4/05/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PHCE ELECTRIC CORPORATION and g
PHCE ELECTRIC, INC., )
)
Plaintiffs, )
) Civil Action No. 05-879-SLR
vs. )
)
MICK DUBEA, )
Defendant. )
DEFENDANT MICK DUBEA’S NOTICE OF 30(B)(6) DEPOSIT ION OF
PIKE ELECTRIC CORPORATION
TO: Alyssa M. Schwartz, Esq.
Richards, Layton & Finger
One Rodney Square
P.O. Box 551 A
Wilmington, DE 19899
PLEASE TAKE NOTICE that the undersigned will take the oral deposition of Pike Electric
Corporation ("Pike") pursuant to Rule 30(b)(6) of the Federal Rules of Civil Procedure, on April 13,
2006, at 10 a.m., or at such other date and time as the Court may order or the parties may agree in writing,
and continuing from day to day until completed, in the offices of Morris, James, Hitchens & Williams
LLP, 222 Delaware Avenue, 10th Floor, Wilmington, Delaware 19801. The testimony shall be recorded
stenographically. Pike shall designate the person(s) most knowledgeable about the topics on
SCHEDULE A attached hereto.
Dated: April 5, 2006 By: (M
Le is H. azarus (#23 74)
Ma thew F. Lintner (#4371)
Jo ph S. Naylor (#3886)
RRIS, JAMES, HITCHENS & WILLIAMS LLP
222 Delaware Avenue, 10th Floor
Wilmington, Delaware 19801
(302) 888-6800
. ll3Z3I'11S@1IlO1`1`lS_l8Y11€S.CO111
mlintner@morrisj ames.com
j11aylor@morrisj ames.com
Attorneys for Defendant Mick Dubea

Case 1:05-cv-00879-SLR Document 28 Filed O4/05/2006 Page 2 of 3
SCHEDULE A
l. Plaintiffs’ retention policy concerning hard—copy and electronic documents;
2. When Plaintiffs first anticipated that litigation with Mr. Dubea relating to any of
the matters alleged in the Complaint and/or Counterclaim might occur;
3. The substance and timing of efforts to preserve Plaintiffs’ hard-copy and/or
electronic documents in connection with this litigation and/ or the Texas action, Pike Electric
Cogoration & Pike Electric, Inc. v. T&D Solutions, Ltd., T&D Solution Managers, LLC, Corey
Close, & Chad Dubea, C.A. No. 05-410 (the "Texas Action"), including but not limited to
communications with Plaintiffs’ employees;
4. Plaintiffs’ computer system and electronic network, including the nature, scope,
character, organization, and formats employed in each system.
5. The integration of RSI’s computer system and electronic network into Plaintiffs’
system.
6. The search methodology Plaintiffs employed in locating and reviewing relevant
electronic documents in response to Defendant’s Request for Production directed to Plaintiffs in
this action and/or any other requests for production directed to Plaintiffs in the Texas action.
1370438/1 2

Case 1:05-cv-00879-SLR Document 28 Filed O4/05/2006 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on April 5, 2006, I electronically filed with the Clerk of Court
using CM/ECP and served Defendant Mick Dubea’s Notice of Deposition of Plaintiff
Pike Electric Corporation this Certificate of Service on the following persons in the
manner indicated below:
BY HAND DELIVERY and E-MAIL:
Alyssa M. Schwartz, Esquire
Richards, Layton & Finger
One Rodney Square
P.O. Box 551
Wilmington, DE 19899
BY FIRST-CLASS MAIL and E-MAIL
Sarah E. Paul, Esquire
Cravath, Swaine & Moore LLP
Worldwide Plaza, 825 Eighth Avenue
New York, NY 10019
/s/ Joseph S. Naylor
Joseph S. Naylor (#3886)
1370803/1