Free Subpoena - District Court of Delaware - Delaware

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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JANE CZARNECKI SUBPOENA IN A CIVIL CASE l
v. Case Number: 05-704
SMITH VOLKSWAGEN, LTD. I
TO: * Claims Records Keeper for: AMERIHEALTH HMO, INC.
c/o Delaware Department of Insurance
841 Silver Lake Blvd
Dover DE 19901
¤ 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 COURTROOM
DATE AND TIME p I
U YOU ARE COMMANDED to appear at the place, date, and time specified below to testify, at the ‘
taking of a deposition in the above case.
PLACE OF DEPOSITION DATE AND TIME
TYBOUT, REDFEARN & PELL, 750 S. Madison Street, 4l“‘ Floor,
Wilmington, DE 19801
X YOU ARE COMMANDED to produce and permit inspection and copying of the following documents .
or objects at the place, date, and time specified below (list documents or objects): : NOTE: Your
appearance is waived if the records are received in this office by the date of the deposition. ·
AMERIHEALTH HMO, INC. is to produce a copy of any claims made by or payments made
on behalf of JANE CZARNECKI, (DOB: 05/30/62) (SSN2 191-52-7468) UNDER Policy N0.
19152746801 or 19152746800. ‘
PLACE DATE AND TIME
TYBoU1*, REDFEARN & PELL, 750 s. Madison stmt, 41* Floor, APRIL 28, 2006 ·
Wilmington, DE 19801 — 1:00 p_m_ _ ~ r
¤ YOU ARE COMMANDED to pennit inspection of the following premises atthe date and time
specified below.
PREMISES l DATE AND TIME V
Any organization not a party to this suit that is subpoenaed for the taking of a deposition shall designate I
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). -
REQUBSTING PARTY'S NAME, ADDRESS AND PHONENUMBER _ - 5
DAVID G. CULLEY, ESQUIRE, Y , DFEARN & PELL, 750 S. MADISON
STREET, 4m FLOOR, P.O. BOX 2092, MINGTON, DE 19899 (302) 658-6901; FAX
(302) 658-4018 · . . E
ISSUING PARTY‘S SIGNATURE AND TITLE (INDICATE IF ATTORNEY FOR PLAINTIFF OR DEFENDANI') DATE
Attorneys for Defendant March 28, 2006

Case 1 *0 - - - -
. 5 cv 00704 GIVIS Document 57 Filed 04/10/2006 Pa e 2 0
i PROOF OF SERVICE i
SERVED DATE April 5, 2000 PLACE Delaware Department of Insurance
(3 : 20 P_M_) 841 Silver Lake Boulevard
Dover, Delaware 19901
SERVED ON (mzmr NAME) _gANN§R if smtvics th f
. . . Y E 1VeI'1I’1g 3 COpy ereo to E1 peISOl’l of
g1dd?Ck_ fe the Delaware suitable age and discretion then employed therein
lsslcmer on behalf of Amerihealth HM;). mg, )
SERVED av (PRINT NAME) TITLE
Jeffrey L. Buble]? process sgfvsj;
l DECLARATION OF SERVER
I declare under penalty of perjury under the laws of the State of Delaware that the foregoing information
contained in the Proof of Service is true and correct. -·
Executed on April 5 , 2006 ( gf ‘
. I ’°
DATE ,~ . •:7/Eg? or ' RVER
legal. Beagl - , Inc.
P.0. Box 886 ’

New Castle, Delaware 19720-0886
(302 )· 322-9897 .

ADDRESS OF SERVER

Rule 45, Federal Rules of Civil Procedure, Parts C & 1) A `
(c) Protection of Persons Subject to Subpoenas.
(1) A party or`an attorney responsible for the issuance and matter and no exception or waiver applies, or
service of a subpoena shall take reasonable steps to avoid imposing (iv) subjects a person to undue burden,
undue burden or expense on a person subject to that subpoena. The
court on behalf of which the subpoena was issued shall enforce this (B) If a subpoena .
duty and impose upon the party or attorney in breach of this duty an (i) requires disclosure of a trade secret or other confidential
appropriate sanction which may include, but is not limited to, lost research, development, or commercial information, or '
earnings and reasonable attorney’s fee. _ (ii) requires disclosure of an unretained expert'sAopinion or
(2)(A) A person commanded to produce and permit inspection information not describing specific events or occurrences in
and copying of designated books, papers, documents or tangible dispute and resulting from the expert's study made not at the
things or inspection of premises need not appear in person at the request of any party, or (iii) requires a person whois not a party _
place of production or inspection unless commanded to appear for or an officer of a party to incur substantial expense to travel more
deposition, hearing or trial. ’ than 100 miles - _
(B) Subject to paragraph (d)(2) of this rule, a person to attend trial;
commanded to produce and permit inspection and copying may, ‘ ‘ ‘
within 14 days after service of the subpoena or before the time the Court may, to protect a person subject to or affected by the.
specified for compliance if such time is less than 14 days after subpoena, quash or modify the subpoena or, if the party in whose A
service, serve upon the party or attorney designated in the subpoena behalf the subpoena is issued. shows a substantial need for the
written objection to inspection or copying of any or all of the testimony or material that cannot be otherwise met without undue
designatedimaterials or of the premises. If objection is made, the hardship and assures that the person to whom the subpoena is
party serving the subpoena shall not be entitled to inspect and copy addressed will be reasonably compensated, the Court may order .
the materials or inspect the premises except pursuant to an order of_ appearance or production only upon specified conditions.
the Court by which the subpoena was issued. lf objection has been A ` ‘
made, the party serving the subpoena may, upon notice to the person (dl Duties in Responding to Subpoena. · .
commanded to produce, move at any time fo ran order to compel the
production. Such an order to compel production shall protect _any (1) A person responding to a subpoena to produce documents A
person who is not a party or an officer of a party from significant shall produce them as they are kept in the usual course of business
expense resulting from the inspection and copying commanded. or shall organize and label them to -correspond with the categories in ‘ _
(3)(A) On timely motion, the Court by which a subpoena was A A the demand. _
issued shall quash or modify the subpoena if it A ~
(i) fails to allow reasonable time for compliance, . (2) When information subject to a subpoena is withheld on a
(ii) requireswa person who is not aparty or an officer of a A claim that it is privileged or subject to protection as trial preparation
party to travel to a place more than 100 miles from the place where materials, the claim shall be made expressly and shall be $l1Pi30|'t9d
that person resides, is employed or regularly transacts business in . by a-description ofthe nature ofthe documents, communications. or
person, except that, subject to the provisions of clause (c)(3)(B)(iii) of things not produced that is sufficient to enable the demanding party
this rule, such a person may in order to attend trial be commanded to to. contest the ` " _
travel from any such place within the state in which the trial is held, claim. · ` ’ ·
Of ·
(iii) requires disclosure of privileged or other protected A — A — . ,