" I - - i I i _ I I _ s uc y e rrr I I I I I VW--?--W---—
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JANE CZARNECKI SUBPOENA IN A CIVIL CASE
v. Case Number: 05-704
SMITH VOLKSWAGEN, LTD. I
TO: * Employment Records Keeper for: BAYSHORE FORD
4003 N. DUPONT HIGHWAY
NEW CASTLE DE 19720
¤ 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
D 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, 4"‘ 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.
a copy of their employment records on employee JANE CZARNECKI, (DOB: 05/30/62) (SSN: 191-52-
7468) including, but not limited to payroll records, applications for employment, contracts or similar
records of emplo ment, 'ob descri tions or other terms &/or conditions of emplo ment.
PLACE DATE AND TIME I
TYBoUT,1usD1¤*EARN & PELL, 750 s. Madison street, 4**· Floor, _ APRIL 10, 2006
Wilmington, DE 19801 1:00 p_m· .
¤ YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below.
PREMISES l DATE AND TIME ` l
Any organization not a party 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(/7) (6).
REQUESTING PARTY'S NAME, ADDRESS AND PHONE NUMBER
DAVID G. CULLEY, ESQUIRE, TYBOUT, REDFEARN & PELL, 750 S. MADISON
STREET, 4TH FLOOR, P.O OX 2092, WILMINGTON, DE 19899 (302) 658-6901; fax (302)
658-4018 I
ISSUING PARTY'S SIGNATURE AND TITLE 4 A I RNEY FOR PLAINTIFF OR DEFENDANT) DATE
Attorneys for Defendant Maréh 28, 2006 A
*If action is pending in district other than district o issuance, state district under case number. A
- Case 1 :05-cv—00704-GIVIS Document 55A Filed 03/31/2006 Pa e 2 of 2 _
y PROOF OF SERVICE ‘ ‘ -
~ 1: . PLACE A `A
ATE March 30, . Ba,yShOI`€ FOIAG U
(3,10 P M ) 4003 N. DuPont Highway
. New Castle, Delaware 19720 A
seizveo on (maint NAME) ° » MANNER org smzvies I *
kub k_ t by delivering a copy thereof to a person of
A Dan Ja OWS 1’ Con f¤11¤r suitable age and discretion then employed therein
A as - •lo ent records kee•erA. .
ssizveo BY (PRINT NAME) ‘ _ . ° ‘ TITLE · _ A A A ‘ _
. Jeffrey L. Butler process server A ‘ »
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. · ‘ A . . _
_ Executed on March 30, 2006 _ A ‘ = A. . .. Ag ` 4 . A
A A DATE / ;a * RE F S " ' ER' . .
i -4 ¢¢-¢ := Inc. A I _ -
A P.O. Box 886 ‘ . A
· ‘ - · New Castle, Delaware 19720-0886 ]
. (302) 322-9897 A A
V . A ADDRESS OF SERVER ` »
° Rule 45, Federal Rules of Civil Procedure, Parts C & D . ‘ A A A ‘ »
A (c) Protection of Persons Subject to Subpoenas. ‘ A · A . A . e
(1) A party or an attorney responsible for the issuance and A `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, A
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 V A
duty andimpose upon the party or attorney in breach of this duty an _ (i)·requires disclosure of a trade secret or otherAconfidential
A A appropriate sanction which may include, but is not limited to, lost research, development, or commercial information, or
earnings and reasonable »attorney’s fee. A . A . (ii)`requires disclosure of an unretained expert's opinion or A
(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)_ requiresa-person who is 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
A deposition, hearing or trial. · ‘ than 100 miles . ·
(B) Subjectto paragraph (d)(2) of this rule, a person to attend trial; ·
commanded to produce and permit inspection and copying may,A . .
within 14 days after serviceAof the subpoena or before the time the Court may, toprotect 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, ifAthe party in lwhose _
service, serve upon the party or attorney designated inthe 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 · ’
designated materials or of the premises. lf 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 A A appearance or production only upon specified conditions.
the Court by which the subpoena was issued. If objection has been A A A - A A A ,
made,A the party serving the subpoena may, upon notice to the person (Cl) DUTIES II1 R6Sp0I1dII1g to St1bp0Bh3. A A · A _
` commanded to produce, move at any time fo ran order to compel the ‘ · A ·‘-· ~ . ~ · . .-
production. Suchan orderAto compel production shall protect any A (1) A person responding to a subpoena to-produce documents
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,Athe Court by which a subpoena was the demand'. _ .
issued shall quash or modify the subpoena if it _ A· - _ ` . AA ~ . _ .
(i) fails to allow reasonable time for compliance, A (2) When information subject to=`a subpoena is withheldon a
‘ ` (ii) requires a person who is not a party or an officer of a claim that itAis 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 supported
that person resides, is employed or regularly transacts business in by a description of the 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 demandingvparty
this rule, such a person may in order to attend trial be commanded to to contest the . _ - A A A » _ -
travel from any such place within thestate in which the trial is held, claim. . A_ »
or _ , — ‘ . A
(iii) requires disclosure of privileged or other protected A ‘ . A
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