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

Case 1 :05-cv-00300-JJF Document 71 Filed O4/07/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
CREEDON CONTROLS, INC., a Delaware )
corporation, )
) C.A. NO. 05-CV-300-JJF
Plaintiff, )
)
v. )
)
BANC ONE BUILDING CORPORATION, an )
Illinois corporation, and FOREST )
ELECTRIC CORPORATION, a New York )
corporation, )
Defendants. )
)
)
NOTICE OF DEPOSITION DUCES TE C UM
PLEASE TAKE NOTICE that counsel for Defendant Banc One Building
Corporation will take the deposition, under oath, of Patricia Creedon, commencing on May 22,
2006, at 9:30 a.m., and will continue thereafter from day to day until completed, at the law offices
of Ashby & Geddes, 222 Delaware Avenue, l7th Floor, Wilmington, Delaware. Deponent shall
produce any and all records set forth in the attached Exhibit A.
PLEASE TAKE FURTHER NOTICE, that the deposition will be taken before a
notary public or other officer authorized to administer oaths. The deposition shall be recorded by
stenographic means as well as by videotape.
LEGAL_US_E # 70692730.].

Case 1 :05-cv-00300-JJF Document 71 Filed O4/07/2006 Page 2 of 3
Dated: April 6, 2006 ASHBY & GEDDES, P.
Byzé g Q
Philip Trainer (DE Bar ID # 2788)
Ricardo Palacio (DE Bar ID # 3765)
222 Delaware Avenue
17th Floor
P.O. Box 1150
Wilmington, Delaware 19899
(302)-654-1888
Attorneys for Defendant Banc One Building
Corporation
168352.1
LEGAL__US_E # 70692730.].

Case 1 :05-cv-00300-JJF Document 71 Filed O4/07/2006 Page 3 of 3
EXHIBIT A
l. Any and all documents in your possession relating to work done by Creedon
Controls, Inc. ("Creedon") at the Banc One Core Data Center in Wilmington, Delaware (the
"Proj ect"), including, inter alia, contract documents, e-mail and other correspondence, and
records of costs and expenses.
2. Any and all documents in your possession relating to the costs of and staffing on
all other work done by Creedon during the same period Creedon was working on the Proj ect.
3. Any and all documents in your possession relating to all discussion, negotiations,
correspondence, and communication with regard to the formulation of any contract between
Creedon Controls, Inc. ("Creedon") and Banc One Building Corporation ("Banc One") and/or
Forest Electric Corporation ("Forest Electric") related to work to be performed by Creedon at the
Banc One Core Data Center in Wilmington, Delaware (the "Proj ect").
4. Any and all documents in your possession relating to the nature and extent of the
contractual obligations of Creedon with respect to the Proj ect.
LEcAL_us_E # 70692730.1