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

Case 1:05-cv-00022-MPT

Document 84

Filed 03/22/2006

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
ST. PAUL MERCURY INSURANCE COMPANY, and PACK & PROCESS, INC. Plaintiff, MALY YAN Defendant : : : : : : :

Civil Action No. LEAD CASE

05-0022 (KAJ)

_____________________________________________________________________________ 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 : VS. : : PACK & PROCESS, INC. : AND : ST. PAUL MERCURY INSURANCE : COMPANY : Defendants :

NOTICE OF DEPOSITIONS TO: Francis J. Deasey, Esquire Deasey, Mahoney & Bender, LTD 1800 John F. Kennedy Blvd. Suite 1300 Philadelphia PA 19103

PLEASE TAKE NOTICE that Yan Thou will take the oral deposition of Corporate Designee of Pack and Process on May 17, 2006 starting at 10:00 a.m. at the law office of Kline & Specter, P.C., 1525 Locust Street, 19th Floor, Philadelphia PA 19102. The Corporate Designee deponent is to bring with him/her any and all records in their possession, custody and control that refer, relate and/or pertain to the incident described in Plaintiffs' Complaint including any and all documents requested in discovery regarding the

Case 1:05-cv-00022-MPT

Document 84

Filed 03/22/2006

Page 2 of 3

employment of Yan Thou and Maly Yan. These documents are to include: 1) employment contracts, times sheets, personnel files, yearly evaluations, pay stubs, insurance
agreements and/or contributions or savings plans, W4 documents for Maly Yan and Yan Thou showing their choices for federal income tax deductions, social security, medicare, state, unemployment, federal and local tax records filed by Pack and Process for five years preceding this incident. 2) any insurance company documents, payments, invoices, contracts, or benefit plans listing employees covered by any plans of Pack and Process for 1997, 1998,1999, 2000, 2001, any property and/or automobile insurance covering vehicles for Pack and Process including vehicles parked on their property from 1997 through 2001. 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, 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. 4) any claims presented to and/or 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 of the Defendants or anyone on behalf of any of the Defendants from 1998 through 2002.

The oral examinations will continue from day to day until concluded. You are invited to attend and participate in this examination. WEISS AND SAVILLE, P.A. BY: S/Yvonne Takvorian Saville, Esquire YVONNE TAKVORIAN SAVILLE, ESQUIRE 1220 North Market Street Suite 604 P.O. Box 370 Wilmington DE 19801 (302) 656-0400 and

DATED: 3/17/06

Case 1:05-cv-00022-MPT

Document 84

Filed 03/22/2006

Page 3 of 3

KLINE & SPECTER, P.C. BY: S/Jonathan M. Cohen, Esquire/ JC593 JONATHAN M. COHEN, ESQUIRE JOSHUA VAN NAARDEN, ESQUIRE 1525 Locust Street, 19th Floor Philadelphia PA 19102 (215) 772-1000