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

Case 1:04-cv-01551-JJF Document 305 Filed 08/10/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
MBIA INSURANCE CORPORATION, et al.
Plaintiffs and C.A. N0. 02-1294-JJF
Counterclaim Defendants, :
v.
ROYAL INDEMNITY COMPANY,
Defendant and
Counterclairn Plaintiff :
ROYAL INDEMNITY COMPANY,
Third~Pa1‘ty Plaintiff
v.
ANDREW N. YAO, et al.,
Third—Pa1‘ty Defendants.
ROYAL INDEMNITY COMPANY,
Counter-Claimant,
v.
MBIA BANK., et al.,
Counter-Defendants.
63lI96vl

Case 1:04-cv-01551-JJF Document 305 Filed 08/10/2007 Page 2 of 4
CHARLES A. STANZIALE, JR.,
CHAPTER 7 TRUSTEE OF STUDENT :
FINANCE CORPORATION, :
Plaintiff, C.A. N0. O4~155l—JJF
PEPPPER HAMILTON LLP, et al.,
Defendants.
CHARLES A. STANZIALE, JR.,
CHAPTER 7 TRUSTEE OF STUDENT :
FINANCE CORPORATION, :
Plaintiff, C.A. No. 05-72—JJF
McGLADREY & PULLEN LLP, et al.,
Defendants.
ROYAL INDEMNITY COMPANY,
Plaintiff, C.A. N0. O5—l65-UF
PEPPER HAMILTON LLP, et al.,
Defendants.
NOTICE OF DEPOSITION OF GEOFFREY C. HAZARD, JR.
PLEASE TAKE NOTICE that, pursuant t0 Rules 26 and 30 0f the Federal Rules
0f Civil Procedure as well as the Second Amended Case Management Order #1 entered

Case 1:04-cv-01551-JJF Document 305 Filed 08/10/2007 Page 3 of 4
by the Court on June 14, 2007, plaintiff Charles A. Stanziale, Jr., Chapter 7 Tmstee of
Student Finance Corporation, will take the deposition upon oral examination of Geoffrey
C. Hazard, Jr., beginning on Friday, August 17, 2007, at 9:30 a.m., at the offices of
Schnader Harrison Segal & Lewis LLP, One Montgomery Street, Suite 2200, San
Francisco, CA 94104. Professor Hazard is directed to produce at the deposition all
documents that he reviewed and upon which he relied in connection with his formation of
the opinions he has expressed and intends to express in the above—captioned actions that
were not disclosed in the report that Professor Hazard submitted in the above—captioned
actions.
Defendants, their counsel and Professor Hazard are further directed to produce at
the deposition all writings, including any statements of the facts in this matter, prepared
by Pepper Hamilton LLP or its counsel and provided to Professor Hazard in connection
with his formation of the opinions he has expressed and intends to express in the above-
captioned actions.
Defendants, their counsel and Professor Hazard are also directed to produce at the
deposition any and all reports, affidavits, opinions, and memoranda prepared at any time
by Professor Hazard as an expert or consultant which refer to or concern the conduct of
Pepper Hamilton LLP or any of its attomeys.
The deposition shall be recorded stenographically. The deposition will continue
from day to day until completed pursuant to the provisions of the Second Amended Case

Case 1:04-cv-01551-JJF Document 305 Filed 08/10/2007 Page 4 of 4
Management Order #1. All counsel of record are invited to attend and participate.
Dated: August 10, 2007 _ W
Wilmington, Delaware THE BAYARD FIM}/r`\\
I
A ·—— /
. tit ,> ..
D . ir rc ,
Charlene D. D; is, Esquire (N0. 2336)
Mary E. August ne (No. 4477)
222 Delaware Avenue, Suite 900
P.O. Box 25130
Wilmington, Delaware 19899
Telephone: (302) 655-5000
-a_nd-
Michael S. Waters, Esquire
McElroy, Deutsch, Mulvaney &
Carpenter, LLP
Three Gateway Center
100 Mulberry Street
Newark, NJ 07102-4079
(973) 622-7711
Counsel for Charles A. Stcznziale, Jr.,
Chapter 7 Trustee
63ll96vl