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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO
Civil Action No. 04-F-1823 (BNB) GERALD M. HAASE, M.D., Plaintiff, v. JEFFERSON PILOT FINANCIAL INSURANCE COMPANY, Defendant.
NOTICE OF DEPOSITION AND REQUEST TO PRODUCE
NORMAN CARRIER AND COUNSEL OF RECORD
PLEASE TAKE NOTICE that on Tuesday, October 25, 2005, beginning at the hour of 8:30 a.m., counsel for Plaintiff will take the deposition of Norman Carrier, Technical Consultant, at Jefferson Pilot Financial, Concord, New Hampshire, or at such other location to be specified, before a certified shorthand reporter, until completed, at which time and place your presence is required. YOU ARE REQUESTED TO PRODUCE and have present at your deposition all original documents, correspondence, internal memoranda, claim manuals, electronic files and email activity, including but not limited to, Defendant's original claim and underwriting files. Respectfully submitted this 19th day of September, 2005 TAFFET LAW, P.C. s/ Steven Taffet _________________________________ Steven Taffet 2305 Broadway Boulder, CO 80304 (303) 449-2830 Attorney for Plaintiff
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CERTIFICATE OF SERVICE I hereby certify that on September 19, 2005, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addressee. Kevin O'Brien HALL & EVANS LLC 1125 17th Street, Suite 600 Denver, Colorado 80202 s/ Lacy Sorrells