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


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Date: December 31, 1969
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State: Delaware
Category: District Court of Delaware
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Case 1:04-cv-01266-SLR Document 190-2 Filed 10/11/2005 Page 1 of 3
EXHIBIT A

Case 1:04-cv-01266-SLR Document 190-2 Filed 10/11/2005 Page 2 of 3
UNITED STATES DISTRICT COURT
For the District of Colorado
-----—-—-----—----- - ---— ~ ~-—--— —·-— ~—--——· -··-·· ~»—~ ·~ »——~~ ·~ -~—-— ··X
in re )
TELEGLOBE COl\/ll\/lUNiCATlOl\tS ) SUBPOENA (N A CIVIL CASE
CORPORATION, etal., )
i
D bt 0 Chapter it
__________________________________,________ ?___2T _________ X) Jointly Administered
TELEGLOBE coivrrnunicnrions ) Bank" CBGB ND) 02***5*3 (WW)
CORPORAUON, et ai., }
>
Plaintiffs, )
V g CASE NUMBER: 04-1266 (SLR)
) District of Delaware
BCE INC , et ai., )
l
Defendants. )
—-----—~---—------—---~—--— ·· -—--—-—-—-—--—-———---—--—————--— X
TO: ll/licnaei Neumann
c/o Timothy l\/tactllonaid (by agreement)
Arnotd & Porter, LLP
370 Seventeenth Street
Denver, Coiorado 80202
E YOU ARE COl\/tl)/IANDED to appear in the United States District Court at the ptace, date, and time specified beiow to
testtf in the above case.
mice oe resriivlorvv coenrnoorvi
orare me time
X YOU ARE COMMANDED to appear at the place, date and time specified below to testify at the taking of a deposition tn
the above case.
Ponce oe oenosirion one Amo r1Me·
Arnoid Sm Porter, LLP October 28. 2005
370 Seventeenth Street 0:00 Bm Mm-
DBHVBE-’ Culcfado 80202 "To continue day to day unlél compteta
(excludéng Saturdays. Sundays, and legal
holidays)
li;] YOU ARE COMMANDED to produce and permit inspection and copying of the foiiowing documents or objects at the
iace, date, and time s ecified below list documents or obects :
orare Amo nine
El YOU ARE COMMANDED to permit inspection of the foiiowing premises at the date and time specified below.
ppggmgsgg DATE AN?] TiME
iss we oeercen veneer ngno re ueioicnre irrxrronrvev Fon euxinrirr on oeeenorinr} DATE
1 4...... 1*. ' 1
.=ren McKinley, Attorney f Plaintiffs October 1 (_ 2005
ass "V oeerceas movie, noone eno Peoria ridneen
Karen ll/tcl Richards, Layton Si Finger
One Rodney Square, P. O. Box 551
Wilmington, DE 19899
(302) 651-7700
iztri-2¤s2690-r

Case 1:04-cv-01266-SLR Document 190-2 Filed 10/11/2005 Page 3 of 3
PROOF OF SERVICE
DATE PLACE
SERVED
SERVES ON (PRINT NAME} MANNER OF SERViCE
SERVED BY (PRINT NAME) TITLE
DECLARATION OF SERVER

l declare under penalty of perjury under the laws ofthe United States of America that the foregoing information
contained in the Proof of Service is true and correct.
Executed on
DATE SIGNATURE GF SERVER
ADDRESS OF SERVER
Rute 45. Federal Rules of Civil Procedure. Parts C & O:
tc) PROTECTION OF PERSONS SUBJECT TO SUBPOENAS person. except that, subject to the provisions of clause (c)(3}(B)(iii) ot this rule,
such a person rnay in order to attend trial be commanded to travel from any such
(1) A party or an attorney responsible for the issuance and sewice place within the state in which the trial is hetd, or
of a subpoena shalt take reasonable steps to avoid imposing undue (iii) requires disclosure ot privileged or other protected matter and no
burden or expense on a person subject to that subpoena The court on exception or waiver applies, or
behaif of which the subpoena was issued shall eniorce this duty and (iv} subjects a person to undue burden
impose upon the party or attorney in breach of this duly an appropriate (B) lf a subpoena
sanction, which may include, but is not limited to. lost earnings and a (E) requires disclosure of a trade secret or other contidentiat research,
reasonable attorneys fee development. or commercial information, or
(2}(A) A person commanded to produce and permit inspection and (ii) requires disclosure of an unretained experts opinion or
copying ot designated books, papers, documents or tangible things, or information not describing specific events or occurrences in dispute and
inspection of premises need not appear In person at the place of resulting from the experts study made not at the request ofany party. or
production or inspection uniess commanded to appear for deposition, (iii) requires a person who is not a party or an officer of a party to
hearing or trial incur substantial expense to travel more than 100 miles to attend trial, the
(B) Subject to paragraph (d}(2} of this rule, a person commanded to court may, to protect a person subject to or affected by the subpoena,
produce and permit inspection and copying may, within 14 days after quash or modify the subpoena or, ifthe party in whose behalf the subpoena
service of the subpoena or before the time specified for compliance if is Issued shows a substantiai need for the testimony or rnateriat that cannot
such time is toss than 14 days after service. serve upon the party or be otherwise met without undue hardship and assures that the person to
attorney designated in the subpoena written objection to inspection or whom the subpoena is addressed will be reasonabty compensated, the
copying of any or all of the designated materials or ofthe premises lf coun may order appearance or production only upon specified conditions
objection is rnade. the party sewing the subpoena shaft not be entitled to
inspect and copy the rnateriais or inspect the premises except pursuant to (dj DLiTiES iN RESPONDING TO SUBPOENA
an order of the court by which the subpoena was issued if objection has
been made. the pany sewing the subpoena may, upon notice to the (1) A person responding to a subpoena to produce documents shail
person commanded to produce. move at any time for an order to compel produce them as they are itept in the usual course of business or shalt organize
the production. Such an order to cornpel production shall protect any and label them to correspond with the categories in the demand
person who is not a party or an officer of a party from significant expense
resulting from the inspection and copying commanded. (2} When information subject to a subpoena is withheld on a ctaim that it
(3)(A) On a timely motion, the court by which a subpoena was is privileged or subject to protection as trial preparation materials, the claim shall
issued shalt quash or modify the subpoena if it be made expressly and shall be supported by a description ot the nature of the
(E) fails to aliow reasonable time for compliance; documents. communications, or things not produced that is sufficient to enabte
(ii} requires a person who is not a party or an officer of a party the demanding party to contest the ctaim
to travet to a place more than SOG rnites from the place where that
person resides. ls empioyed or regularly transacts business in
2
Rtli I -2932.o99-l