Free Subpoena - District Court of Delaware - Delaware

"°" “"· ""‘ S $3;-;L -:- é,—;-9--;--—;-=,=1—;-;-~;-----.- --4;-— ----;-;-;-;-;-;-;-g- —=-Q-,-A--im;
UNITED STATES DISTRICT COURT _ ( (
FOR THE DISTRICT OF DELAWARE · 0, . if A
JENNIFER RENZI AND JEFFREY RENZI
SUBPOENA IN A CIVIL CASE
v. Case Number 04-707 GMS
DELAWARE SUPERMARKETS, ET AL
TO: * Records Keeper for: Protection Technology, lnc., Attn: Personnel Records, 2 lnternational Plaza,
Suite ll8, Philadelphia, PA l9l l3
El YOU ARE COMMANDED to appear in tho United States District Court at the place, date, and time
specihed below to testify in the above case.
PLACE OF TESTIMONT COURTKOOM
DATEANDTIME
XYOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the
taking of a deposition in the above case.
PIACE OE DEPOSl'l`l0N DATE AND TIME
TYBOUT, REDFEARN & PELL, 300 Delaware Avenue, llth May r9, 2005
Floor, Wilmington, DE 19801 *000 3-'“·
YOU ARE COMMANDED to produce and permit inspection and copying of the following documents
o ` ts at the place, date, and time specihed below (list documents or objects):
* Personnel records, reports, medical records, reports, and any other writings regarding Jennifer Renzi
(formerly known as Jennifer Losalt), date of birth: 6/2/72, SS#: 208-62-l750. : NOTE: Your appearance
is waived if the records are received in this ofhce by the date ofthe deposition.
PLACE DATE AND TIME
Tybout, Redfeam & Pell yu lll rtw
El YOU ARE COMMANDED to permit insrection of the following premises at the date and time
specihed below.
PREJ/IISES I DATEANDTIME
Any organization not a party to this suit that is subpaenaed for the taking of a deposition shall designate
one or more officers, directors, or managing agents, or other persons who consent to testify on its behalf,
and may set forth, for each person designated, the matters on which the person will testify. Federal Rules
0[ Civil Procedure 30(QJ(6J.
REQUESTING PARTYS NAME, ADDRESS AND PHONE NUMBER
B. WILSON REDFEARN, ESQUIRE, TYBOUT, REDFEARN & PELL, 300 DELAWARE
AVENUE, 11TH FLOOR, P.O. BOX 2092, WILMINGTON, DE 19899
ISSUINGPAllT\'SSll]lAl`llllEANDlTT|.E|lNDlCATEIEATPORNEYFOJlPLAlNTlFF0llDEFENDAN'D I l` if DATE'
wp x (¢lp,_\l9,2005
Attorney- for Delaware Sugermarkets . Q ;»—
*lf action is pending in district other than district ofissuance, sta{e district under case number.

, Case 1.04-cv-00707-GMS Document 34 Filed 04/28/2005 Pa e 2 of 2
I- PROOF OF SERVICE I
om
SERVED
strtvroonpruerrnxirq itttwrtonutvrct

SElt\'ED BY (PRINT NAME) rm;
RETURN OF SERVICE
On April 26, 2005 at 5:20 p.m., I served the within records
DECLA subpoena on Protection Technology, Inc., Personnel Records, 2
International Plaza, Suite 118, Philadelphia, PA 19113: Service
I declare under H { . d was accepted by Mark Bognar.
pcm Y 0 perjury un cr Ideclare under penalty of perjury under the laws of the State of Delaware
COHl2tltl€tI lll lil€ Pl‘O0l0l`S€l1lIC€ is ll'll€ lllltl COll€Cl. that the foregoing information contained in the Proof of Service is true and
Executed or . By: DONNA M. HAASE, Process Server
DATE 824 Market St. Suite 112
Wilmington, DE 19801
302-388-7978
SWORN TO AND SUBSCRIBED before me, a tary Public of the State of
Deaware, this 26th day f priI’200
Fre erick T. aase, r., Notary Public
My commission ex ires: 12/16/07

Rule 45, Federal Rules of Civil Procedure, Parts C & Il
(c) Protection of Persons Subject to Subpoenas.
ll) A party or an attorney responsible for the issuance and service of a (ii) requires disclosure of an unretarned expert’s opinion or
subpoena shall tale reasonable steps to avoid imposing undue burden or information not describing specific events or occurrences in dispute and resulting
expense on a person subject to that subpoena. The court on behalf of which the fromtheexpertsstudyrnadenotattherequestofanyparty,or (iii) requires
subpoena was issued shall enforce this duty and impose upon the party or a person who is not a party or an officer of a party to incur substantial expense
attorney in breach of this duty an appropriate sanction which may include, but totravelmorethanlddrniles
rs not limited to, lost earnings and reasonable attorneysfee. to attend trial;
l2llA) A person commanded to produce and permit inspection and copying
of designated books, papers, documents or tangible things or inspection ol the Court may, to protect a person subject to or affected by the subpoena, quash
premises need not appear in person at the place of production or inspection or modify the subpoena or, if the party in whose behalf the subpoena is issued
unlesscommandedtoappearfordepositbn,hearingortrial, shows a substantial need for the testimony or material that cannot be otherwise
lBl Subject to paragraph (d)(2) of this rule, a person commanded to met without undue hardship and assures that the person to whom the subpoena
produce and permit inspection and copying may, within ll days after service of is addressed will be reasonably compensated, the Court may order appearance
the subpoena or before the time specified for compliance if such time is less than orproductiononlyuponspecihedconditions.
lil days alter service, serve upon the party or attorney designated in the
subpoena written objection to inspection or copying of any or all of the (CI) DUTIES II'1 RGSpOI'1dII'1g to SUbpOGI'18.
designated materials or of the premises. lf objection is made, the party serving
the subpoena shall not be entitled to inspect and copy the materials or inspect li) A person responding to a subpoena to produce documents shall produce
the premises except pursuant to an order of the Court by which the subpoena them as they are lrept in the usual course of business or shall organize and label
was issued, If objection has been made, the party serving the subpoena may, themtocorrespondwiththecategoriesinthedemand.
upon notice to the person commanded to produce, move at any time fo ran order
to compel the production. Such an order to compel production shall protect any (2) When information subject to a subpoena is withheld on a claim that it
person who is ncl a party or an officer of a party from significant expense is privileged or subject to protection as trial preparation materials, the claim shall
resultinglromtheinspectionandcoppngcommanded. be made expressly and shall be supported by a description ol the nature of the
(3l(Al On timely motion, the Court by which a subpoena was issued shall documents, communications, or things not produced that is sufficient to enable
quash or rnodily the subpoena if it the demanding party to contest the
li) fails to allow reasonable titre for corrpliance, claim.
liil requires a person who is not a party or an officer of a party to
travel to a place more than l00 miles from the place where that person resides,
is employed or regularly transacts business in person, except that, subject to the
provisions ol clause lcll3l(B)liii) of this rule, such a person may in order to attend
trial be commanded to travel from any such place within the state in which the
trial is held, or
liir) requires disclosure of privileged or other protected matter and no
exception or waiver applies, or
liv) subjects a person to undue burden,
lB)lfasubpoena
li) requires disclosure of a trade secret or other confidential
research, devdopment, or comriercial information, or

Case 1:04-cv-00707-GMS

Document 34

Filed 04/28/2005

Page 1 of 2

Case 1:04-cv-00707-GMS

Document 34

Filed 04/28/2005

Page 2 of 2