Free Response to Motion - District Court of Arizona - Arizona

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Victoria Kingsley
From: Scott Levine [[email protected]]
Sent: Wednesday, August 10, 2005 8:05 PM
To: David J. Schwab
Cc: Mario Herman
Subject: Depositions — Kahala v. Rilwaia
Gentlemen,
Enclosed please find a revised version of the Deposition Schedule. Please note the following:
l. I am unable to produce the following witnesses and you will need to Serve a proper Subpoena upon
them: Robert Petersen, Ray Dioguardi, Marci Taylor, John Oguzturk, Jerry Conklin. None of these
people are current employees of Kahala.
2. Note that Kathryn Blackwell and Nicole Rayborn will be flying in on the morning of their scheduled
dates/times. They need to return home at the end of the day to be back with their children. As such,
they cannot go over the time allotted. I have scheduled them for l/2 day each as you have requested.
3. Michael Reagan has been scheduled for l day as requested as well. He too, needs to return at the
conclusion of his deposition day to be with his family. His wife recently had a second child and he
camrot be away from home other than for the day at this point in time.
4. For Mr. Shah's deposition on 9/22, I am going to request that it be videotaped. We will take care of
the arrangements for this process.
5. I have been promised for 2 months additional documents from Mr. Pravin Patel's possession. To
date, I have not received anything. I would like to know when I will receive these documents. Can you
please advise? I would like to not have to contact the Court to get this resolved, but I have made
several written and verbal inquiries in this regard.
6. I am preparing a second copy of the documents that have already been produced (at the outset of the
case via Rule 26 Disclosure) on Disk. At the same time, I am having the additional documents
requested by Request for Production added to these disks. I believe that these will be ready in the next
week for mailing to your office.
If you have any questions or wish to discuss this further, please feel free to contact me.
Very truly yours,
Naumann, Levine & Silldorf, LLP
Scott Levine
Case 2:03-cv-02160-JAT Document 158-10 Filed 08/29/2005 Page 1 of 1
8/25/2005

Case 2:03-cv-02160-JAT

Document 158-10

Filed 08/29/2005

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