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

Case 1:07-cv-00735-JJF Document 19 Filed 02/14/2008 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
IN AND FOR THE DISTRICT OF DELAWARE
KATHRYN L. FITZGIBBON, *
LAUREN M. FLEMING, and *
ALL SIMILARLY SITUATED CURRENT *
AND FORMER EMPLOYEES OF *
ING BANK, fsb, AND ITS WHOLLY *
OWNED SUBSIDIARIES, *
Plaintiffs, *
* C.A. NO. 07-735 (JJF)
=l¤
v. *
>l=
ING BANK, fsb, (a Delaware corporation), *
and ALL OTHER WHOLLY OWNED * JURY TRIAL DEMANDED
SUBSIDIARIES OF ING BANK, fsb, *
WHICH HAVE EMPLOYED *
SIMILARLY SITUATED CURRENT *
AND FORMER EMPLOYEES SINCE *
November 15, 2004, *
NOICE OF DEPOSITION
PLEASE TAKE NOTICE that pursuant to Rule 30(b)(6) of the Federal Rules of
Civil Procedure, Plaintiffs Kathryn L. Fitzgibbon and Lauren M. Fleming ("Plaintiffs"),
by and through their undersigned attorneys, will take the deposition of ING Bank, fsb’s
Rule 30(b)(6) witness by oral testimony before an officer duly authorized to administer
an oath, commencing at 10:00 a.m. on Monday February 25, 2008, at the offices of
Martin & Wilson, P.A., 1508 Pennsylvania Avenue, Wilmington, DE 19806. The
deposition shall continue thereafter until terminated by counsel for the Plaintiff. The
deposition will be recorded stenographically and/or videographically and/or
audiographically, before a Notary Public or other officer authorized to administer oaths in
Delaware, and will be for the purpose of discovery of evidence and for use at trial.

Case 1:07-cv-00735-JJF Document 19 Filed 02/14/2008 Page 2 of 3
MARTIN & ON, P.A.
nm
Tim 5 J. Wi l'1(DE Bar1.D. 4323)
1508 imsyl . ia Avenue
Wilm gton, ll 19806
(302) 777-4681 telephone
(302) 777~5803 facsimile
[email protected]
Attorney for Plaintwfc
DATED: February 14, 2008
cc: Wilcox & Fetzer

Case 1:07-cv-00735-JJF Document 19 Filed 02/14/2008 Page 3 of 3
CERTIFICATE OF SERVICE
I, Timothy J. Wilson, hereby certify that on Friday, February 14, 2008, I caused
the attached Notice of Deposition to be served on the following attorneys of record via
CM/ECF:
David Phillip Primack
Drinker Biddle
1 100 North Market sneer
Suite 1000
Wilmington, DE 19801-1254
MARTIN & ' 1 ON, P.A.

Tim hy J. F i . DE Bar I.D. 4323)
1508 ennsyl - . Ave
Wilmington, I 9806
(302) 777-46 elephone
(302) 777-58 i 3 facsimile
twilson@martina11dm¢i1son.com
Attorney for Plaint%*
DATED: February 14, 2008

Case 1:07-cv-00735-JJF

Document 19

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Case 1:07-cv-00735-JJF

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Case 1:07-cv-00735-JJF

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