HomeMy WebLinkAbout98-00881
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IN'r!!RlIACIONAL AGRICOLA, LTDA. -VS-
COMMUNITY BANK OF HOMl!lST!!AIl, I!:T AL.
DAD!! COUNt! CAB!! No. _ 95-04086-01.-27
for Dade county, Florida, bearing Case No. 95-040B6-CA (27), (the
"Florida action,")
2. plaintiff INTERNACIONAL AGRICOLA, LTDA., desires to
conduct deposition discovery upon a corporate representative having
the most knowledge, of Lee Associates, a corporate entity having
residence in the state of Pennsylvania, county of cumberland, \~hich
plaintiff believes may possess information which is material and
relevant to the allegations which are the subject matter of the
Florida action.
3. Attached to this motion as Exhi.bit "A" is a copy of
the Notice of Taking Corrorate Deposition as filed in the Florida
action, which:
a. sets forth the areas of inquiry upon which
Plaintiff wishes to depose the appropriate corporate representative
of Lee Associates having the most knowledge; and
b. sets forth the date, tIme and place for the
deposition to occur w.ithin Cumberland county, Pennsylvania,
4. Plaintiff requests the Court or Prothonotary of
Cumberland County, Pennsylvania, to issue or cause to be issued a
Subpoena for corporate Deposition directed to Lee Associates, of
the state of pennsylvania, County of cumberland, said subpoena to
be served under the laws of the State of Pennsylvania, requiring
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IIITIIRNACIONM. AORICOLA, LTDA. -VS-
OOMMUlUTY BAIllt or HOMI!lS'RAD, I!:T M..
DADIl OOIlllTY OASI: No, 95-04086-0A-27
VOU ARE COMMANDED to appear before Central pennsylvania Court
.Reporting servi.ces, or other person authorized by law to take
depositions, on Tuesday, February 24, 1998, at 10:00 a.m., at the
New Cumberland County Courthouse, 4th floor conference room, One
Courthouse square, CarliSle, Pennsylvania, 17013, for taking of
your deposition in thi.s acti.on. Vou should designate one or more
persons to testify who have the most knowledge regarding the
following:
1. All business transactions by and between Lee Associates,
and either or any of the Plaintiff Internacional Aqricola Ltda., or
Defendant coaaunity Bank of Ho.estead, or Third Party Defendants
Gary Avins, Nega Marketing and Brokerage, Xnc., and Bee Natural
Honey co., named above, related to the purchase of Chilean onions
during the period of time January 1, 1994, through and including
August 1, 1994.
2. All documents, including, but not 11mi ted to purchase
contracts, agreements, bills of lading, purchase orders, invoices,
cancelled checks, bills, notes, warehouse receipts, trucking
reoeipts, and drafts reflecting or relating to the purchase of
Chilean onions from either or any of the Plaintiff, Defendant, or
Third Party Defendants named above during the period of time
January 1, 1994, through and inoluding August 1, 1994.
If you tail to appear, you ..y be in conte.pt of court. Vou
are subpoenaed to appear by the following attorneys and, unless
excused from this subpoena by these attorneys or the court, you
shall respond to this subpoena as directed.
Dated at Carlisle, Cumberland County, Pennsylvania, this
day of February, 1998,
Prothonotary
Cumberland county Court
BY:
Deputy
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