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Home My WebLink About99-07724?' 2 y N 11 d Q k ', ,ii :?;% ?:??;`, GEORGE ALEXANDER, ET AL VERSUS INGERSOLL-RAND, ET AL r1FC - 19 t ?9-'772Y Cloy( NUMBER 53,836 DIVISION "B11 16TH JUDICIAL DISTRICT COURT PARISH OF ST. MARTIN STATE OF LOUISIANA *,r,r*****r***?**+*****,t*rr,r********t**r*,t***«,tr*.«+r********r**?r?,r*r*r**** ORDER FOR LETTER ROGATORY Considering the foregoing Petition for Letters Rogatory and attached Oaths: IT IS HEREBY ORDERED, that a subpoena for deposition appearance shall be issued to Chris Etter, residing at 106 Middle Spring Road, Shippensburg, PA in Cumberland County, for his appearance on January 10, 2000 at the Clarion Hotel and Convention Center located at 1700 Harrisburg Pike, Carlisle, PA 17013. Signed ( in Carlisle, Pennsylvania, this Vie? day of JU GE J I O%UON LEE OVERTON ATTORNEYS AT LAW. INC. 172 THIRD STREET BATON ROUGE. U 70801 235.344-0071 z1 C' O O GEORGE ALEXANDER, ET AL VERSUS INGERSOLL-RAND, ET AL NUMBER 53,836 DIVISION "B" 16TH JUDICIAL DISTRICT COURT PARISH OF ST. MARTIN STATE OF LOUISIANA SUBPOENA IN A CIVIL CASE TO TAKE DEPOSITION NOTICE TO APPEAR TO: CHRIS ETTER 106 Middle Spring Road Shippensburg, PA Cumberland County You are commanded to appear at Clarion Hotel and Convention Center, meeting room, at 1700 Harrisburg Pike in Carlisle, Pennsylvania on the 19`h day of January at 1:00 p.m. to be examined by oral deposition to the truth according to your knowledge and of facts relevant to the subject matter in the above entitled and numbered cause. Herein fail not under penalty of law. This service was ordered by attorney Lee Overton and was issued by the 0V<.1<1lJlr LEE OVERTON ATTORNEYS AT LAW, INC. IM THIRD STREET BATON ROUGE. U 70901 2455/1-0071 Prothonotary's Office on the +'! day of anU.OS y , 2000 . gm-0i -A) a im- 02.h &A) Deputy Prothonotary f Cumberland County r- Ci' _ i= C)i ..... ?'I -? 1- C? ? I ':'1 t-- r.-. J iJ i? .+ ,......,_.? OIl??11111 , STATE OF LOUISIANA PARISH OF ST. MARTIN I, ALLEN BLANCHARD, SR., CLERK OF COURT, Ex-Offico Recorder in and for the Parish of St. Martin, State of Louisiana, do hereby certify that I am, the duly elected and qualified Clerk of Court in and for the Parish of St. Martin, State of Louisiana. IN FAITH WHEREOF, Witness my hand and the impression of the seal of my said office this 22nd day of December , 19 99 CLERK OF COURT, IN AND FOR ST. MARTIN PARISH, LOUISIANA STATE OF LOUISIANA PARISH OF ST. MARTIN I, PAUL J. deMAHY , one of the duly elected and qualifed Judges of the Sixteenth Judicial District Court in and for the Parish of St. Martin, State of Louisiana, do hereby certify that ALLEN BLANCHARD, SR., is the duly elected and qualified Clerk of Court in and for the Parish of St. Martin, State of Louisiana. IN FAITH WHEREOF, Witness my hand and the impression of the seal of my said office, this 22nd day of December , 19 99 uuu r, N FOR ?SfI 0 ST IN, STATE OF LOUISIANA STATE OF LOUISIANA PARISH OF ST. MARTIN I, ALLEN BLANCHARD, SR., CLERK OF COURT, Ex-officio Recorder in and for the Parish of St. Martin, State of Louisiana, duly elected and qualified, do hereby certify that PAUL J. deMAHY is one of the duly elected and qualified Judges of the 16th Judicial District Court in and for the Parish of St. Martin, State of Louisiana. IN FAITH WHEREOF, Witness my hand and the impression of the seal of my said office this 22nd day of December , 1999 . CLERK OF COURT, IN AND FOR ST. MARTIN PARISH, LOUISIANA GEORGE ALEXANDER, ET AL VERSUS INGERSOLL-RAND, ET AL NUMBER 53,836 DIVISION "B" 16TH JUDICIAL DISTRICT COURT PARISH OF ST. MARTIN STATE OF LOUISIANA TO TAKE OF The petition of Plaintiff, George Alexander, with respect represents: Chris Etter is a significant witness in regards to the manufacturing defect of the MT- milling machine manufactured by defendant, Ingersoll-Rand, which is the subject of the captioned suit. 2. Chris Etter resides at 106 Spring Road, Shippensburg, PA, a location outside the jurisdiction 1 this Court. 3. Petitioner has noticed the deposition of Chris Etter to be taken at the Clarion Hotel Convention Center meeting room, located at 1700 Harrisburg Pike, Carlisle, Pennsylvania on 10, 2000 at 1:00 p.m. WHEREFORE, Plaintiff, George Alexander prays that a letter rogatory issue to appropriate authority in Cumberland County commissioning him to take the deposition of Chris BY ATTORNEYS: O%UUN LEE OVERTON ATTORNEYS AT LAW. INC. 132 THIRD STREET BATON ROUGE. U 70001 225.344-0071 14- RECCUED I "LED ion? n='' 42t7 r1 'I: 7 f cLEI I, Ur L' irr"r sT I.. 3TI a r? l :f LEE OVERTON ATTORNEYS AT LAW 132 THIRD STREET BATON ROUGE, LA 70801 PHONE: (225) 344-0071 FACSIMILE: (225) 344-0075 1 W. LEE OVERTON .(131r-Roll:-1031ti)__._..__ ? n ? CERTIFICATE I hereby certify that a copy of the above and foregoing has been mailed, postage prepaid and properly addressed to: Mr. Edward P. Landry LANDRY & WATKINS 211 East Main Street Post Office Drawer 12040 New Iberia, Louisiana 70562-2040 Mr. William H. Robinson, Jr., WRIGHT, ROBINSON, MCCAMMON, OSTHIME 411 E. Franklin St., 4th Floor Richmond, Virginia 23219-1115. Mr. R. Michael Moity, Jr. Assistant Attorney General Louisiana Department of Justice Division of Risk Litigation Suite 400, Gordon Square 100 E. Vermillion Street Lafayette, LA 70501 Baton Rouge, Louisiana, this 1?day of December, 1999. W. LEE OVERTON der LEE OVERTON ATTORNEYSATUW, INC. 192 TNIRO STREET BATON ROUGE, U 70501 225.9/10071 GEORGE ALEXANDER, ET AL VERSUS INGERSOLL-RAND, ET AL NUMBER 53,836 DIVISION "B" 16TH JUDICIAL DISTRICT COURT PARISH OF ST. MARTIN STATE OF LOUISIANA **«***,t**r+r*t**?*,r*******t++*rr****,r**«*?*,t«,r+«,ttrr****«,tfr•«**«?«*r**r«* ORDER FOR LETTER ROGATORY TO: CUMBERLAND COUNTY COURTHOUSE PROTHONOTARY'S OFFICE 1COURTHOUSESQUARE CARLISLE, PA 17013 In the 161h Judicial District Court for the Parish of St. Martin of the State of A N LEE OVERTON ATTORNEYSAT LAW, INC. 172 THIRD STREET BATON ROUGE. IA 70001 225.7/10011 Louisiana there is pending a case entitled "George Alexander, et al vs. Ingersoll' Rand, et al", bearing Docket No. 53,836 on the docket of said Court, and it appears to this Court that the just determination of the issues therein presented requires that testimony be taken from Chris Etter, who resides at 106 Middle Spring Road, Shippensburg, PA in Cumberland County. It is therefore requested that you assist the Court in serving the interests of justice by causing Chris Etter to appear on January 10, 2000 at Clarion Hotel and Convention Center in the meeting room, 1700 Harrisburg Pike, Carlisle, PA 17013, before you, or before a competent officer authorized by you, and require him to submit to a deposition for all purposes allowed by law, and that you have his deposition reduced to writing, and cause the deposition to be returned to this Court under cover and duly sealed, addressed to the Clerk of the 161h Judicial District Court for the Parish of St. Martin Parish of the State of Louisiana. This Court is ready and willing to extend the same courtesies to your government in a similar case when required. Si red in St. Martinville, 1999. RECCpL-n r;:; FLED N19 PC- 0 Louisiana, this A& day of S5 JUDGE PA L MAHY r, COPY a ?so®®ns GEORGE ALEXANDER, ET AL VERSUS NUMBER 53,836 DIVISION "B" 16TIl JUDICIAL DISTRICT COURT PARISH OF ST. MARTIN INGERSOLL-RAND,CO., ET AL STATE OF LOUISIANA ?,r,t««*r**«r,rr****,t*rr*.**r*«««t*r*«rr***r*a«?r«*rtr****..a***«*,t**+r«**««r*r*?*rr« ! RE-NOTICE OF VIDEO TRIAL DEPOSITIONS TO: Edward P. Landry, Esq. LANDRY & WATKINS 211 East Main Street Post Office Drawer 12040 New Iberia, Louisiana 70562-2040 Mr. William H. Robinson, Jr. WRIGHT, ROBINSON, MCCAMMON, OSTHIME 411 E. Franklin St. 4th Floor Richmond, Virginia 23219-1115 R. Michael Moity, Jr., Esq Assistant Attorney General Suite 400, Gordan Square 100 E. Vermillion Street Lafayette, LA 70501 NOTICE IS HEREBY GIVEN that W. Lee Overton, attorney for plaintiffs, George Alexander, et al, will take the oral and video trial depositions of the following individuals at the date, time and place listed below: DEPONENT T-j*ME' 4t! DATE . ' z* ' Y PLACED' y,", A 7 t Chris Etter 1:00 P.M. Monday Clarion Hotel & January 10, 2000 Convention Center 1700 Harrisburg Pike Carlisle, PA 17013 These depositions will be taken for all purposes authorized by the Louisiana Code of Civil Procedure. These depositions will be taken before, Geiger & Loria, a certified court reporter and shall continue from day to day until they are completed. RESPECTFULLY SUBMITTED: i W. LEE OVERTON LEE;OVERTON ATTORNEYS AT LAW, INC. 132 THIRD STREET BATON ROUGE, LA 70801 REGEr,' :D r'.iD i'PR NE: (225) 344-0071 BARRO L ]0 19 D -7r- 20 d&rnv LEE OVERTON ATTORNEYSATIAW,INC. 172 THIRD STREET BATON ROUGE, 1A 70901 225-714.0071 'y. l ! 1 i. I' ?I CERTIFICATE I hereby certify that a copy of the above and foregoing has been mailed, postage prepaid and properly addressed to: Edward P. Landry, Esq. LANDRY & WATKINS 211 East Main Street Post Office Drawer 12040 New Iberia, Louisiana 70562-2040 William H. Robinson, Jr., Esq. WRIGHT, ROBINSON, MCCAMMON, OSTHIME 411 E. Franklin St., 4th Floor Richmond, Virginia 23219-1115 R. Michael Moity, Jr., Esq. Assistant Attorney General Suite 400, Gordan Square 100 E. Vermillion Street Lafayette, LA 70501 Baton Rouge, Louisiana, this I I day of December, 1999. -v, W'uLd:?? W.LEE ERT N d&DN LEE OVERTON ATTORNEYSATIAW.INC. 132 THIRD STREET BATON ROUGE, lA 70001 225.344-0071 J c --j SHERIFF'S RETURN - REGULAR CASE NO: 1999-07724 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ALEXANDER GEORGE VS INGERSOLL-RAND CHRISTPHER EVANS Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within PETITION FOR LETTERS ROGA was served upon ETTER CHRIS the RESPONDANT at 0014:05 HOURS, on the 7th day of January , 2000 at 106 MIDDLE SPRING ROAD SHIPPENSBURG, PA 17257 by handing to CHRIS ETTER a true and attested copy of PETITION FOR LETTERS ROGA together with OATHS FROM THE COURT, NOTICE OF DEPOSITION, SUBPOENA IN CIVIL CASE TO TAKE DEPOSITION and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 13.02 Affidavit .00 Surcharge 10.00 .00 41.02 Sworn and Subscribed to before me this 3/,.,,f- day of C 1.5....x...<,..., L6-n-1 A. D. Prothonotary' So Answers- Thomas Kline 01/10/2000 LEE OVERTON By: ? ? -? v-7,: L / ,ti Deputy Sheriff