HomeMy WebLinkAbout11-7430IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
ANDERSON CONTRACTING, INC.,
Petitioner,
VS.
DSM COPOLYMER, INC.,
Respondent.
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PETITION FOR ISSUANCE OF SUBPOENAS
TO NON-PARTIES CARLISLE SYNTEC, INC. AND VERSICO, INC.
FOR USE IN A MATTER PENDING OUTSIDE THE COMMONWEALTH
Pursuant to 42 Pa.C.S. § 5326(a) and Pennsylvania Rules of Civil Procedure 4007.1 and
4009.2 1, Petitioner, Anderson Contracting, Inc. ("Anderson"), by and through counsel,
respectfully petitions this Court to issue subpoenas duces tecum to non-party Carlisle SynTec,
Inc. and non-party Versico, Inc. in the matter, Anderson Contracting, Inc. v. DSM Copolymer,
Inc., Case No. 05771 LACL095959 (Iowa Dist. Ct., Polk County), and in support thereof avers
as follows:
1. Anderson brought an indirect purchaser class action under the Iowa antitrust law
alleging price-fixing of EPDM.
2. The Iowa District Court certified a class of Iowa end-users of EPDM products.
The Iowa Supreme Court has reviewed and affirmed certification of that class.
3. The parties are now proceeding with merits discovery.
4. As part of discovery, Anderson seeks the testimony of corporate representatives
and production of certain materials that are related to its case from non-party Carlisle SynTec,
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Inc. and non-party Versico, Inc., both of which are located in Carlisle, Pennsylvania. See
Subpoenas duces tecum attached hereto as Exhibits A and B, respectively.
5. Petitioner has obtained from the Iowa District Court where its case is pending, for
both Carlisle SynTec, Inc. and Versico, Inc., a Commission for Oral Depositions and Document
Production Outside the State of Iowa ("Commission'), dated June 24, 2011, See Commissions
attached hereto as Exhibits C and D, respectively. The Iowa Court examined the proposed areas
of testimony and the categories of documents to be produced, and concluded that Anderson
satisfied the requirements to obtain such Commissions.
6. Pursuant to Local Rule 208.3(a)(9), Petitioner sought the concurrence of
Respondent DSM Copolymer, Inc. in the filing of this Petition. Counsel for Respondent advised
Counsel for Petitioner that Respondent does not intend to oppose this Petition.
WHEREFORE, Petitioner prays for the following relief:
The Court grant this Petition for Issuance of Subpoenas to Non-Parties Carlisle
SynTec, Inc. and Versico, Inc. For Use In A Matter Pending Outside the
Commonwealth:
2. The Court grant Petitioner leave to serve Subpoenas duces tecum on Carlisle
SynTec, Inc.; and Versico, Inc. and
3. Grant such other and additional relief as may be just and appropriate.
Dated: September 26, 2011 Respectfully submitted,
Krishna B. Narine (Bar No. 52238 y? '
Law Office of Krishna B. Narine, PC
101 Greenwood Ave. Suite 600
Jenkintown, PA 19046
k.narinekkbnlaw.com
Phone: (215) 277-5770
VERIFICATION OF PETITIONER
I, Krishna Narine, hereby state:
1. I am attorney for Petitioner Anderson Contracting, Inc. in this action;
2. I verify that the statements contained in the foregoing Petition for Issuance of
Subpoenas to Non-Parties Carlisle SynTec, Inc. and Versico, Inc. For Use In A Matter Pending
Outside The Commonwealth are true and correct to the best of my knowledge, information, and
belief, and
I understand that the statements in the Petition for Issuance of Subpoenas to Non-
Parties Carlisle SynTec, Inc. and Versico, Inc. For Use In A Matter Pending Outside The
Commonwealth are subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn
falsification to authorities.
Krishna B. Narme (Bar No. 52238)
Attorney for Petitioner, Anderson
Contracting, Inc.
Dated: September 26, 2011
EXHIBIT A
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ANDERSON CONTRACTING, INC. .
Plaintiff File No.
vs.
DSM COPOLYMER, INC.
Defendant
SUBPOENA TO ATTEND AND TESTIFY
TO: Carlisle Syntec, Inc., Carlisle, PA
c/o The Prentice-Hall Corporation System, 2704 Commerce Dr., Harrisburg, PA 17110
You are ordered by the court to come to
Law Office of Krishna B. Narine, PC, 101 Greenwood Ave. Suite 600
(Specify Courtroom or other place)
at Jenkintown , Montgomery County, Pennsylvania, on October 24, 2011
at 10:00 o'clock, A. M,. to testify on behalf of
Anderson Contracting, Inc.
in the above case, and to remain until excused.
2. And bring with you the following:
See attached Schedule A.
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If you fail to attend or to produce the documents or things required by this
subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the
Pennsylvania Rules of Civil Procedure, including but not limited to costs, attorney fees
and imprisonment.
REQUESTED BY A PARTY/ATTORNEY IN COMPLIANCE WITH Pa.R.C.P.No.234.2(a):
Name: Krishna Narine
Address: 101 Greenwood Ave. Suite 600
Jenkintown, PA 19046
Telephone: (215) 277-5770
Supreme Court ID # 52238
BY THE COURT:
Prothonotary/Clerk, Civil Division
Date:
Seal of the Court Deputy
Official Note: This form of subpoena shall be used whenever a subpoena is issuable, including
hearings in connection with depositions and before arbitrators, masters, commissioners, etc. in
compliance with Pa. R.C.P.No.234.1. If a subpoena for a production of documents, records or
things is desired, complete paragraph 2. (Eff. 7/97)
SCHEDULE A
Instructions
1. For purposes of this document request, the term "EPDM" shall refer to ethylene propylene
diene monomor synthetic rubber.
2. The term "Document," as used herein, is defined to be synonymous with the broadest
possible meaning of the word "documents" as that word is used in Federal Rules of Civil Procedure
34, and shall include but is not limited to hard copy writings and documents as well as electronically
stored information. With respect to electronically stored information, the term "Document" also
includes, without limitation, any data on magnetic or optical storage media stored as an "active" file
or backup file, in its native format.
The term "relating to" means, without limitation, discussing, describing, reflecting,
concerning, dealing with, pertaining to, analyzing, evaluating, estimating, constituting, studying,
surveying, projecting, assessing, recording, summarizing, criticizing, reporting, commenting or
otherwise involving, in whole or in part.
4. For purposes of this document request, "You" or "Your" shall refer to Carlisle SynTec, Inc.
5. Unless otherwise noted, the relevant time period of this document request is January 1994
through December 2002 (the "relevant time period")
Documents To Be Produced
1. Documents sufficient to identify the EPDM-containing roofing materials, pond liners and/or
automotive products that you bought, sold or handled in any way during the relevant time period.
All documents relating to your purchase, acquisition or procurement of EPDM-
containing roofing materials. This document request includes but is not limited to documents
relating to cost, shipping, terms, conditions, source and origin of the EPDM-containing roofing
materials.
All documents relating to Your purchase, acquisition or procurement of EPDM-containing
pond liners. This document request includes but is not limited to documents relating to cost,
shipping, terms, conditions, source and origin of the EPDM-containing pond liners.
4. All documents relating to your purchase, acquisition or procurement of EPDM-containing
automotive products. This document request includes but is not limited to documents relating to cost,
shipping, terms, conditions, source and origin of the EPDM-containing automotive products.
5. All documents relating to your sales of EPDM-containing roofing materials. This document
request includes but is not limited to documents relating to price, pricing methodology, quantity,
terms, conditions, shipping, marketing, distribution, supply, inventory, or end uses of EPDM-
containing roofing materials.
6. All documents relating to Your sales of EPDM-containing pond liners. This document
request includes but is not limited to documents relating to price, pricing methodology, quantity,
terms, conditions, shipping, marketing, distribution, supply, inventory, or end uses of EPDM-
containing pond liners.
All documents relating to Your sales of EPDM-containing automotive products. This
document request includes but is not limited to documents relating to price, pricing methodology,
quantity, terms, conditions, shipping, marketing, distribution, supply, inventory, or end uses of
EPDM-containing automotive products.
8. All reports, studies, forecasts, business plans, projections, analyses, articles, papers, and
presentations relating to markets for EPDM-containing roofing materials, pond liners and/or
automotive products, whether published or not, or in draft or final form.
9. All documents constituting, embodying, reflecting or containing communications between
You and any marketer, wholesaler, distributor, packager or manufacturer of EPDM-containing
roofing materials, pond liners and/or automotive products.
2
10. All documents constituting, embodying, or containing communications between You and any
officers, employees, agents or representatives of any producer of EPDM containing products,
including but not limited to Bayer AG; Bayer Polymers, LLC N/K/A Bayer Materialscience, LLC;
Bayer Corporation; Crompton Corporation; Uniroyal Chemical Company, Inc. N/K/A Crompton
Manufacturing Company, Inc.; Dow Chemical Company; El Dupont De Nemours & Company;
Dupont Dow Elastomers LLC; DSM Copolymer, Inc.; DSM Elastomers Europe B.V.; Exxon Mobil
Chemical Corporation DB/A Exxon Mobil, Inc.
11. All documents constituting, embodying, reflecting or containing communications between
You and any officers, employees, agents or representatives of any purchaser of EPDM-containing
roofing materials, pond liners and/or automotive products.
12. For each year during the relevant time period, documents (e.g. personnel directories)
sufficient to identify all persons in your company who had any responsibility relating to the
production, manufacture, distribution, marketing, pricing, or sale of EPDM-containing roofing
materials, pond liners and/or automotive products.
13. With respect to the persons identified in response to No. 12 above, documents (e.g.
organizational charts) sufficient to describe the positions and responsibilities of such persons.
14. For each year during the relevant time period, documents sufficient to show Your
aggregate gross profits, aggregate net profits, per unit gross profits, and per unit net profits
attributable to Your sales of EPDM-containing roofing materials, pond liners and/or automotive
products.
3
EXHIBIT B
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ANDERSON CONTRACTING, INC.
Plaintiff
vs.
DSM COPOLYMER, INC.
Defendant
File No.
SUBPOENA TO ATTEND AND TESTIFY
TO: Versico, Inc., Carlisle, PA
c/o The Prentice-Hall Corp. System, 2704 Commerce Dr., Harrisburg, PA 17110
You are ordered by the court to come to
Law Office of Krishna B. Narine, PC, 101 Greenwood Ave. Suite 600
(Specify Courtroom or other place)
at Jenkintown , Montgomoery County, Pennsylvania, on October 25, 2011
at 10:00 o'clock, A. M,. to testify on behalf of
Anderson Contracting, Inc.
in the above case, and to remain until excused.
2. And bring with you the following:
See attached Schedule A.
L
If you fail to attend or to produce the documents or things required by this
subpoena, you may be subject to the sanctions authorized by Rule 234.5 of the
Pennsylvania Rules of Civil Procedure, including but not limited to costs, attorney fees
and imprisonment.
REQUESTED BY A PARTY/ATTORNEY IN COMPLIANCE WITH Pa.R.C.P.No.234.2(a):
Name: Krishna B. Narine
Address: 101 Greenwood Ave. Suite 600
Jenkintown, PA 19046
Telephone: (215) 277-5770
Supreme Court ID # 52238
BY THE COURT:
Prothonotary/Clerk, Civil Division
Date:
Seal of the Court Deputy
Official Note: This form of subpoena shall be used whenever a subpoena is issuable, including
hearings in connection with depositions and before arbitrators, masters, commissioners, etc. in
compliance with Pa. R.C.P.No.234.1. If a subpoena for a production of documents, records or
things is desired, complete paragraph 2. (Eff. 7/97)
SCHEDULE A
Instructions
For purposes of this document request, the term "EPDM" shall refer to ethylene propylene
diene monomor synthetic rubber.
2. The term "Document," as used herein, is defined to be synonymous with the broadest
possible meaning of the word "documents" as that word is used in Federal Rules of Civil Procedure
34, and shall include but is not limited to hard copy writings and documents as well as electronically
stored information. With respect to electronically stored information, the term "Document" also
includes, without limitation, any data on magnetic or optical storage media stored as an "active" file
or backup file, in its native format.
3. The term "relating to" means, without limitation, discussing, describing, reflecting,
concerning, dealing with, pertaining to, analyzing, evaluating, estimating, constituting, studying,
surveying, projecting, assessing, recording, summarizing, criticizing, reporting, commenting or
otherwise involving, in whole or in part.
4. For purposes of this document request, "You" or "Your" shall refer to Versico, Inc.
Unless otherwise noted, the relevant time period of this document request is January 1994
through December 2002 (the "relevant time period")
Documents To Be Produced
1. Documents sufficient to identify the EPDM-containing roofing materials, pond liners and/or
automotive products that you bought, sold or handled in any way during the relevant time period.
2. All documents relating to your purchase, acquisition or procurement of EPDM-
containing roofing materials. This document request includes but is not limited to documents
relating to cost, shipping, terms, conditions, source and origin of the EPDM-containing roofing
materials.
3. All documents relating to Your purchase, acquisition or procurement of EPDM-containing
pond liners. This document request includes but is not limited to documents relating to cost,
shipping, terms, conditions, source and origin of the EPDM-containing pond liners.
4. All documents relating to your purchase, acquisition or procurement of EPDM-containing
automotive products. This document request includes but is not limited to documents relating to cost,
shipping, terms, conditions, source and origin of the EPDM-containing automotive products.
5. All documents relating to your sales of EPDM-containing roofing materials. This document
request includes but is not limited to documents relating to price, pricing methodology, quantity,
terms, conditions, shipping, marketing, distribution, supply, inventory, or end uses of EPDM-
containing roofing materials.
6. All documents relating to Your sales of EPDM-containing pond liners. This document
request includes but is not limited to documents relating to price, pricing methodology, quantity,
terms, conditions, shipping, marketing, distribution, supply, inventory, or end uses of EPDM-
containing pond liners.
7. All documents relating to Your sales of EPDM-containing automotive products. This
document request includes but is not limited to documents relating to price, pricing methodology,
quantity, terms, conditions, shipping, marketing, distribution, supply, inventory, or end uses of
EPDM-containing automotive products.
8. All reports, studies, forecasts, business plans, projections, analyses, articles, papers, and
presentations relating to markets for EPDM-containing roofing materials, pond liners and/or
automotive products, whether published or not, or in draft or final form.
9. All documents constituting, embodying, reflecting or containing communications between
You and any marketer, wholesaler, distributor, packager or manufacturer of EPDM-containing
roofing materials, pond liners and/or automotive products.
2
10. All documents constituting, embodying, or containing communications between You and any
officers, employees, agents or representatives of any producer of EPDM containing products,
including but not limited to Bayer AG; Bayer Polymers, LLC N/K/A Bayer Materialscience, LLC;
Bayer Corporation; Crompton Corporation; Uniroyal Chemical Company, Inc. N/K/A Crompton
Manufacturing Company, Inc.; Dow Chemical Company; El Dupont De Nemours & Company;
Dupont Dow Elastomers LLC; DSM Copolymer, Inc.; DSM Elastomers Europe B.V.; Exxon Mobil
Chemical Corporation DB/A Exxon Mobil, Inc.
11. All documents constituting, embodying, reflecting or containing communications between
You and any officers, employees, agents or representatives of any purchaser of EPDM-containing
roofing materials, pond liners and/or automotive products.
12. For each year during the relevant time period, documents (e.g. personnel directories)
sufficient to identify all persons in your company who had any responsibility relating to the
production, manufacture, distribution, marketing, pricing, or sale of EPDM-containing roofing
materials, pond liners and/or automotive products.
13. With respect to the persons identified in response to No. 12 above, documents (e.g.
organizational charts) sufficient to describe the positions and responsibilities of such persons.
14. For each year during the relevant time period, documents sufficient to show Your
aggregate gross profits, aggregate net profits, per unit gross profits, and per unit net profits
attributable to Your sales of EPDM-containing roofing materials, pond liners and/or automotive
products.
3
EXHIBIT C
IN THE IOWA DISTRICT COURT FOR POLK COUNTY
ANDERSON CONTRACTING, INC., on
behalf of itself and all others similarly
situated,
Plaintiffs,
V.
DSM COPOLYMER, INC.,
Defendants.
No. 05771 LACL095959
COMMISSION
FOR ORAL DEPOSTIONS AND
DOCUMENT PRODUCTION OUTSIDE
THE STATE OF IOWA
(Carlisle SynTec Inc., Carlislej; A)
TO THE APPROPRIATE JUDICIAL AUTHORITY: €-`
The Plaintiffs' Application for Issuance of a Commission for Oral Depositions 4hi
Document Production outside of the State of Iowa, together with Exhibits "A";, B'%-`"_'C"
and "D" has been filed with the Court. This Court has previously certified this Iowa
indirect purchaser class action, involving the sale of products to the end-user Class
members containing EPDM. The Iowa Supreme Court has since reviewed and affirmed
such certification.
The parties are now proceeding with merits discovery. As attached to the
Application, this Court has examined the proposed areas of testimony for out-of-state
non-parry corporate representative witnesses and corresponding categories of
documents to be requested in relations to merits discovery in this case.
The Court finds that Plaintiffs have satisfied the requirements to obtain a
Commission requesting the appropriate out-of-state court to issue a non-party witness
corporate representative subpoena and subpoena duces tecum. See Iowa Code
section 622.84(2) and I. R. Civ. Proc. 1.714.
J ,
Therefore, pursuant to the issuance of this Commission, this Court requests that
the appropriate out-of-state court issue a non-party witness corporate representative
subpoena and subpoena duces tecum, regarding Carlisle SynTec Inc., in Carlisle,
Pennsylvania. Such oral depositions shall be taken by:
Krishna B. Narine (admitted pro hac vice)
LAW OFFICES OF KRISHNA NARINE
101 Greenwood Ave., Suite 600
Jenkintown, PA 19046
and/or ?
1N?+p???WNK3 Di#7E
Isaac L. Diel (admitted pro hac vice) JUN I I toll
SHARP MCQUEEN, P.A.
6900 College Blvd., Suite 285
Overland Park, KS 66211
16
Signed this 24th day of June, 2011.
JLft)dt D. J. STOVALL
District Court Judge
Fifth Judicial District of Iowa
Polk County
Copies to:
Joseph R. Gunderson - iaundersonta?midwest-law.com
Isaac L. Diel (admitted pro hac vice) - idiel(a)sharpmcgueen.com
Rex A. Sharp (admitted pro hac vice) - rsharp(amidwest-law.com
Krishna Narine (admitted pro hac vice) - knarine _kbnlaw.com
ATTORNEYS FOR PLAINTIFFS
Edward W. Remsburg - eremsburg d-)ahlerslaw.com
Andrew S. Marovitz (admitted pro hac vice) - amarovitzccDmayerbrown.com
Britt M. Miller (admitted pro hac vice) - bmiller(cDmayerbrown.com
Gary A. Winters (admitted pro hac vice) - gwinters(cDmayerbrown.com CERTIFICATE
1. Randy Osborn, Clerk of the District Court of the
Amanda G. Wachuta - awachutat?a ahlerslaw.cam State of fovea, in and to yolk Count ,
?rtify.that this is a true W comp;efe copy of the
Richard J. Favretto - rfavretto(a?_mayerbrown.com ginal instrument &!c in this ofce.
(N TESTIMONY WttEREOF, t have hereunto set
ATTORNEYS FOR DEFENDANT DSM Copolymer, Inc. my hand and affixed the s
o e2t cf said Court at my
office in Moines, tcwa this (yc ,
•-2- --?--._:.. clay of
RAUv y oseoR -
ev! - Irk gf the Diftrict court
EXHIBIT D
ANDERSON CONTRACTING, INC., on
behalf of itself and all others similarly
situated,
Plaintiffs,
V.
DSM COPOLYMER, INC.,
Defendants.
No. 05771 LACLO95959
COMMISSION
FOR ORAL DEPOSTIONS AND
DOCUMENT PRODUCTION OUTSIDE
THE STATE OF IOWA
(Versico, Carlisle, Pennsylva-ia)
TO THE APPROPRIATE JUDICIAL AUTHORITY: -
The Plaintiffs' Application for Issuance of a Commission for Oral Depositions and
Document Production outside of the State of Iowa, together with Exhibits "A", "B", "C"
and °D" has been filed with the Court. This Court has previously certified this Iowa
indirect purchaser class action, involving the sale of products to the end-user Class
members containing EPDM. The Iowa Supreme Court has since reviewed and affirmed
such certification.
The parties are now proceeding with merits discovery. As attached to the
Application, this Court has examined the proposed areas of testimony for out-of-state
non-party corporate representative witnesses and corresponding categories of
documents to be requested in relations to merits discovery in this case.
The Court* finds that Plaintiffs have satisfied the requirements to obtain a
Commission requesting the appropriate out-of-state court to issue a non-party witness
corporate representative subpoena and subpoena duces tecum. See Iowa Code
section 622.84(2) and I. R. Civ. Proc. 1.714.
I
Therefore, pursuant to the issuance of this Commission, this Court requests that
the appropriate out-of-state court issue a non-parry witness corporate representative
subpoena and subpoena duces tecum, regarding Versico, in Carlisle, Pennsylvania.
Such oral depositions shall be taken by:
Krishna B. Narine (admitted pro hac vice)
LAW OFFICES OF KRISHNA NARINE
101 Greenwood Ave., Suite 600
Jenkintown, PA 19046
and/or
Isaac L. Diel (admitted pro hac vice)
SHARP MCQUEEN, P.A.
6900 College Blvd., Suite 285
Overland Park, KS 66211
Signed this 24th day of June, 2011.
CORIE57I ON
TIf411QWMi16DATE
JUN 2 7 2011
M ?Q
PLTF ATTY: PLTF. U
DEFT. ATT1?: DEFT.
J E D J. STOVALL
District Court Judge
Fifth Judicial District of Iowa
Polk County
Copies to:
Joseph R. Gunderson - jqunderson(a)midwest-law.com
Isaac L. Die{ (admitted pro hac vice) - idiela-sharpmcgueen.com
Rex A. Sharp (admitted pro hac vice) - rsharp(v_)midwest-law.com
Krishna Narine (admitted pro hac vice) - knarine(a)kbnlaw.com
ATTORNEYS FOR PLAINTIFFS
Edward W. Remsburg - eremsburgCa}.ahlersiaw.com
Andrew S. Marovitz (admitted pro hac vice) - amarovitz(a)-mayerbrown.com
Britt M. Miller (admitted pro hac vice) bmiller(a)mayerbrown.com _
Gary A. Winters admitted pro hac vice awinters(a)-mayerbrown.com CERTIFICATE
ry ( ) - I, Randy Oshom, Clerk of the District COUrt of the
Amanda G. Wachuta - awachuta(cDahlerslaw.com state of Iowa, in and for Potk County, do hereby
certifv that this is a true and complete copy of the
filed in this office.
Richard J. Favretto - rfavretto(c?mayerbrown.co original Instruinent
m IN TESTIMCNY WHEREOF, I have hereunto set
ATTORNEYS FOR DEFENDANT DSM CoPolymer, Inc. my hand and affixed the Seal of sa- W my
office in s Moines, Iowa this -_dayof,
uMo_
"2- RANDY OSBORN
` A A Clgrk cf the Rstnct court
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing Petition for Issuance of Subpoenas
to Non-Parties Carlisle SynTec, Inc. and Versico, Inc. For Use In A Matter Pending Outside The
Jurisdiction was filed in the Pennsylvania Court of Common Pleas for Cumberland County. In
addition, I caused copies of the same to be sent via electronic mail to the following:
Britt M. Miller
MAYER BROWN LLP
71 South Wacker Drive
Chicago, IL 60606
bmillerkmayerbrown. com
Gary A. Winters, Esq.
MAYER BROWN LLP
1999 K Street, N.W.
Washington, D.C. 20006-1101
gwinters nmayerbrown. c om
Counsel for DSM C
Inc.
Edward W. Remsburg
AHLERS & COONEY, P.C.
100 Court Avenue, Suite 600
Des Moines, IA 50309-2231
eremsburggahlerslaw. com
Date: September 26, 2011
i
Krishna B. Narine
LAW OFFICE OF KRISHNA B. NARINE,
P.C.
10l Greenwood Ave. Suite 600
Jenkintown, PA 19046
Telephone: (215) 277 -5770
Facsimile: (215) 277-5771
E-mail: knarine@kbnlaw.com
Counsel for Petitioner