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Home My WebLink About02-3360SHEILA MILLER AND JOHNNY MILLER VERSUS CIVIL DOCKET NO. 94116-E 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA PETITION FOR LETTER ROGATORY NOW INTO COURT, through undersigned counsel, come defendants, SCOTT DUGAS and PHILLIPS IRON WORKS, INC., who make this application for Letters Rogatory and in support hereof, would show unto the Court the following: The defendants would show that they desire to take the records deposition of the custodian of records of RITE AID CORPORATION, of the County of Cumberlan, City of Camp Hill, State of Pennsylvania, for discovery purposes, and that it is necessary to obtain these records to properly prepare this matter for trial. Defendants respectfully request this Honorable Court to grant an Order in support of this Petition for Letter Rogatory and for same to be forwarded to the competent judicial authority in the County of Cumberlan, City of Carlisle, State of Pennsylvania. The records deposition is noticed for Monday, August 5, 2002, as per the attached Notice of Records Deposition. It is necessary that a deposition subpoena be issued by the appropriate judicial authority in Cumberlan County, City of Carlisle, State of Pennsylvania, compelling the production of the requested documents. WHEREFORE~ defendants, SCOTT DUI,~AS and PHILLIPS IRON WORKS~ INC.~ pray that this Petition for Letter Rogatory be in all things granted, and a certified copy of this application and the Order of this Court, together with a certified copy of the Notice of Records Deposition, be forwarded to the proper judicial authority with this Letter Rot~atr~rv Respectfully submitted: GUGLIELMO, LOPEZ, TUTTLE, HUNTER ~ JARRELL Post Office Drawer 1329 306 East North Street Opelousas, Louisiana 7057 !- 1299 (337) 948-8201 GINA B. TUTTLE ATTORNEY FOR SCOTT DUGAS AND PHILLIPS IRON WORKS, INC. CERTIFICATE I HEREBY CERTIFY that a copy of the foregoing has been forwarded to all known counsel of record by placing a copy of same in the U.S. Mail, postage prepaid and properly addressed this ~ At ck day of ~1.(~[(.¢ 2002. Gina/Bradley ~I'uttle SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA ORDER The Petition for Letter Rogatory is hereby granted and the Clerk of this Honorable Court is directed to transmit to the appropriate judicial authority for the County of Cumberlan, City of Carlisle, State of Pennsylvania, requesting of said Court in and for the County of Cumberlan, City of Carlisle, State of Pennsylvania, to issue a Subpoena Duces Tecum requesting that Rite Aid Corporation produce the documents indicated in the Subpoena Decus Tecum, on Monday, August 5, 2002, at the offices of Guglielmo, Lopez, Tuttle, Hunter & Jarrell, P.O. Drawer 1329, 306 East North Street, Louisiana, Louisiana, 70571. ./ SIGNED at New Iberia, Louisiana this oV day of JUDGE, 16TH JUDICIAL DISTRICT COURT ,2002. SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH LOUISIANA LETTERS ROGATOR¥ TO: Clerk of Court County of Cumberlan Cumberlan County Clerk's Office 1 Courthouse Square Carlisle, Pennsylvania 17013 WHEREAS, ~COTT DUGAS and PHILLIP~ IRON WORKS, INC., has been made defendants in the above entitled and numbered cause before the 16th Judicial District Court, in and for the Parish of Iberia, State of Louisiana; WHEREAS, Rite Aid Corporation is located in Cumberlan County, City of Camp Hill, State of Pennsylvania; WHEREAS, it appears that Rite Aid Corporation has information which is relevant to this case. We therefore request that, in the interest of justice, you issue a deposition subpoena by your proper and usual process, requesting that Rite Aid Corporation produce the requested documents on Monday, August 5, 2002, at the offices of Guglielmo, Lopez, Turtle, Hunter & Jarrell, 306 East North Street, P.O. Drawer 1329, Opelousas, Louisiana, 70571, as per the attached certified copy of the Notice of Records Deposition, which is annexed hereto in order for the said Rite Aid Corporation. Your assistance in this matter is requested and your courtesies appreciated, and we shall be ready and w/lling to do the same for you in a similar case when requested. WITNESSETH, the Honorable District Judge for 16th Judicial District Court, in and for the Parish of Iberia, State of Louisiana, on this ~ day of ~? ,~ ,2002. JUDGE, I6 DISTI~ICT COURT SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116~E VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL ...... · -........................ IBERIA PARISH, LOUISIANA 16TM JUDICIAL DISTRICT COURT PARISH OF IBERIA STATE OF LOUISIANA I, / /~/./.(~ .3 ~ p1'~ f/l~( ~_ , District Judge of the 16~ Judicial District Court, in and for the Parish of Iberia, State of Louisiana, do hereby certify that wrtm,~, ~T~)~n~ , whose signature is attached to the Letter Rogatory herein annexed, was at the date thereof the Clerk of the 164 Judicial District Court, in and for the Parish of Iberia, State of Louisiana, that the official acts and doings of said Clerk are entitled to full faith and credit; and that the testation to the said Letter Rogatory is in due form of law. I further certify that the seal attached to said Letter Rogatory is the seal of this Court. Witnessed my Hand and Seal of said Court in the City of New Iberia, Parish of Iberia, State of Louisiana, this _ . day of // 2002. JUDGE, 16th JUDICIAL DISTRICT COURT SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16T~ JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL ............. · ........ ................ IBERIA PARISH, LOUISIANA 16th JUDICIAL DISTRICT COURT PARISH OF IBERIA STATE OF LOUISIANA Clerk in and for the 16TM Judicial District Court, Parish of Iberia, State of Louisiana, do hereby certify that KEITIt R. J. COl~.tnl[ whose name is signed to the accompanying papers, is now and was at the time of the signing of same, a District Judge in and for the 16th Judicial District Court, Parish of Iberia, State of Louisiana. New In Witness thereof, I have hereunto set the Seal of this District Court in the City of Iberia, Parish of Iberia, State of Louisiana, on this J n~l day of JULY ,2002. CLERK OF COURT 16TH JUDICIAL DISTRICT COURT PARISH OF IBERIA STATE OF LOUISIANA STATE OF LOUISIANA PARISH OF IBERIA _OFFICE OF THE CLFJ~_K OF COURT I IO'EREBY CERTIFY that the above and foregoing constitutes a true and correct cop3, of the original recorded in the records ofrberia Parish, Louisiana, together with the endorsements thereon, as .same now appears on file and of record in this office. ..../.~.~ GIVEN UNDER MY HAND AND SEAL OF OFFICE ON THIS 10Tit DAY OF .... -< -- ,20 02 ~ CLERK OF COURT & EX-OFFICIO RECORDER ._ IBERIA PARISH, LOUISIANA STATE OF LOUISIANA PARISH OF IBERIA I, UNITED STATES OF AMERICA OFFICE OF THE DISTRICT JUDGF KIgITlt R. J. Ct~.&n~ , Judge of the 16e Judicial District Court in and for the Parish of lbena, State of Louisiana, do hereby certify that MICHAEL THIBODEAUX, CLERK OF COURT, whose genuine simaature appears to th~ foregoing certificate, is now and was at the time of signing of same, CLERK of the 16e Judicial District and Ex-officio record for Iberia Parish, Louisiana. State of Louisiana, duly elected, commissioned and qualified as such, and that said attestation is and is in due form of law. GIVEN UNDER MY HAND AND SEAL OF SAID COURT, AT NEW IBERIA, LOUISIANA THIS ~ DAY OF ~ , 20 02 STATE OF LOUISIANA PARISH OF IBERIA ~OFFICE OF THE CLERK OF COUR'i' I, MICHAEL THIBODEAUX, CLERK OF THE 16TM JUDIC/AL DISTRICT COURT in and for the Parish of Iberia, State &Louisiana, and ex-officio Recorder of Mortgages, Conveyances, etc. in and for the Parish of Iberia, Louisiana, do hereby certify that KRITit R. J. COI~UX _, whose signature appears to the foregoing instrument and/or certificate, is now and was at the time of the signing of same, the presiding Judge of the 16~ Judicial District Court, in and for the Parish nflh,~4o e ....... SHEILA MILLER AND JOHNNY MILLER VERSUS SCOTT DUGAS, ET AL CIVIL DOCKET NO, 94116-E 16~ JUDICIAL DISTRICT COURT IBERIA PARISH, LOUISIANA ORDER Considering the above: IT I80RD~P.~D that the Clerk of District Court, do issue a Subpoena Duces Tecum as follows: Rite Aid Corporation 30 Hunter Lane Camp Hill, Pennsylvania 17011 and to produce the following documents: A complete copy of your personnel files regarding Sheila Ann Duplantis Miller, S~N: 435-29-3398, who was employed by K ~k B Drugs in 1991 and 1994, including application for employment, personnel records, file info~mation~ payment and leave information, hiring and discharge summaries, medical information, evaluations, and any and all other records whatsoever in the possession of Rite Aid Corporation. City of [arlisle, Coun~.~f~.~?mberlan, State ~ day of ~ , 2002. of Pennsylvania, this STATE OF PENNSYLVANIA SHEILA MILLER AND JOHNNY MILLER VERSUS CML DOCKET NO. 94116-E 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA PETITION FOR LETTER ROi~ATORY NOW INTO COURT, through undersigned counsel, come defendants, SCOTT DUOAS and PHILLIP~ IRON WORKS, INC., who make this application for Letters Rogatory and in support hereof, would show unto the Court the following: 1. The defendants would show that they desire to take the records deposition of the custodian of records of RITE AID CORPORATION, of the County of Cumberlan, City of Camp Hill, State of Pennsylvania, for discovery purposes, and that it is necessary to obtain these records to properly prepare this matter for trial. 2. Defendants respectfully request this Honorable Court to grant an Order in support of this Petition for Letter Rogatory and for same to be forwarded to the competent judicial authority in the County of Cumberlan, City of Carlisle, State of Pennsylvania. 3. The records deposition is noticed for Monday, August 5, 2002, as per the attached Notice of Records Deposition. 4. It is necessary that a deposition subpoena be issued by the appropriate judicial authority in Cumberlan County, City of Carlisle, State of Pennsylvania, compelling the production of the requested documents. WHEREFORE, defendants, SCOTT DUOAS and PHILLIPS IRON WORKS, INC., pray that this Petition for Letter Rogatory be in all things granted, and a certified copy of this application and the Order of this Court, together with a certified copy of the Notice of Records Deposition, be forwarded to the proper judicial authority with this Letter Roaatorv Respectfully submitted: GUOLIELMO~ LOPEZ, TUTTLE~ HUNTER ~ JARRELL Post Office Drawer 1329 306 East North Street Opelousas, Louisiana 70571-1299 (337) 948-8201 GINA B. TUTTLE ATTORNEY FOR SCOTT DUGAS AND PHILLIPS IRON WORKS, INC. CERTIFICATE I HEREBY CERTIFY that a copy of the foregoing has been forwarded to all known counsel of record by placing a copy of same in the U.S. Mail, postage prepaid and properly dayof ./~ l.(.[{.~ ~ ,2002. addressed this GinalBradley ~i'uttle SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA ORDI~R The Petition for Letter Rogatory is hereby granted and the Clerk of this Honorable Court is directed to transmit to the appropriate judicial authority for the County of Cumberlan, City of Carlisle, State of Pennsylvania, requesting of said Court in and for the County of Cumberlan, City of Carlisle, State of Pennsylvania, to issue a Subpoena Duces Tecum requesting that Rite Aid Corporation produce the documents indicated in the Subpoena Decus Tecum, on Monday, August 5, 2002, at the offices of Guglielmo, Lopez, Tuttle, Hunter & Jarrell, P.O. Drawer 1329, 306 East North Street, Louisiana, Louisiana, 70571. SIGNED at New Iberia, Louisiana this ,2002. JUDGE, 16TM JUDICIAL DISTRICT COURT SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA LETTERS ROOATORY TO: Clerk of Court County of Cumberlan Cumberlan County Clerk's Office 1 Courthouse Square Carlisle, Pennsylvania 17013 WHEREAS, SCOTT DUGAS and PHILLIPS IRON WORKS, INC., has been made defendants in the above entitled and numbered cause before the 16th Judicial District Court, in and for the Parish of Iberia, State of Louisiana; WHEREAS, Rite Aid Corporation is located in Cumberlan County, City of Camp Hill, State of Pennsylvania; WHEREAS, it appears that Rite Aid Corporation has information which is relevant to this case. We therefore request that, in the interest of justice, you issue a deposition subpoena by your proper and usual process, requesting that Rite Aid Corporation produce the requested documents on Monday, August 5, 2002, at the offices of Guglielmo, Lopez, Tuttle, Hunter & Jarrell, 306 East North Street, P.O. Drawer 1329, Opelousas, Louisiana, 70571, as per the attached certified copy of the Notice of Records Deposition, which is annexed hereto in order for the said Rite Aid Corporation. Your assistance in this matter is requested and your courtesies appreciated, and we shall be ready and willing to do the same for you in a similar case when requested. WITNESSETH, the Honorable District Judge for 16th Judicial District Court, in and for the Parish of Iberia, State of Louisiana, on this ~ day of ,~' ,2002. JUDGE, I6 DISTI~ICT COURT SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA 16TM JUDICIAL DISTRICT COURT PARISH OF IBERIA STATE OF LOUISIANA I, , {/~'~* ~ .F;'~' f t4'~( ~ , District Judge of the 16TM Judicial District Court, in and for the Parish of Iberia, State of Louisiana, do hereby certify that wrc~Am. T~T~O])~,m~ , whose signature is attached to the Letter Rogatory herein annexed, was at the date thereof the Clerk of the 16m Judicial District Court, in and for the Parish of Iberia, State of Louisiana, that the official acts and doings of said Clerk are entitled to full faith and credit; and that the testation to the said Letter Rogatory is in due fo~m of law. I further certify that the seal attached to said Letter Rogatory is the seal of this Court. Witnessed my Hand and Seal of said Court in the City of New Iberia, Parish of Iberia, State of Louisiana, this '~ day of ~,~'~/ , 2002. JUDGE, 16m JUDICIAL DISTRICT COURT SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA 16th JUDICIAL DISTRICT COURT PARISH OF IBERIA STATE OF LOUISIANA I, MIC~,~m, THIBODEABX , Clerk in and for the 16TM Judicial District Court, Parish of Iberia, State of Louisiana, do hereby certify that KEITIt R. J. COMFAr0[ whose name is signed to the accompanying papers, is now and was at the time of the signing of same, a District Judge in and for the 16th Judicial District Court, Parish of Iberia, State of Louisiana. In Witness thereof, I have hereunto set the Seal of this District Court in the City of New Iberia, Parish of Iberia, State of Louisiana, on this 1/)~ day of JULY ,2002. CLERK OF COURT 16TH JUDICIAL DISTRICT COURT PARISH OF IBERIA STATE OF LOUISIANA STATE OF LOUISIANA PARISH OF IBERIA OFFICE OF THE CLERK OF COURT I I~-REBY CERTIFY that the above and foregoing constitutes a true and correct cop3, of the original recorded in the records oflbena Parish, Louisiana, together with the endorsements thereon, as same now appears on file and of record in this office. ~'L- GIVEN UNDER MY HAND AND SEAL OF OFFICE ON THIS 10~II DAY OF ~ .I1~¥ ,20 02 -. CLERK OF COURT & EX OFFICIO RECORDER _ IBERIA PARISH, LOUISIANA STATE OF LOUISIANA PARISH OF IBERIA I, UNITED STATES OF AMERICA OFFICE OF THE DISTRICT JUDGE I~.'r'rlt R. J.C. Ol~ang ,Judgeofthel6thJudicialDistrictCourt in and for the Parish of Iberia, State of Louisiana. do hereby certify that MICHAEL THIBODEAUX, CLERK OF COURT, whose genuine signature appears to the foregoing certificate, is now and was at the time of signing of same, CLERK of the 16~ Judicial District and Ex-officio record for Iberia Parish. Louisiana. State &Louisiana, duly elected, commissioned and qualified as such, and that said attestation is and is in due form of law. GIVEN UNDER MY HA_ND AND SEAL OF SAID COURT, AT NEW IBERIA, LOUISIANA THIS ~ DAY OF ~ , 20 02 JUDGE - 16TM JUDiC~aT r~ - IBERIA PARISH, CUISI/~A~ ..... STATE OV OUISIANA PARISH OF IBERIA OFFICE OF THE CLERK OF COURT I, MICHAEL THIBODEAUX, CLERK OF THE 16TM JUDICIAL DISTRI'CT COURT in and for the Parish oflberia, State &Louisiana, and ex-officio Recorder of Mortgages, Conveyances, etc. in and for the Parish of Iberia, Louisiana, do hereby certify that Ki~ITIt R. J. COi~BX _, whose signature appears to the foregoing instrument and/or certificate, is now and was at the time of the signing of same, the presiding Judge of the 16~ Judicial District Court, in and for the Par/eh ,,rn..~ o._. STATE OF LOUISIANA PARISH OF IBERIA OFFICE OF THE CLERK OF COURT I HEREBY CERTIFY that the above and foregoing constitutes a true and correct copy of the original recorded in the records of Iberia Parish, Louisiana, together with the endorsements thereon, as same now appears on file and of record in this office. GIVEN UNDER MY HAND AND SEAL OF OFFICE ON THIS 10TH DAY OF JOLY _, 20 02 CLERK OF COURT & EX-OFFICIO RECORDER IBERIA PARISH, LOUISIANA STATES OF AMERICA STATE OF LOUISIANA PARISH OF IBERIA .OFFICE OF THE DISTRICT JUDGE I, IZIIlt R. J. COm~.AnX , Judge of the 16~ Judicial District Court in and for the Parish of Iberia, State of Louisiana. do hereby certify that MICHAEL THIBODEAUX, CLERK OF COURT, whose genuine signature appears to the foregoing certificate, is now and was at the time of signing of same, CLERK of the 16~h Judicial District and Ex-officio record for Iberia Parish, Louisiana. State of Louisiana, duly elected, commissioned and qualified as such, and that said attestation is and is in due form oflaar. GIVEN UNDER MY HAND AND SEAL OF SAID COURT, AT NEW IBERIA, LOUISIANA THIS --L0_IIL DA~ ,20. 02 . JUDGE - 16TM JUDICIAL / T~~CT COURT IBERIA PARISH, L~UISIANA STATE OF LOUISIANA OFFICE OF THE CLERK OF COURT PARISH OF IBERIA I, MICHAEL THIBODEAUX, CLERK OF THE 16TM JUDICIAL DISTRICT COURT in and for the Parish of Iberia, State of Louisiana, and ex-officio Recorder of Mortgages, Conveyances, etc. in and for the Parish of Iberia, Louisiana, do hereby certify that _ KIIITH R. J. , whose signature appears to the foregoing instrument and/or certificate, is now and was at the time of the signing of same, the presiding Judge of the 16~ Judicial District Court. in and fn~ SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA SUBPOENA DUCESTECUM To: Rite Aid Corporation Custodian of Records 30 Hunter Lane Camp Hill, Pennsylvania 17011 YOU ARE HEREBY COMMANDED, to produce at the offices of Guglielmo, Lopez, Tuttle, Hunter & Jarrell, P.O. Drawer 1329, 306 East North Street, Opelousas, Louisiana 70571, on the 5th day of August, 2002, on behalf of Scott Dugas and Phillips Iron Works, Inc., in a controversy pending herein between the parties above named, and produce the following documents: A complete copy of your personnel files regarding Shella Ann Duplantis Miller, SSN: 435-29-3398, who was employed by K ~ B Drugs in 1991 and 1994, including application for employment, personnel records, file info~-~ation, payment and leave lnfo.~.ation, hiring and discharge summaries, medical information, evaluations, and any and all other records whatsoever in the possession of Rite Aid Corporation. AND FAlL NOT UNDER PENALTY OF CONTEMPT OF COURT. By order of the Honorable 16th Judicial District Court for the Parish of Iberia, Louisiana, on this 10TH day of .11~¥ ,2002. REQUESTED BY: Gina B. Tuttle Guglielmo, Lopez, Turtle, Hunter & Jarrell P.O. Drawer 1329 Opelousas, Louisiana 70571 [337) 948-8201 SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA NOTICE OF RECORDS DEPOSITION To; Curtis Hollinger, Jr. Attorney at Law 2014 West Pinhook Road Suite 503 Lafayette, Louisiana 70508 PLEASE TAKE NOTICE that the undersigned will take the records deposition of the below named individual, pursuant to Louisiana Code of Civil Procedure, for discovery purposes, commencing on the date designated below and thereafter from day to day as the taking of the records deposition may be adjourned, at which time and place you are hereby notified to appear and take part as you feel advisable: CUSTODIAN OF RECORDS DATE Rite Aid Corporation Monday, August 5, 2002 Please produce the following documents: A complete copy of your personnel files regarding Sheila Ann Duplantis Miller, SSN: 435-29-3398, who was employed by K lk B Drugs in 1991 and 1994, including application for employment, personnel records, file information, payment and leave information, hiring and discharge summaries, medical information, evaluations, and any and all other records whatsoever in the possession of Rite Aid Corporation. Respectfully submitted: GUGLIELMO, LOPEZ, TUTTLE, HUNTER/~ JARRELL 321 East North Street P.O. Drawer 1329 Opelousas, Louisiana 70571 (337) 948-8201 CERTIFICATE OF SERVICE I DO HEREBY CERTIFY that a copy of the above and foregoing has been forwarded to opposing counsel by depositing same in the United States Mail, postage prepaid and properly addressed. Opelousas, Louisiana, this ~ ~-~ -":~'(- f' day of ~ ,2002. GINAIB. TUTTLE PLEASE NOTE THAT YOU MAY COMPLY BY MAILING A CERTIFIED COPY OF THE REQUESTED INFORMATION TO GINA B. TUTTLE, P.O. DRAWER 1329, 306 EAST NORTH STREET, OPELOUSAS, LOUISIANA 70571, BY CERTIFIED MAIL. SHEILA MILLER AND CIVIL DOCKET NO. 94116-E JOHNNY MILLER VERSUS 16TM JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH LOUISIANA SUBPOENA DUCESTECUM To: Rite Aid Corporation Custodian of Records 30 Hunter Lane Camp Hill, Pennsylvania 17011 YOU ~ HEREBY COMli~II~)ED, to produce at the offices of Guglielmo, Lopez, Tuttle, Hunter & Jarrell, P.O. Drawer 1329, 306 East North Street, Opelousas, Louisiana 70571, on the 5th day of August, 2002, on behalf of Scott Dugas and Phillips Iron Works, Inc., in a controversy pending herein between the parties above named, and produce the following documents: A complete copy of your personnel files regarding She/la Ann Duplantis Miller, SSN: 435-29-3398, who was employed by K & B Drugs in 1991 and 1994, including application for employment, personnel records, file information, payment and leave information, hiring and discharge summaries, medical information, evaluations, and any and all other records whatsoever in the possession of Rite Aid Corporation. AND FAIL NOT UNDER PENALTY OF CONTEMPT OF COURT. By order of the Honorable 16m Judicial District Court for the Parish of Iberia, Louisiana, on this 10TIt day of ~,.¥ ,2002. REQUESTED BY: Gina B. Tuttle Guglielmo, Lopez, Tuttle, Hunter & Jarrell P.O. Drawer 1329 Opelousas, Louisiana 70571 (337) 948-8201 SHEILA MILLER AND JOHNNY MILLER CIVIL DOCKET NO. 94116-E VERSUS 16TH JUDICIAL DISTRICT COURT SCOTT DUGAS, ET AL IBERIA PARISH, LOUISIANA NOTICE OF RECORDS DEPOSITION To' Curtis Hollinger, Jr. Attorney at Law 2014 West Pinhook Road Suite 503 Lafayette, Louisiana 70508 PLEASE TAKE NOTICE that the undersigned will take the records deposition of the below named individual, pursuant to Louisiana Code of Civil Procedure, for discovery purposes, commencing on the date designated below and thereafter from day to day as the taking of the records deposition may be adjourned, at which time and place you are hereby notified to appear and take part as you feel advisable: CUSTODIAN OF RECORDS DATE Rite Aid Corporation Monday, August 5, 2002 Please produce the following documents: A complete copy of your personnel files regarding Shella Ann Duplantis Miller, $SN: 435-29-3398, who was employed by K ~ B Drugs in 1991 and 1994, including application for employment, personnel records, file information, payment and leave information, hir/ng and discharge summaries, medical information, evaluations, and any and all other records whatsoever in the possession of Rite Aid Corporation. Respectfully submitted: GUGLIELMO, LOPEZ, TUTTLE~ HUNTER/k JARRELL 321 East North Street P.O. Drawer 1329 Opelousas, Louisiana 70571 {337) 948-8201 CERTIFICATE OF SERVICE I DO HEREBY CERTIFY that a copy of the above and foregoing has been forwarded to opposing counsel by depositing same in the United States Mail, postage prepaid and properly addressed. Opelousas, Louisiana, this -- ~ /'~ ~ ~:~'~ /~ day of , ~ ,2002. PLEASE NOTE THAT YOU MAY COMPLY BY MAILING A CERTIFIED COPY OF THE REi~UESTED INFORMATION TO GINA B. TUTTLE, P.O. DRAWER 1329, 306 EAST NORTH STREETs OPELOUSAS~ LOUISIANA 70571~ BY CERTIFIED MAIL. SHERIFF'S RETURN CASE NO: 2002-03360 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MILLER SHEILA ET AL VS DUGAS SCOTT ET AL - REGULAR GEP~ALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within SUBPOENA was served upon RITE AID CORPORATION the law, WITNESS , at 1035:00 HOURS, at 30 HUNTER LANE on the 31st day of ~uly _, 2002 CAMP HILL, PA 17011 HEATHER LEININGER a true and attested copy of by handing to SENIOR PARALEGAL SUBPOENA NOTICE OF RECORDS DISPOSITION together with and at the same time directing He~ attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 11.04 Affidavit .00 Surcharge 10.00 .00 -- 39.04 Sworn and Subscribed to before me this _22_~..{ day of So Answers: R. Thomas Kline 08/01/2002 GUGLIELMO LOPEZ TUTTLE HUNTER Deputy Sh~iff In the Court of Common Pleas of Cumberland County, Pennsylvania To Prothonotary 19 Filed VS. PRAECIPE 19