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Home My WebLink About95-02348 ~ .' ~ .1 J . " l' " ~~\~ , I' \ " '" ~ ~ \. ,~ . , , . I ,~ t ~ ('. ". " , ..... . k ~ ... , ~ .. (':~ .. ~ ,-. ,'. ') " " ~, ! (J, \, 'J '~, j.: , \ . ""- \ , . I;S<) "- ..J '" .~ . :J ~ \;~ C, , '" ~ 8 ,... Q :; lil - ~ N ::: \Q-- ..... ~ " c:: :l: '5 .~ E. ::c: :i VI g ~ ~ f-.. . ~ ~ ::: ~ ~ 5 c::~Vi.El'l -- '" - ,ld ;:1 0 "" r:o U? ~~]~~ c:: I"t 'E _ ~ N.s~ ....~ ~ " . MAY () 2 lYY:1 I 4. Pursuant to Rulcs 28 and 28(i) of thc Supcrior Court Rulcs of Civil Proccdure of the District of Columbia, Plaintiff has issucd II Notice of Dcposition of Peter Glen for May 10, 1995 at 9:30 a.m. at the law ollices of Lavery & Kain, Suite 610. 212 Locust Street, Harrisburg, Pennsylvania 17101. True and correct copies of the Notice of Deposition. Ccrtificate of Servicc and Ccrtificatc Regarding Discovcry are attach cd hcreto and are markcd as Exhibit "A". 5. On April 3. 1995, thc Honorable Stephen G. Millikcn. Judgc, Superior Court of the District of Columbia, Civil Division issucd a Commission and Order directing that the testimony of certain matcrialwitnesses, including Pcter Glcn be takcn on oral exumination. de bene ~ and/or lor discovcry and to be rcad as evidence in the above cntitled cause. True and correct copies of Judge Milliken's Ordcr and Commission are attached hcreto and are marked as Exhibit "B". 6. Peter Glen resides outside the jurisdiction and subpoena powers of the Supcrior Court of the District of Columbia, Civil Division. 7. Pursuant to 42 Pa.C.P.S. g5961 !U. sea.. this Honorable Court is authorized to issuc a Subpocna compclling Petcr Glcn's attcndancc at thc dcposition on May 10, 1995 at the law officcs of Lavcry & Kaill in Harrisburg, Pcnnsylvania. 2 " 4. Pursuant to Rules 28 and 2H(i) of the Superior Court Rules of Civil Procedure of the District of Columbia, Plaintiff has issued a Notice of Deposition Duces Tecum to Peter Glenn for May 8, 1996 at 9:30 a.m. at the Law Offices of Lavery & Kain, Suite 800, 301 Market Street, Harrisburg, Pennsylvania 17101. True and correct copies of the Notice of Deposition Duces Tecum, Certificate of Service and Certificate Regarding Discovery are attached hereto and are marked as Exhibi t "A". 5. On April 11, 1996, the Honorable Steffen W. Graae, Judge, Superior Court of the District of Columbia, Civil Division issued a Commission and Order directing that the testimony of certain material witnesses, including Peter G. Glenn be taken by oral examination, de bene esse and/or for discovery and to be read as evidence in the above entitled case. True and correct copies of Judge Graae's Order and Commission are attached hereto and are marked as Exhibit "B". 6. Peter G. Glenn resides outside the jurisdiction and subpoena powers of the Superior court of the District of Columbia, Civil Division. 7. Pursuant to 42 Pa.C.S.A. ~5326, this Honorable Court is authorized to order a person domiciled or is found within this Commonwealth to give his testimony or statement or to produce documents or other things for use in a matter pending in a tribunal outside this Commonwealth. EXIIIIIIT A INSTKlIe'J'I0NS AND DEFINITIONS Elich of thc rcquests set forth herein rcquircs thc deponent to producc 1I11 documents in thc possession. custody or control. or othcrwise rClIsonubly uvuiluble to uny und 1I11 of his/its ugcnts, ullorneys, und other rcprcscntutivc of ull descriptions. As uscd hercin, "document" includes uny lellcr, memorandum, application, handwritten or typcwrittcn notc. diary, culendar, drawing, sketch, laboratory rccord, photograph. microfilm, vicw graph, transcript of tcstimony. uppraisal. spread shcct, chart, or othcr written, recordcd, transcribed. punchcd, taped. filmcd or graphic mailer of any kind or description, however produced or rcproduced, including drafts and computerized records. The singulur includes the plural and vice versa. "And" us uscd herein mcans "and/or"; "or" as used herein mcans "und/or". "Brcezevllle" means Brcczevale, Ltd. "ODC" means the law firm of Gibson, Dunn and Crutchcr, including its partncrs, ussociates or employees or others lIcting on its behalf. "LlIwsuit" meuns Breezcvalc. Ltd. v. Bridgestone-Firestone. Inc. and Firestone EXDort Sales CorD., Casc No. 5:90 CV 1613, in the United States District Court for the Northcm District of Ohio. Unless otherwise provided, thcsc requcsts include the time period beginning January 1. 1985, up to and including Deccmber 31, 199 I. DOCUMENTS REOUESTED I. All documcnts, including mcmoranda mul notcs. rclating or refcrring to cOl1l1l1unicalillns from Scptcmhcr 1. 11)1)1 through thc prcscnt with (i) any currcnt or fonner .. , , .. E,\/!II!IT ,\ I NS'I'IU II 'I!!!~:i..!\NJ.UW!'O!N!1J.U1'J-,'i Eadl Ill' Ihl' IClllleSls SI'I fnllh hl'It'i1l lI'lJllill'S 111l' ""I"111l'1I1 In II/lllhl~l! all dllCUl1IenlS in Ihe possessioll, CII.Sllldy 01 l'lllllllll, II/ nlh"1 wise ll'i1"'lIahly i11'ailuhh, 10 allY 11I111 1111 of his/its IIgellls. IIl1llrneys, alld Illlwr rcpresl'lIlaliVl' of all dl''''llplillIlS As IIscd hl'Il'iIl, ''tIO('lIl11elll'' IIlChllh's III1Y klll'I, 1111'11I11/,1111111111. i1pplil'atillll, handwrillen or Iypewrillen 1I0le, dlllry, clllelllhll, dlawilll!, Skl'ldl, luhlllilhllY "'('llId, pholograph, microfilm, view gruph, lrullsnipl Ill' h'slirllOIlY, IIPPlllisul, SJlIl'illl SIIl"'I, dlilll. III III her wrillen, recorded, Ifllllscrihed, pllnchl'd, IlII11'd, lihllell III IHaphil' 1IH1lh'l III allY kiad m descriplion, however produ~ed Ilr rcprndll~cd, illcludillg dlafts IIl1d CIlIllPIII,'rill'd 11'('olds. The singlllar incllldes Ihe plnllll and Vil'I' versa, "And" liS 1I,,'d hl'lcin I1Icuns "1II111/or"; "nr" us n.sl'd hl'II'in nll'ans "and/or". "lIreC1.evulc" IIlcans IIreel,evule, Ltd. "(ilK'" 1II,'ans Ihe luw firl1l of Gihson, Dnnn un,1 Crlllcher. inclllding ils partners, ussociales Ilr elllploYI!I'S or III hers uetinllon ils hehulf. "Lllwsllil" 1I11'II11S Ihecl'cvulc, Ltd. v, IIridl!cslone-Firesllllw. IIII'. ullll Firestone Export SlIles Cllrp., <'ase Nil, ~:l)() CV 1(,1:1, ill till! IJlIlll'd Slules Disllil't COIIII for Ihe Norlhern Distriet of Ohio. lJnless IlIlll'lWiM' plllVirkd, Ihe", lel/lIl'sls illdlldl' Ihe IIl11e period hegilllling January I, Il)X5, lip III allIl inclllding I h'celllhl" .11, 1(11) I. I)OCIJI\U-:NTS HIo:OIIES'I'EIJ I. All dlll'llllll'IIIS, incllldinl! 11I1'llIllnllllla and 11ll1,'S. lelUlinl! or referring to 1'l1l1l11l1l1l1l'allllllS 1111111 S"pll'IIIIll'1 I. Illlll IllIolIgh 1I1l' 11I1's,'nl wilh (i) allY cllrrenl or fonller 4. Pursuant to Rules 28 and 28(i) of the Superior Court Rules of Civill'rocedure of the District of Columbia, I'hlintiff has issued a Notice of Deposition Duces Tecum to Peter Glenn for May 10, 1996 at 9:30 a.m. at the Law Offices of Eckert, Seamans, Cherin & Mellott, located at 1 South Market Square Building, Harrisburg, PA. True and correct copies of the Notice of Deposition Duces Tecum, Certificate of Service and Certificate Regarding Discovery are attached hereto and are marked ,IS Exhibit "A". 5. On April 11, 1996, the Honorable Steffen W. Graae, Judge, Superior Court of the District of Columbia, Civil Division issued a Commission and Order directing that the testimony of certain material witnesses, including Peter G. Glenn be taken by oral examination, de bene esse and/or for discovery and to be read as evidence in the above entitled case. True and correct copies of Judge Graae's Order and Commission are attached hereto and are marked as Exhibit "B". 6. Peter G. Glenn resides outside the jurisdiction and subpoena powers of the Superior court of the District of Columbia, Civil Division. 7. Pursuant to 42 Pa.C.S.A. $5326, this Honorable Court is authorized to order a person domiciled or is found within this Commonwealth to give his testimony or statement or to produce documents or other things for use in a matter pending in a tribunal outside this Commonwealth. EXIIIIIIT ^ INSTRUCTIONS AND DEFINITIONS Euch of the requests set forth herein requires the deponent to produce all documents in the possession, custody or control, or otherwise reasonubly uvuiluhle to uny and ull of his/i1s ugents. ullorneys, und other representutive of ull descriptions. As uscd herein, "document" includes any leller, memontndull1, lIppliclltion, handwritten or typewrillen note, diary, culendar. drawing, sketch, laboratory record, photograph. microfilm, view graph, transcript of testimony, appraisal, spread sheet, chart, or other wrinen. recorded, transcribed, punched, tuped, filmed or graphic matter of any kind or description, however produced or reproduced, including drafts and computerized records. The singulur includes the plural and vice versa. "And" us used herein means "and/or"; "or" as used hcrcin means "and/or". "Urcezevule" means Ureezevale. Ltd. "GDC" means the law finn of Gibson, Dunn und Crutcher, including its partners, associates or employees or others acting on its behalf. "Lnwsuit" means Breezevale, Ltd. v. Bridgestone-Firestone. Inc. and Firestone EXDort Sules CorP., Cuse No. 5:90 CV 1613, in the United States District Court for the Northem District of Ohio. Unless otherwise provided, these requests include the time period beginning January 1, 19115, up to and including Deccmber 31. 1991. DOCUMENTS REQUESTED I. All documcnts, including mcmoranda und notcs. relating or referring to COlllll1llllicutions from Scptember I, 1991 through the prescnt with (il ,lilY current or former '.... I . EXmJIIT A INSTRUCTIONS ANI> DE....NITIONS Each of lhe requests set forlh herein requircs the deponent to produce 1111 documents in lhe possession, custody or conlIol, or otherwise reasonably available to IIny and 1111 of his/its IIgents, uttorneys. and other reprcscntative of nil descriptions. As used herein, "document" includes nny lellcr, memorandum, application, handwritten or typewritten note, diary, calendnr, drawing, sketch, labonllory record, photograph, microfilm, view grnph, transcript of testimony, appraisal, spread sheet, chari, or other wrillen, recorded, transcribed, punched, taped, filmed or graphic mailer of any kind or description, however produced or reproduced, including drafts und computerized records. The singular includes the plural and vice versa. "And" as used herein means "and/or"; "or" as used herein means "und/or". "Oreezevalc" means Oreczcvalc, LId. "GDC" means the Inw firm of Gibson, Dunn nnd Cnllcher, including its partners, associates or employees or others ncting on its behulr. "Lawsuit" menns Dreezevnle. Ltd. v. Drid~estone-Firestonc. Inc. und Firestone EllPOI1 Sales Corp., Case No. 5:90 CV 1613, in thc United States District Court for the NOrlhem District of Ohio. Unless otherwise provided, these requcsts include the time period beginning January I, 1985, up to and including Decemhcr 31, 1991. nOClJMENTS REOlJESTIm I. All docllmcnts. including memoranda ami nOles, rclating or rcferring to communications from Scptcmher I. I'J91 through the prcsent wilh (i) any currcnt or ronncr