Document 6546BNM88KLGeL48r9Jvd2Je4
EXHIBIT
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UPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
IN RE: NEW YORK CITY ASBESTOS LITIGATION
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-X NOTICE TO TAKE DEPOSITION UPON
-X ORAL EXAMINATION
ALL WEFTZ & LUXENBERG CASES V. FORD MOTOR COMPANY ----------------------------------------------------------------------------------------- -X
Index No: 40,000/88
PLEASE TAKE NOTICE, that pursuant to the New York Asbestos Litigation Case
Management Order and Article 31 of the Civil Practice Law and Rules, that plaintiffs), by
their attorneys, WEIT2 & LUXENBERG. P.C., will take the deposition of the person(s)
designated by, FORD MOTOR COMPANY as most knowledgeable with respect to those
areas set forth in "EXHIBIT A", annexed hereto and made a part hereof by reference.
The deposition^) will commence on the 24TM and 28th days of JULY, 2006 at
10:00 a.m. and continuing day-to-day until completion, at the offices of WEIT2 &
LUXENBERG, P.C., located at 180 Maiden Lane, 17th Floor, New York, New York. At
such date and time, WEITZ & LUXENBERG, P.C. will conduct an examination and the
testimony will be recorded by stenographically recording and by videotape.'
PLEASE TAKE FURTHER NOTICE, that the person(s) to be examined is required
to bring with him/her fjose documents referenced in "EXHIBIT B",
This deposition will be held before an officer duly authorized to administer oaths at
which time and place you are invited to attend and cross-examine.
LMV OFFICES OF
WErrz <- 4 LUXENBERG, P.C.
180 MAIDEN LANE NEW YORK, N.Y. 10038
Dated: New York, New York June 20,2006
'
WEITZ & LUXENBERG, P.C. Attorneys for Plaintiffs, 180 Maiden Lane New York, New York 10038 (212)558-5500
Bv: f.
To: Justin Kasmir, Esq
[JjaMes C. LONG
Aarronson, Rappaport, Feinstein & Deutsch, LLP
757 Third Avenue
- New York, NY
Ph: 212-593-3937
Fx: 212-593-6970