Document Negd2165EBwrRKk5QLLk21JE8
CAUSE NO. 2001-36408
SAM P. BURNETT, ET AL
vs.
THE DOW CHEMICAL COMPANY
IN THE DISTRICT COURT OF HARRIS COUNTY, TEXAS
269th JUDICIAL DISTRICT
ORDER ON MQTIQN TO QUASH DEP_QSITION OF CORPORATE REPRESENTATIVE OF THE DOW CHEMICAL COMPANY
On APB t 1
. 2003, the Court considered Defendant, The Dow Chemical
Company's Motion to Quash the Deposition of a Corporate Representative of The Dow Chemical
Company and the Court, having considered the evidence and arguments of counsel finds that
Defendant's Motion to Quash should be in all things DENIED.
IT IS THEREFORE ORDERED that the Deposition ofthe Corporate Representative ofthe Dow
Chemical Company go forward as scheduled on April 23,2003, at 10:00 am at the office ofMehaffy
and Weber, 500 Dallas, Suite #1200, Houston, Texas 77002,
IT IS ORDERED that Defendant shall produce a corporate representative(s) who will testily
on the following matters:
a. The relationship and any arrangements between The Dow Chemical Company and Otto Ambrose
b. Any agreements between The Dow Chemical Company and Otto Ambrose.
c. Any and all correspondence and documents sent to and/or received from Otto
Ambrose by Defendant. Such request includes, but is not limited to, any consulting agreements between Defendant and Otto Ambrose as well as any other "documents" as it more fully defined in attached Definitions and Instructions.
ilRM, L.L.P
8441 Gulf Freeway, Suite 600
Houston, TX 77017 TOTAL P.02