We don't need no stinkin' damages! Or do we?
AMENDED NOTICE OF TAKING DEPOSITION OF PERSON(S) MOST KNOWLEDGEABLE
"TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
YOU ARE HEREBY NOTIFIED that Defendant, MARY DAY, will take the deposition(s) of Plaintiffs', VARIAN MEDICAL SYSTEMS, INC.'S and VARIAN SEMICONDUCTOR EQUIPMENT ASSOCIATES, INC.'S, officers, directors, managing agents or other persons most knowledgeable about the damages alleged to have been sustained by each of the corporate Plaintiffs as a result of any actions taken by Defendant, MARY DAY and about how the damages alleged to have been sustained by each of the corporate Plaintiffs or any predecessors in interest as a result of any actions taken by Defendant, MARY DAY, were calculated who shall also bring with them the following documents:
1. All documents which evidence, refer or relate to each item of damages which is set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1 (Federal Court)
2. All agreements entered into with any person or entity to install all or any part of any security system which comprised all or any part of the "Increased security costs:..." set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1 (Federal Court)
3. All proposals made by any person or entity to install all or any part of any security system which comprised all or any part of the "Increased security costs:..." set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1 (Federal Court)
4. All invoices, pay stubs, bills , records, documents, printouts, contracts and statements evidencing, referring to or relating to the "Increased security costs:..." set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1 (Federal Court)
5. If a security system was installed in any facility used by any corporate Plaintiff which system comprises any part of the "Increased security costs:..." set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1, all documents which relate to, evidence or refer to said security system. (Federal Court)
6. If any temporary security system was installed in any facility used by any corporate Plaintiff which system comprises any part of the "Increased security costs:..." set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1, all documents which relate to, evidence or refer to said security system. (Federal Court)
7. If a security system was installed in any facility used by any corporate Plaintiff which system comprises any part of the "Increased security costs:..." set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1, all documents which relate to, evidence or refer to said original security system. (Federal Court)
8. If any temporary security system was added to any facility used by any corporate Plaintiff which system comprises any part of the "Increased security costs:..." set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1, and there was already a security system in effect, all documents which relate to, evidence or refer to said security system. (Federal Court)
9. All documents which evidence, refer to or relate to the costs of security for each of the corporate Plaintiffs for the period commencing one year prior to the filing of the complaint in this matter to the present. (Federal Court)
10. All documents which which set forth or itemize the costs of security for each of the corporate Plaintiffs for the period commencing one year prior to the filing of the complaint in this matter to the present. (Federal Court)
11. All documents which evidence, refer to or relate to the monies paid to any independent contractor for security for each of the corporate Plaintiffs for the period commencing one year prior to the filing of the complaint in this matter to the present. (Federal Court)
12. All documents which refer to set forth the reason(s) there were "Increased security costs:..." set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1, in light of the alleged defamatory statements made by any Defendant in this action. (Federal Court)
13. If "Increased security costs:..." set forth in the response to Defendant's, MARY DAY'S, Supplemental Interrogatory No. 1 were incurred for any reason in addition to any alleged defamatory statements made by an Defendant in this action, all documents which refer to, relate to or evidence said reason(s). (Federal Court)
14. The originals of all Log Books, notebooks and diaries in which you recorded incidents concerning employees referring to, relating to or evidencing the following:
A. Defamatory statements.
B. Complaints about Ms. Felch, Mr. Zdasiuk, Mr. Delfino, Ms. Day, Varian Medical Systems, Inc. and/or Varian Semiconductor Equipment Associates, Inc.
15. The originals of all Log Books, notebooks and diaries in which you reference e-mails, memos or letters that refer to, relate to or evidence the following:
A. Defamatory statements.
B. Complaints about Ms. Felch, Mr. Zdasiuk, Mr. Delfino, Ms. Day, Varian Medical Systems, Inc. and/or Varian Semiconductor Equipment Associates, Inc.
16. The original of your Log Book, notebook or diary reviewed by Jane Crisler as testified to in her deposition.
17. The originals of any other documents, writings or e-mails authored or received by you that evidence, refer to or relate to incidents involving Varian Medical Systems, Inc.'s and Varian Semiconductor Equipment Associates, Inc.'s employees referring to, relating to or evidencing the following:
A. Defamatory statements.
B. Complaints about Ms. Felch, Mr. Zdasiuk, Mr. Delfino, Ms. Day, Varian Medical Systems, Inc. and/or Varian Semiconductor Equipment Associates, Inc.
Said deposition will be taken before a notary public or other officer authorized to administer oaths and will be taken at 2501 Park Blvd., Suite 205, Palo Alto, CA 94306, on March 28 and 29, 2001, commencing at 9:30 a.m. and shall continue from day to day until completed.
Dated: March 7, 2001
RANDALL M. WIDMANN
Attorney for Defendant, DAY"
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