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Microcap & Penny Stocks : PLNI - Game Over -- Ignore unavailable to you. Want to Upgrade?

To: scion who wrote (10391)	7/3/2007 9:36:29 PM
From: bearclaw51	Respond to of 12518

This may be a moot point after Thursday...Lets see how the Judge sorts this out too...

To: scion who wrote (10391)	7/4/2007 10:44:56 AM
From: scion	Respond to of 12518

3. It is unknown to counsel for the Debtor in Possession if a subpoena has been issued for James P. Toohey’s appearance at the deposition. In the event a subpoena has been issued for James P. Toohey’s appearance and/or a subpoena duces tecum, the Debtor in Possession objects to same as set forth in detail below. Furthermore, said subpoena (if any) would violate Federal Rule of Bankruptcy Procedure 9016 by requiring James P. Toohey to travel more than 100 miles from where he resides and subjects Toohey to undue burden. Extract from MOTION TO QUASH NOTICE OF DEPOSITION OF JAMES P. TOOHEY Plasticon Doc 89 --- PRO PLAS, LLC’S RESPONSE TO DEBTOR’S MOTION TO QUASH NOTICE OF DEPOSITION OF JAMES P. TOOHEY b. James P. Toohey has agreed to be deposed in St. Louis, Missouri; however, the date and time may change due to an illness in his family. c. On June 27, 2007 at the Meeting of Creditors, Debtor Plasticon International, Inc.’s (“Debtor Plasticon’s”) representative testified that numerous individuals including James P. Toohey regularly transacted business at Pro Mold in St. Louis, Missouri.1 1 Pursuant to Federal Rule of Civil Procedure 45(b)(2) and 45(c)(3)(A)(ii) and Federal Rule of Bankruptcy Procedure 9016, a subpoena was issued from the United States Bankruptcy Court for the Eastern District of Missouri. Extract from PRO PLAS, LLC’S RESPONSE TO DEBTOR’S MOTION TO QUASH NOTICE OF DEPOSITION OF JAMES P. TOOHEY Plasticon Doc 91