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Re: Tatyana's Deposition
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J
J. Epstein Oct 31, 2006 8:13 PM
To
<DKIESQ@aol.com>
lawyers office..
----- Original Message ----
From: "DKIESQ@aol.com" <DKIESQ@aol.com>
To: jeeproject@yahoo.com
Sent: Tuesday, October 31, 2006 2:11:10 PM
Subject: Tatyana's Deposition
From: "DKIESQ@aol.com" <DKIESQ@aol.com>
To: jeeproject@yahoo.com
Sent: Tuesday, October 31, 2006 2:11:10 PM
Subject: Tatyana's Deposition
Robert Sack scheduled Tatyana to come to Sack's office tomorrow November 1,
2006 to be prepared for her Deposition Scheduled to be taken on November
7. Neither the time nor the place of the deposition is yet
confirmed. Sack told me that the depositions are usually taken starting at
10:00 am. And that the depositions are usually taken at the courthouse,
but could be taken at either lawyer's office.
Topics to be addressed during the prep and at the deposition are as
follows:
Tatyana's background info. Name, age, dob, etc.
her general health prior to the accident
circumstances leading up to the injury
immediate injuries, health and medical issues
residual injuries, health and medical issues
Opposing lawyer taking the deposition will try to establish
how bad can the injuries have been if Tatyana is already working
and how did she manage to walk out of a moving bus. (implying that the
injury is her fault)
JEE, you should know that according to Sack, as of October 1, 2006,
there is now no right of an attorney defending a deposition to object on behalf
of the deponent to any deposition questions, which means already broad leeway
granted in asking questions will be even broader and less restricted.
No workers comp has bee paid. Sack's wc specialist only
recently found the wc carrier. Nobody was cooperating and the information
only recently came to light. The carrier has opened a file finally, but
Sack has no idea when Tatyana will ever get paid for workers comp.
Please let me know what questions you have.
Also, please let me know if you want me to get Sack to try to arrange for
the deposition to be taken at Sack's offices so that Tatyana does not get too
scared.
Darren K.
Indyke
Attorney-At-Law
457 Madison Avenue
4th Floor
New York, New York 10022
Tel: 212-750-1176
Fax: 212-750-0381
e-mail: dkiesq@aol.com
Confidentiality Notice: This communication and any attachments contain information from Darren K. Indyke, Esq. that constitute attorney work product or that are otherwise confidential and/or privileged. Except for personal use by the intended recipient, or as expressly authorized by the sender, any person who receives this information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promptly notify the sender at the above telephone number or electronic mail address. Nothing in this communication is intended to operate as an electronic signature under applicable law.
Attorney-At-Law
457 Madison Avenue
4th Floor
New York, New York 10022
Tel: 212-750-1176
Fax: 212-750-0381
e-mail: dkiesq@aol.com
Confidentiality Notice: This communication and any attachments contain information from Darren K. Indyke, Esq. that constitute attorney work product or that are otherwise confidential and/or privileged. Except for personal use by the intended recipient, or as expressly authorized by the sender, any person who receives this information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promptly notify the sender at the above telephone number or electronic mail address. Nothing in this communication is intended to operate as an electronic signature under applicable law.
J
J. Epstein Oct 31, 2006 8:14 PM
To
<DKIESQ@aol.com>
she should know how to respond to personal questions.
----- Original Message ----
From: "DKIESQ@aol.com" <DKIESQ@aol.com>
To: jeeproject@yahoo.com
Sent: Tuesday, October 31, 2006 2:11:10 PM
Subject: Tatyana's Deposition
From: "DKIESQ@aol.com" <DKIESQ@aol.com>
To: jeeproject@yahoo.com
Sent: Tuesday, October 31, 2006 2:11:10 PM
Subject: Tatyana's Deposition
Robert Sack scheduled Tatyana to come to Sack's office tomorrow November 1,
2006 to be prepared for her Deposition Scheduled to be taken on November
7. Neither the time nor the place of the deposition is yet
confirmed. Sack told me that the depositions are usually taken starting at
10:00 am. And that the depositions are usually taken at the courthouse,
but could be taken at either lawyer's office.
Topics to be addressed during the prep and at the deposition are as
follows:
Tatyana's background info. Name, age, dob, etc.
her general health prior to the accident
circumstances leading up to the injury
immediate injuries, health and medical issues
residual injuries, health and medical issues
Opposing lawyer taking the deposition will try to establish
how bad can the injuries have been if Tatyana is already working
and how did she manage to walk out of a moving bus. (implying that the
injury is her fault)
JEE, you should know that according to Sack, as of October 1, 2006,
there is now no right of an attorney defending a deposition to object on behalf
of the deponent to any deposition questions, which means already broad leeway
granted in asking questions will be even broader and less restricted.
No workers comp has bee paid. Sack's wc specialist only
recently found the wc carrier. Nobody was cooperating and the information
only recently came to light. The carrier has opened a file finally, but
Sack has no idea when Tatyana will ever get paid for workers comp.
Please let me know what questions you have.
Also, please let me know if you want me to get Sack to try to arrange for
the deposition to be taken at Sack's offices so that Tatyana does not get too
scared.
Darren K.
Indyke
Attorney-At-Law
457 Madison Avenue
4th Floor
New York, New York 10022
Tel: 212-750-1176
Fax: 212-750-0381
e-mail: dkiesq@aol.com
Confidentiality Notice: This communication and any attachments contain information from Darren K. Indyke, Esq. that constitute attorney work product or that are otherwise confidential and/or privileged. Except for personal use by the intended recipient, or as expressly authorized by the sender, any person who receives this information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promptly notify the sender at the above telephone number or electronic mail address. Nothing in this communication is intended to operate as an electronic signature under applicable law.
Attorney-At-Law
457 Madison Avenue
4th Floor
New York, New York 10022
Tel: 212-750-1176
Fax: 212-750-0381
e-mail: dkiesq@aol.com
Confidentiality Notice: This communication and any attachments contain information from Darren K. Indyke, Esq. that constitute attorney work product or that are otherwise confidential and/or privileged. Except for personal use by the intended recipient, or as expressly authorized by the sender, any person who receives this information is prohibited from disclosing, copying, distributing, and/or using it. If you have received this communication in error, please immediately delete it and all copies, and promptly notify the sender at the above telephone number or electronic mail address. Nothing in this communication is intended to operate as an electronic signature under applicable law.