View
216
Download
1
Category
Preview:
Citation preview
1
THE STATE OF NEW HAMPSHIRE
HILLSBOROUGH SS SUPERIOR COURT NORTH
Docket No. 216-2016-CV-00327
Sanjeev Lath
v.
Oak Brook Condominium Owners' Association, Board of
Directors, Warren Mills, Vickie Grandmaison, Dorothy Vachon,
and Scott Sample
July 13, 2016
PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO QUASH AND
PLAINTIFF’S PETITION FOR ENTRY OF ORDER ON DEPOSITION SCHEDULE
NOWCOMES the Plaintiff, Sanjeev Lath in the matter and respectfully submits his opposition to
the Motion to Quash the Eight Notices of Deposition served upon eight “nominal” witnesses. In
support thereof, he states as follows:
1. The Defendants contend that Plaintiff is a disgruntled owner. Without expanding the
reasons of filing several litigations, it is imperative for this Hon’ble Court to know that
one of the Defendants in this instant action, Scott Sample, resorted to violence, and have
assaulted the Plaintiff in the premises of Oak Brook condominium, since the filing of
2
various disputes, citing in many instances, including to Plaintiff’s roommate, his
disagreement over the litigations. See Exhibit A.
2. Further, Plaintiff’s car was mutilated since the inception of these litigations. See Exhibit
B. Several of the Defendants, have created and have perpetuated a hostile environment,
with the toxic “informational” meetings that Oak Brook Management and have used as
forum, to discuss these litigations, and blame the Plaintiff. See Exhibit C. This becomes
evidently clearer, because even though Oak Brook Management and Board have
terminated Defendant Sample’s employment, some of these Board members, including
the President, Bill Morey and Board Member Cheryl Vallee, appeared at Plaintiff’s
stalking hearing against Sample, on July 12, 2016 at the 9th
District Court, to support
Sample’s violent and despicable acts.
3. Defendant’s Attorney, Gary Burt, Esq., has resorted to dilatory tactics since the inception
of the litigation. For e.g., Attorney Burt negotiated a copy of the initial deposition
transcript, held March 10, 2016, for the venue of the Deposition. Attorney Burt quoted
obtaining a copy of the deposition transcript as “a practice in NH for the person taking
the deposition to pay for the original plus one for the person deposed.” See Exhibit D.
4. During that negotiation, Plaintiffs contended that they booked a venue in Bedford, the
New England Executive Center’s posh Victorian room, about seven (7) miles from the
Oak Brook Office, as a neutral location for all parties involved in the matter. Plaintiff
contended that the “club house”, as proposed by Attorney Burt, was not private, housed
3
recreational amenities like gym, swimming pool and the sauna and was not a neutral
venue. See Exhibit D.
5. On June 21, 2016, Hearing on the Motions in another case, pending before this Court,
Case Number: 216-2015-CV-859, Hon’ble Judge Brown ordered one deposition for each
witness in all pending matters before this Court and New Hampshire Human Rights
Commission. Shortly after this hearing, on June 27, 2016, Plaintiff Lath provided a list of
deponents with the envisaged hours to Attorney Burt for a possible schedule. See Exhibit
E. To this Attorney Burt responded, that he would take “time to arrange these” and that
the nominal witnesses in the matters were not under his control and Plaintiff “will need to
issue subpoenas.”
6. To date of filing this Opposition, July 13, 2016, the Plaintiff has not received, even for a
single witness, a possible date for the deposition.
7. To effectively manage a forty hour work schedule and the pending litigations, Plaintiff
Lath, on July 07, 2016, requested Attorney Burt for his availability for “any day” during
the week of July 17, 2016, to schedule a deposition of “nominal”, third party witnesses.
To this request, Attorney Burt responded, “Booked solid. Right now, I don’t anticipate
my calendar clearing until perhaps the week of Oct 10th
and even that is an issue.” See
Exhibit F. According to this email, the date provided, October 13, 2016, was three
months away, and even that date was questionable with respect to his availability. Being
in a professional field myself, and working on missile systems for Department of
4
Defense, with critical deliveries for warfighter, I am not booked for every single day, for
the next three months.
8. Further, Attorney Burt in his motion contends that these subpoenas that are the matter of
this Motion to Quash involve different counsels retained by several Defendants. This
argument is misplaced, as this deposition and subpoenas were not for any of the
Defendants, but rather third party nominal witnesses. Further, Attorney Burt has failed to
provide the names of other counsels, and these unknown counsels, in turn have not filed a
Notice of Limited Appearance with this Court, in accordance with Rule 17 (c) of
Superior Court for the State of New Hampshire.
9. Defendant’s Attorney has claimed in his motion that the Plaintiff has made
“unreasonable” demands and has not made any “real effort to schedule the depositions
for a mutually agreeable date” (See Def. Mtn. to Quash ¶9). Without explaining
Plaintiff’s position, this Court can see from the above paragraphs and attached Exhibits as
to which party has been “unreasonable” and is misleading this Court.
10. Further, instead of proposing a fairly reasonable date in the near future, that is not three
months away, Attorney Burt, simply responds, “I am not available. Do I need to file a
motion to quash?” See Exhibit G.
11. Plaintiff Lath requests this Court an order for a deposition schedule that is just and fair.
Contemporaneously Plaintiff requests this Court for appropriate sanctions and cost of this
motion and hearing to be reimbursed by the Defendants.
5
WHEREFORE, for the above reasons, the Plaintiff prays for the following relief:
1) Deny the Defendant’s Motion
2) Sanction the Defendants for using dilatory tactics and misleading this Court, by imposing
fine for this Motion
3) Reimburse the Plaintiff for cost incurred for this Motion
4) Order a Deposition Schedule.
Respectfully submitted,
__________________________________
Sanjeev Lath, July 13, 2016
6
CERTIFICATE OF SERVICE
I certify that a copy of this Opposition to Plaintiff’s Motion to Quash and all
attachments has been mailed to the Defendant’s Attorney Gary Burt via email at
gburt@primmer.com.
__________________________________
Sanjeev Lath, July 13, 2016
Sanjeev Lath <slath1676@gmail.com>
Fwd: "Informational Meeting for Oakbrook"1 message
Jerry 1 <jerryshc@gmail.com> Thu, Jun 23, 2016 at 10:38 AMTo: Decline Decline <SLath1676@gmail.com>
---------- Forwarded message ----------From: >oakbrookcondos@comcast.net<Date: Wed, Jun 22, 2016 at 12:11 PMSubject: Re: "Informational Meeting for Oakbrook"To: Jerry 1 <jerryshc@gmail.com>Cc: "Bisson, John" <jbisson@cbzlaw.com>
Good Morning, How are you?
The meeting was going to be an informational meeting with some of oak brook suits and on the changes that are taken effect, most of all Scott not working with us anymore and a little bit as to why he isn't here anymore. The board wanted to reassure every one that we do have a new maintenance manager who has just started with us on Monday. Our Attorneys name is John Bisson. He is there for any additional information that he would have spoke about at the meeting. I am forwarding this email to him. Thank you and have a nice day.
ThanksZeny
From: "Jerry 1" <jerryshc@gmail.com>To: "Vickie Grandmaison" <oakbrookcondos@comcast.net>Cc: "Decline Decline" <SLath1676@gmail.com>, belwarebarbara@gmail.comSent: Wednesday, June 22, 2016 12:02:52 PMSubject: "Informational Meeting for Oakbrook"
Zeny,
We received two (2) notices recently.
1. The first was dated June 1, 2016, as an invitation from "the Board of Directors" for us to attend the "informational meeting in regards to Oak Brook" that was scheduled to "take place at 1pm at the club house." on "June 25, 2016". The notice further stated "This meeting is very important. We want to reassure and keep all owners updated with any changes or occurrences here at Oak Brook."
Page 1 of 2Gmail - Fwd: "Informational Meeting for Oakbrook"
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=jerry&qs=true&sea...
Questions. What are the "reassurance"(s) that were to be disclosed to the unit owners? What was the information that would "keep all owners updated with any changes or occurrences here at Oak Brook."?
2. The "short notice" of "having to cancel the Informational meeting that was going to take place on June 25th.." "and if anyone has any concerns or questions", "Zeny", "will then forward your email to our Attorney and he would be happy to reassure your concerns and answer your question."
Questions. Who is the Attorney that the emails are being forwarded to?Please lists the "reassurance"(es) of "concerns" and "questions" the Attorney would "be happy" to "answer" for "anyone"?Why was the "important meeting" information which was "to reassure and keep all owners updated with any changes or occurrences here at Oak Brook" not put in writing and mailed to all unit owners as should be rather than in secrecy?
Thank you for your anticipated co-operation in answering all these questions.Gerard Dufresne, 13 Northbrook Drive, Unit 1302.jerryshc@gmail.com
Page 2 of 2Gmail - Fwd: "Informational Meeting for Oakbrook"
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=jerry&qs=true&sea...
Sanjeev Lath <slath1676@gmail.com>
RE: Lath et al v. Oak Brook---depositions1 message
Gary Burt <gburt@primmer.com> Fri, Jan 29, 2016 at 5:41 PMTo: Sanjeev Lath <slath1676@gmail.com>Cc: "belwarebarbara@gmail.com" <belwarebarbara@gmail.com>
Why? First, there was no recording, as I told you before, and second, why would your claim require an independent location. Saying so does not make it so.
The private room at the club house is for the convenience of the deponents, as most live right at the location, and therefore don’t have to travel, find parking, or otherwise be inconvenienced. As you and the others live there also, that seems to make the most sense.
Please forward the email to Jeryshc@gmail.com as the ones I send don’t seem to reach him.
Gary M. Burt, Esquire
PRIMMER PIPER EGGLESTON & CRAMER PC
900 Elm Street, 19th Floor, P.O. Box 3600, Manchester, NH 03105-3600
Direct Dial: 603 626 3310 | Cell 603 494 4881
Fax: 603 626 0997 | Office: 603 626 3310
Gburt@primmer.com | www.primmer.com
From: Sanjeev Lath [mailto:slath1676@gmail.com] Sent: Friday, January 29, 2016 5:38 PMTo: Gary BurtCc: belwarebarbara@gmail.com; jereyshc@gmail.comSubject: RE: Lath et al v. Oak Brook---depositions
Mr burt
Page 1 of 2Gmail - RE: Lath et al v. Oak Brook---depositions
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=deposition&qs=tru...
This is a case about surreptitious recording . An independent location sounds fair enough to me ....
If you change your mind , let me know
On Jan 27, 2016 4:48 PM, "Gary Burt" <gburt@primmer.com> wrote:
The following are available on 3/10/16. What time do we start, and how much time between each witness. Note Mr. Clavijo will require an interpreter that you will need to provide.
Justin Bouffard
Dorothy Vachon
Vickie Grandmaison
Cheryl Vallee
Ruben Clavijo (needs interpreter)
John Bisson.
Gary M. Burt, Esquire
PRIMMER PIPER EGGLESTON & CRAMER PC
900 Elm Street, 19th Floor, P.O. Box 3600, Manchester, NH 03105-3600
Direct Dial: 603 626 3310 | Cell 603 494 4881
Fax: 603 626 0997 | Office: 603 626 3310
Gburt@primmer.com | www.primmer.com
Page 2 of 2Gmail - RE: Lath et al v. Oak Brook---depositions
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=deposition&qs=tru...
Sanjeev Lath <slath1676@gmail.com>
RE: Lath et al v. Oak Brook---depositions1 message
Gary Burt <gburt@primmer.com> Fri, Jan 29, 2016 at 5:37 PMTo: Sanjeev Lath <slath1676@gmail.com>Cc: "belwarebarbara@gmail.com" <belwarebarbara@gmail.com>, "jereyshc@gmail.com" <jereyshc@gmail.com>
Your call, but I will do so.
Gary M. Burt, Esquire
PRIMMER PIPER EGGLESTON & CRAMER PC
900 Elm Street, 19th Floor, P.O. Box 3600, Manchester, NH 03105-3600
Direct Dial: 603 626 3310 | Cell 603 494 4881
Fax: 603 626 0997 | Office: 603 626 3310
Gburt@primmer.com | www.primmer.com
From: Sanjeev Lath [mailto:slath1676@gmail.com] Sent: Friday, January 29, 2016 5:36 PMTo: Gary BurtCc: belwarebarbara@gmail.com; jereyshc@gmail.comSubject: RE: Lath et al v. Oak Brook---depositions
Mr Burt
I will issue subpoenas then and you can file the motion to quash
Sanjeev
On Jan 29, 2016 5:31 PM, "Gary Burt" <gburt@primmer.com> wrote:
We will need a judge to decide then. You will have to file a motion. Until the motion is acted upon, there will be no deposition.
Page 1 of 5Gmail - RE: Lath et al v. Oak Brook---depositions
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=deposition&qs=tru...
I will tell you that it has always been the practice in NH for the person taking the deposition to pay for the original plus one for the person deposed.
The location is a convenience to the deponents. In fact, as members of the association, and perhaps officers or directors, they probably have a right to sit in, but they don’t intend to.
There is a private room available at the site in the club house. Finally, I don’t know who Duffy is.
From: Sanjeev Lath [mailto:slath1676@gmail.com] Sent: Friday, January 29, 2016 5:27 PMTo: Gary BurtCc: belwarebarbara@gmail.com; jereyshc@gmail.comSubject: RE: Lath et al v. Oak Brook---depositions
Mr Burt
I understand that I pay for my copy and the steno but as far as I know if you need a copy you pay for it
I need the deposition at an independent location . Duffy provides conference room and i have booked it already. The club house is not a private place and other owners come by as it houses gym etc. Additionally I want the deponents independently deposed .
We can have a judge decide that if we have a disagreement
On Jan 29, 2016 4:25 PM, "Gary Burt" <gburt@primmer.com> wrote:
Depositions to take place at the club house at Oak Brook. I understand you are getting steno. I assume you are aware that you pay for an original transcript, plus one for me.
The Jereyshc@gmail.com email address seems not to work. Please advise as to correct address.
Gary M. Burt, Esquire
PRIMMER PIPER EGGLESTON & CRAMER PC
900 Elm Street, 19th Floor, P.O. Box 3600, Manchester, NH 03105-3600
Direct Dial: 603 626 3310 | Cell 603 494 4881
Fax: 603 626 0997 | Office: 603 626 3310
Gburt@primmer.com | www.primmer.com
Page 2 of 5Gmail - RE: Lath et al v. Oak Brook---depositions
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=deposition&qs=tru...
From: Sanjeev Lath [mailto:slath1676@gmail.com] Sent: Friday, January 29, 2016 9:20 AMTo: Gary BurtCc: jereyshc@gmail.com; belwarebarbara@gmail.comSubject: Re: Lath et al v. Oak Brook---depositions
Attorney Burt,
March 10 works.
I will provide an interpreter.
We can start 9 AM
9AM-9:30AM Justin Bouffard
9:30AM - 10:00AM Dorothy Vachon
10:00 AM-11:00 AM Vickie Grandmaison
11:00AM-11:30 AM Ruben Clavijo
11:30AM-12:00 AM John Bisson, Esq.
Does this schedule work?
Let me know
On Wed, Jan 27, 2016 at 4:47 PM, Gary Burt <gburt@primmer.com> wrote:
Page 3 of 5Gmail - RE: Lath et al v. Oak Brook---depositions
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=deposition&qs=tru...
The following are available on 3/10/16. What time do we start, and how much time between each witness. Note Mr. Clavijo will require an interpreter that you will need to provide.
Justin Bouffard
Dorothy Vachon
Vickie Grandmaison
Cheryl Vallee
Ruben Clavijo (needs interpreter)
John Bisson.
Gary M. Burt, Esquire
PRIMMER PIPER EGGLESTON & CRAMER PC
900 Elm Street, 19th Floor, P.O. Box 3600, Manchester, NH 03105-3600
Direct Dial: 603 626 3310 | Cell 603 494 4881
Fax: 603 626 0997 | Office: 603 626 3310
Gburt@primmer.com | www.primmer.com
--
Sanjeev Lath
7 Northbrook Dr
Unit 710
Manchester NH 03102
6034614936
Statement of Confidentiality
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the
Page 4 of 5Gmail - RE: Lath et al v. Oak Brook---depositions
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=deposition&qs=tru...
addressee(s). Please notify Sanjeev Lath at slath1676@gmail.com if you are not the intended recipient and destroy all copies of this electronic message and any attachments.
Page 5 of 5Gmail - RE: Lath et al v. Oak Brook---depositions
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=deposition&qs=tru...
Sanjeev Lath <slath1676@gmail.com>
RE: List of Deponents1 message
Gary Burt <gburt@primmer.com> Mon, Jun 27, 2016 at 5:32 PMTo: Sanjeev Lath <slath1676@gmail.com>Cc: "jerryshc@gmail.com" <jerryshc@gmail.com>, "belwarebarbara@gmail.com" <belwarebarbara@gmail.com>
This is going to take some time to arrange. I don’t have control over residents, only employees, officers, and directors. So to the extent that any below are not employees, officers or directors, you will need to issue subpoenas.
Also, I will need to find some time to arrange these. They will have to be taken over days, and not consecutive days.
From: Sanjeev Lath [mailto:slath1676@gmail.com] Sent: Monday, June 27, 2016 9:25 AMTo: Gary BurtCc: jerryshc@gmail.com; belwarebarbara@gmail.comSubject: List of Deponents
Defendant witnesses
Jane Bright 1 hrs
John Bisson 2 hrs
Vickie Grandmaison 5 hrs
Dorothy Vachon 2 hrs
Justin Boufford 2 hrs
Bill Morey 5 hrs
Zeny Rodriguez 1 hr
Scott Sample 5 hrs
Beth Mullen 1 hrs
Warren Mills 2 hrs
Ruben Clavijo 0.5 hr
Page 1 of 2Gmail - RE: List of Deponents
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=list&qs=true&sear...
Chris Klardie 2 hrs
Cheryl Vallee 2 hrs
Perry Vallee 1 hr
Nominal and Plaintiffs' depositions
Jason Manujian 0.5 hrs
Jared Dufresne 0.5 hrs
Cynthia Camp 0.5 hr
Michael Camp 0.5 hr
Al Terry 0.5 hr
Barbara Belware 2 hrs
Jerry Dufresne 2 hrs
Jane Beaulieu 1 hrs
Jason Cox 0.5 hrs
--
Sanjeev Lath
7 Northbrook Dr
Unit 710
Manchester NH 03102
6034614936
Statement of Confidentiality
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the addressee(s). Please notify Sanjeev Lath at slath1676@gmail.com if you are not the intended recipient and destroy all copies of this electronic message and any attachments.
Page 2 of 2Gmail - RE: List of Deponents
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=list&qs=true&sear...
Sanjeev Lath <slath1676@gmail.com>
RE: List of Deponents1 message
Gary Burt <gburt@primmer.com> Thu, Jul 7, 2016 at 8:51 AMTo: Sanjeev Lath <slath1676@gmail.com>Cc: Jerry 1 <jerryshc@gmail.com>, "belwarebarbara@gmail.com" <belwarebarbara@gmail.com>
Booked solid. Right now, I don’t anticipate my calendar clearing until perhaps the week of Oct 10th and even that is an issue.
Gary M. Burt, Esquire
PRIMMER PIPER EGGLESTON & CRAMER PC
900 Elm Street, 19th Floor, P.O. Box 3600, Manchester, NH 03105-3600
Direct Dial: 603 626 3310 | Cell 603 494 4881
Fax: 603 626 0997 | Office: 603 626 3310
Gburt@primmer.com | www.primmer.com
www/primmer.com/bio
We are pleased to announce the launch of our newly designed website. Please visit us at www.primmer.com
From: Sanjeev Lath [mailto:slath1676@gmail.com] Sent: Thursday, July 07, 2016 8:44 AMTo: Gary BurtCc: Jerry 1; belwarebarbara@gmail.comSubject: Re: List of Deponents
Atty Burt,
Page 1 of 4Gmail - RE: List of Deponents
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=list&qs=true&sear...
I want to schedule the third party depos (see below) week of July 17th.
what is your availability any day that week?
Jason Cox 0.5 hrs
Jared Dufresne 0.5 hrs
Al Terry 0.5 hr
Cynthia Camp 0.5 hr
Michael Camp 0.5 hr
Beth Mullen 1 hrs
Jason Manujian
On Mon, Jun 27, 2016 at 6:28 PM, Sanjeev Lath <slath1676@gmail.com> wrote:
Let us know whenever you are ready...
On Jun 27, 2016 5:33 PM, "Gary Burt" <gburt@primmer.com> wrote:
This is going to take some time to arrange. I don’t have control over residents, only employees, officers, and directors. So to the extent that any below are not employees, officers or directors, you will need to issue subpoenas.
Also, I will need to find some time to arrange these. They will have to be taken over days, and not consecutive days.
From: Sanjeev Lath [mailto:slath1676@gmail.com] Sent: Monday, June 27, 2016 9:25 AMTo: Gary BurtCc: jerryshc@gmail.com; belwarebarbara@gmail.comSubject: List of Deponents
Defendant witnesses
Jane Bright 1 hrs
John Bisson 2 hrs
Page 2 of 4Gmail - RE: List of Deponents
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=list&qs=true&sear...
Vickie Grandmaison 5 hrs
Dorothy Vachon 2 hrs
Justin Boufford 2 hrs
Bill Morey 5 hrs
Zeny Rodriguez 1 hr
Scott Sample 5 hrs
Beth Mullen 1 hrs
Warren Mills 2 hrs
Ruben Clavijo 0.5 hr
Chris Klardie 2 hrs
Cheryl Vallee 2 hrs
Perry Vallee 1 hr
Nominal and Plaintiffs' depositions
Jason Manujian 0.5 hrs
Jared Dufresne 0.5 hrs
Cynthia Camp 0.5 hr
Michael Camp 0.5 hr
Al Terry 0.5 hr
Barbara Belware 2 hrs
Jerry Dufresne 2 hrs
Jane Beaulieu 1 hrs
Jason Cox 0.5 hrs
--
Sanjeev Lath
7 Northbrook Dr
Unit 710
Page 3 of 4Gmail - RE: List of Deponents
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=list&qs=true&sear...
Manchester NH 03102
6034614936
Statement of Confidentiality
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the addressee(s). Please notify Sanjeev Lath at slath1676@gmail.com if you are not the intended recipient and destroy all copies of this electronic message and any attachments.
--
Sanjeev Lath
7 Northbrook Dr
Unit 710
Manchester NH 03102
6034614936
Statement of Confidentiality
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the addressee(s). Please notify Sanjeev Lath at slath1676@gmail.com if you are not the intended recipient and destroy all copies of this electronic message and any attachments.
Page 4 of 4Gmail - RE: List of Deponents
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=list&qs=true&sear...
Sanjeev Lath <slath1676@gmail.com>
RE: Notices of Deposition1 message
Gary Burt <gburt@primmer.com> Thu, Jul 7, 2016 at 3:05 PMTo: Sanjeev Lath <slath1676@gmail.com>, "dmreporting@stenosearch.com" <dmreporting@stenosearch.com>Cc: Jerry 1 <jerryshc@gmail.com>, "belwarebarbara@gmail.com" <belwarebarbara@gmail.com>
I am not available. Do I need to file a motion to quash?
Gary M. Burt, Esquire
PRIMMER PIPER EGGLESTON & CRAMER PC
900 Elm Street, 19th Floor, P.O. Box 3600, Manchester, NH 03105-3600
Direct Dial: 603 626 3310 | Cell 603 494 4881
Fax: 603 626 0997 | Office: 603 626 3310
Gburt@primmer.com | www.primmer.com
www/primmer.com/bio
We are pleased to announce the launch of our newly designed website. Please visit us at www.primmer.com
From: Sanjeev Lath [mailto:slath1676@gmail.com] Sent: Thursday, July 07, 2016 3:00 PMTo: Gary Burt; dmreporting@stenosearch.comCc: Jerry 1; belwarebarbara@gmail.comSubject: Notices of Deposition
Please see attached
Page 1 of 2Gmail - RE: Notices of Deposition
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=burt&qs=true&sea...
--
Sanjeev Lath
7 Northbrook Dr
Unit 710
Manchester NH 03102
6034614936
Statement of Confidentiality
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the addressee(s). Please notify Sanjeev Lath at slath1676@gmail.com if you are not the intended recipient and destroy all copies of this electronic message and any attachments.
Page 2 of 2Gmail - RE: Notices of Deposition
07/13/2016https://mail.google.com/mail/u/0/?ui=2&ik=98c0f68f10&view=pt&q=burt&qs=true&sea...
Recommended