Lasheen v. Loomis Company, et al

Filing 402

ORDER signed by Magistrate Judge Edmund F. Brennan on 11/2/16 ORDERING the Cultural and Educational Bureau to Appear for Examination on 11/30/16 at 4:00 PM in Courtroom 8 (EFB) before Magistrate Judge Edmund F. Brennan. (Becknal, R)

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November 2, 2016 1 2 3 4 5 6 7 Randy M. Andrus (CA SBN 116745) ANDRUS LAW FIRM, LLC 299 South Main Street, Suite 1300 Salt Lake City, Utah 84111 Telephone: (801) 535-4645 Email: Randy@andrusfirm.com Attorney for Plaintiff/Judgment Creditor MOHAMED E. LASHEEN UNITED STATES DISTRICT COURT 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 EASTERN DISTRICT OF CALIFORNIA ) ) Plaintiff/Judgment Creditor, ) ) v. ) THE LOOMIS COMPANY; EMBASSY ) OF THE ARAB REPUBLIC OF EGYPT; ) ) THE ARAB REPUBLIC OF EGYPT; ) CULTURAL AND EDUCATIONAL BUREAU; UNITED PAYORS & UNITED ) ) PROVIDERS; and BCE EMERGIS, ) Defendants/Judgment Debtors, ) ) ) ) THE LOOMIS COMPANY, ) ) Cross-Complainant, ) v. ) ) THE EMBASSY OF THE ARAB ) REPUBLIC OF EGYPT; THE ARAB ) REPUBLIC OF EGYPT; THE ) CULTURAL AND EDUCATIONAL ) BUREAU; and DOES 1 through 15, ) inclusive, ) ) Cross-Defendants. ) MOHAMED E. LASHEEN, CASE NO. 2:01-cv-00227 KJM-EFB NOTICE OF POST-JUDGMENT DEPOSITIONS AND EXAMINATIONS TO AND OF JUDGMENT DEBTORS 28 1 ____________________________________________________________________________________________ NOTICE OF POST-JUDGMENT DEPOSITIONS AND EXAMINATIONS TO AND OF JUDGMENT DEBTORS 1 2 3 4 5 PROPOUNDING PARTY: JUDGMENT CREDITOR, MOHAMED E. LASHEEN RESPONDING PARTIES: JUDGMENT DEBTORS, EMBASSY OF THE ARAB REPUBLIC OF EGYPT, THE ARAB REPUBLIC OF EGYPT, AND THE CULTURAL AND EDUCATIONAL BUREAU PLEASE TAKE NOTICE that on the dates and times listed on EXHIBIT A hereto, 6 7 Judgment Creditor, MOHAMED E. LASHEEN, pursuant to the Federal Rules of Civil 8 Procedure, including Rules 26-30, including 30(b)(6), Rules 69 and 30, and California Code 9 of Civil Procedure §§ 491.110, 708.110, et seq. will take the depositions and examinations of 10 each designated deponent listed on EXHIBIT A, whose addresses are well known to them 11 and their attorneys, designated by them, upon oral examination, before a certified shorthand 12 13 reporter notary public. Said depositions will continue from day to day until completed. 14 PLEASE TAKE FURTHER NOTICE that the deposing party intends to cause the 15 proceedings to be recorded stenographically, by a method that provides for the instant visual 16 display of the testimony received (i.e., “Live Notes”) and/or by videotape. 17 DATED: October 12, 2016 ANDRUS LAW FIRM, LLC 18 19 20 21 BY: /s/ Randy M. Andrus RANDY M. ANDRUS Attorney for Plaintiff/Judgment Creditor MOHAMED E. LASHEEN 22 23 24 25 26 27 28 2 ____________________________________________________________________________________________ NOTICE OF POST-JUDGMENT DEPOSITIONS AND EXAMINATIONS TO AND OF JUDGMENT DEBTORS 1 EXHIBIT A 2 3 4 5 DEPONENT 8 9 10 of The Arab Republic of Egypt 1. 2. 13 14 15 3. 16 17 18 4. 19 20 21 22 5. 23 24 25 26 27 Courtroom 8 (13th Floor) Sacramento, CA 95814 Pursuant to the Federal Rules of Civil Procedure, Rule 30(b)(6), Defendant/Judgment Debtor, THE ARAB REPUBLIC OF EGYPT, is required to designate and have appear the officer, director, or managing agent who is the most knowledgeable person regarding the following matters and topics: 11 12 LOCATION A. PERSON MOST KNOWLEDGEABLE 11-30-16 9:30 am 501 “I” Street 6 7 DATE/TIME 6. All assets of any Judgment Debtor used for any commercial purpose located anywhere in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 1 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 1). All financial accounts of any Judgment Debtor used for any commercial purpose located anywhere in the United States of America (see accompanying PostJudgment Interrogatories, Set 1, Interrogatory No. 2 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 2). All commercial debt (whether monetary or otherwise) owed to any Judgment Debtor by any entity (whether natural person, corporation, partnership, business, institution, enterprise, government, or otherwise) located in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 3 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 3). All commercial debt (whether monetary or otherwise) owed to any Judgment Debtor by any entity (whether natural person, corporation, partnership, business, institution, enterprise, government, or otherwise) whether or not located in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 4 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 4). Any entity (whether natural person, corporation, partnership, business, institution, enterprise, government, or otherwise) with whom any Judgment Debtor does any commercial dealings with in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 5 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 5). All commercial airline activities for any Judgment Debtor to and/or from the United States of America currently and/or within the last five years (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 6 and PostJudgment Requests for Production of Documents, Set 1, Request No. 6). 28 3 ____________________________________________________________________________________________ NOTICE OF POST-JUDGMENT DEPOSITIONS AND EXAMINATIONS TO AND OF JUDGMENT DEBTORS 1 2 B. PERSON MOST KNOWLEDGEABLE 11-30-16 2:00 pm 501 “I” Street of Embassy of the Arab Republic of Egypt Courtroom 8 (13th Floor) Sacramento, CA 95814 3 4 5 6 7 Pursuant to the Federal Rules of Civil Procedure, Rule 30(b)(6), Defendant/Judgment Debtor, EMBASSY OF THE ARAB REPUBLIC OF EGYPT, is required to designate and have appear the officer, director, or managing agent who is the most knowledgeable person regarding the following matters and topics: 1. 8 9 2. 10 11 12 3. 13 14 15 4. 16 17 18 19 5. 20 21 22 23 24 6. All assets of any Judgment Debtor used for any commercial purpose located anywhere in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 1 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 1). All financial accounts of any Judgment Debtor used for any commercial purpose located anywhere in the United States of America (see accompanying PostJudgment Interrogatories, Set 1, Interrogatory No. 2 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 2). All commercial debt (whether monetary or otherwise) owed to any Judgment Debtor by any entity (whether natural person, corporation, partnership, business, institution, enterprise, government, or otherwise) located in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 3 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 3). All commercial debt (whether monetary or otherwise) owed to any Judgment Debtor by any entity (whether natural person, corporation, partnership, business, institution, enterprise, government, or otherwise) whether or not located in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 4 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 4). Any entity (whether natural person, corporation, partnership, business, institution, enterprise, government, or otherwise) with whom any Judgment Debtor does any commercial dealings with in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 5 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 5). All commercial airline activities for any Judgment Debtor to and/or from the United States of America currently and/or within the last five years (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 6 and PostJudgment Requests for Production of Documents, Set 1, Request No. 6). 25 26 27 28 4 ____________________________________________________________________________________________ NOTICE OF POST-JUDGMENT DEPOSITIONS AND EXAMINATIONS TO AND OF JUDGMENT DEBTORS 1 2 C. PERSON MOST KNOWLEDGEABLE 11-30-16 4:00 pm 501 “I” Street of Cultural and Educational Bureau Courtroom 8 (13th Floor) Sacramento, CA 95814 3 4 5 6 7 Pursuant to the Federal Rules of Civil Procedure, Rule 30(b)(6), Defendant/Judgment Debtor, CULTURAL AND EDUCATIONAL BUREAU, is required to designate and have appear the officer, director, or managing agent who is the most knowledgeable person regarding the following matters and topics: 1. 8 9 2. 10 11 12 3. 13 14 15 4. 16 17 18 19 5. 20 21 22 23 24 6. All assets of any Judgment Debtor used for any commercial purpose located anywhere in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 1 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 1). All financial accounts of any Judgment Debtor used for any commercial purpose located anywhere in the United States of America (see accompanying PostJudgment Interrogatories, Set 1, Interrogatory No. 2 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 2). All commercial debt (whether monetary or otherwise) owed to any Judgment Debtor by any entity (whether natural person, corporation, partnership, business, institution, enterprise, government, or otherwise) located in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 3 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 3). All commercial debt (whether monetary or otherwise) owed to any Judgment Debtor by any entity (whether natural person, corporation, partnership, business, institution, enterprise, government, or otherwise) whether or not located in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 4 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 4). Any entity (whether natural person, corporation, partnership, business, institution, enterprise, government, or otherwise) with whom any Judgment Debtor does any commercial dealings with in the United States of America (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 5 and Post-Judgment Requests for Production of Documents, Set 1, Request No. 5). All commercial airline activities for any Judgment Debtor to and/or from the United States of America currently and/or within the last five years (see accompanying Post-Judgment Interrogatories, Set 1, Interrogatory No. 6 and PostJudgment Requests for Production of Documents, Set 1, Request No. 6). 25 26 27 28 5 ____________________________________________________________________________________________ NOTICE OF POST-JUDGMENT DEPOSITIONS AND EXAMINATIONS TO AND OF JUDGMENT DEBTORS

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