Lasheen v. Loomis Company, et al

Filing 414

ORDER TO APPEAR FOR EXAMINATION signed by Magistrate Judge Edmund F. Brennan on 12/22/16. (Judgment Debtor Exam as to Cultural and Educational Bureau SET for 3/8/2017 at 04:00 PM in Courtroom 8 (EFB) before Magistrate Judge Edmund F. Brennan. (Mena-Sanchez, L)

12/22/16

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: [phone]
Email: [e-mail]
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: December 15, 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 03-08-17 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