Toffoloni v. LFP Publishing Group, LLC

Filing 191

NOTICE to Take Deposition of Tyler Downey filed by LFP Publishing Group, LLC (Solomon, Darrell)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
MAUREEN TOFFOLONI,
as Administrator and Personal
Representative of the ESTATE
OF NANCY E. BENOIT,
Plaintiff,
vs.

)
)
)
)
)
)
)
)
)

CASE NO. 1:08-cv-00421-TWT

LFP PUBLISHING GROUP, LLC,)
d/b/a Hustler Magazine, et al.,
)
)
Defendant.
)

NOTICE OF DEPOSITION OF TYLER DOWNEY
TO: Richard P. Decker, Esq.
Hallman & Wingate, LLC
166 Anderson Street, S.E.
Suite 210
Marietta, Georgia 30060
PLEASE TAKE NOTICE pursuant to Fed. R. Civ. P. 30 that on April 21,
2011, beginning at 1:30 p.m. CDT, Defendant LFP Publishing Group, LLC, d/b/a
Hustler Magazine, et al., by and through its attorneys, will take the deposition of
Mr. Tyler Downey of 301 East 70th Terrace, Kansas City, Missouri 64113, upon
oral examination, for use at trial and all proper purposes under the Federal Rules of

Civil Procedure, before a Notary Public or some other officer duly authorized by
law to administer oaths. The deposition is to be taken for use in this action, in the
United States District Court for the Northern District of Georgia, Atlanta Division,
Civil Action File Number 1:08-cv-00421-TWT.
The deposition of Mr. Downey will take place at the offices of Midwest
Litigation Services, 1301 Oak Street, Kansas City, Missouri 64106, and will be
conducted remotely via video conference as stipulated by the parties.
deposition will be recorded both stenographically and by videotape.
Respectfully submitted this 20th day of April 2011.
/s/ Darrell J. Solomon
Darrell J. Solomon
Georgia Bar No. 305922
MCKENNA LONG & ALDRIDGE LLP
303 Peachtree Street, Suite 5300
Atlanta, Georgia 30308
[phone]
[phone] (facsimile)

The

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
MAUREEN TOFFOLONI,
as Administrator and Personal
Representative of the ESTATE
OF NANCY E. BENOIT,
Plaintiff,
vs.

)
)
)
)
)
)
)
)
)

CASE NO. 1:08-cv-00421-TWT

LFP PUBLISHING GROUP, LLC,)
d/b/a Hustler Magazine, et al.,
)
)
Defendant.
)
CERTIFICATE OF SERVICE
This is to certify that I have this day filed the within and foregoing Notice of
Deposition of Tyler Downey via the CM/ECF system which will automatically
send notification to Plaintiff’s attorneys of record, who are participants in the
CM/ECF system.
This 20th day of April 2011.

/s/ Darrell J. Solomon
Darrell J. Solomon
Georgia Bar No. 305922
MCKENNA LONG & ALDRIDGE LLP
303 Peachtree Street, Suite 5300
Atlanta, Georgia 30308
[phone]
[phone] (facsimile)
ATLANTA:5299583.1