Mikhlyn et al v. Bove et al

Filing 94

Letter Joint Deposition Schedule by Ana Bove (Kogan, Boris)

Mikhlyn et al v. Bove et al

Doc. 94

Case 1:08-cv-03367-CPS-RER Document 94

Filed 11/10/09 Page 1 of 2

BORIS KOGAN & ASSOCIATES
ATTORNEYS AND COUNSELORS AT LAW
277 BROADWAY, SUITE 701 NEW YORK, NY 10007 TEL: [phone] FAX: [phone] WWW.BORISKOGAN.COM EMAIL: [e-mail]

November 10, 2009 Sent Via ECF To: Honorable Judge Ramon E. Reyes United States District Court Eastern District of New York 225 Cadman Plaza East Brooklyn, NY 11201 Re: Mikhlyn, et al. v. Bove, et al. Case No. 1:08-cv-3367

Honorable Judge Reyes: The parties jointly agree to the following deposition schedule with the understanding that: (a) each side preserves its right under Rule 30 to seek additional days of deposition with respect to any witness if the witness' deposition is not completed in the scheduled time, (b) with respect to the depositions of Vadim and Inga Mikhlyn, plaintiffs will consent to a second day of either or both depositions if defendants request it; and (c) the parties will negotiate any issues about the length and scheduling of depositions in good faith before seeking Court intervention: Monday, November 23, 2009 Tuesday, November 24, 2009 Ana Bove Ana Bove

Wednesday, November 25, 2009 - Representative from Accounting and Tax Services Tuesday, December 1, 2009 Monday, December 7, 2009 Inga Mikhlyn Zinaida Bolyachevski Vadim Mikhlyn Alex Sakirski Polina Dolginov (the parties

Wednesday, December 9, 2009 Thursday, December 10, 2009 Wednesday, December 16,

2009

Dockets.Justia.com

Case 1:08-cv-03367-CPS-RER Document 94

Filed 11/10/09 Page 2 of 2

stipulate that this deposition will last beyond the seven hour limit of Rule 30(d) and will continue for half a day on Thursday, December 17, 2009. In the event that more time is needed to complete the deposition thereafter, it shall be done remotely.) Very truly yours, /s/ Boris Kogan Boris Kogan (BK-9135) BK:ya