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    The document discusses scheduling issues regarding deposing Jon Huntsman. His counsel offered dates for his deposition during the weeks of February 9th, February 16th, and February 23rd. However, each time his availability changed or new reasons were given for rescheduling. On February 9th, his counsel said his health would prevent testifying on merits during the week of February 23rd, though he had no travel conflicts. His counsel offered to make him available on February 24th for only 4 hours to discuss settlement issues. The opposing counsel responded they would use the full 4 hours on February 24th to also question him on merits.

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    The document discusses scheduling issues regarding deposing Jon Huntsman. His counsel offered dates for his deposition during the weeks of February 9th, February 16th, and February 23rd. However, each time his availability changed or new reasons were given for rescheduling. On February 9th, his counsel said his health would prevent testifying on merits during the week of February 23rd, though he had no travel conflicts. His counsel offered to make him available on February 24th for only 4 hours to discuss settlement issues. The opposing counsel responded they would use the full 4 hours on February 24th to also question him on merits.

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    32 views1 page

    Saudi

    Uploaded by

    BessenyeiGeorge
    The document discusses scheduling issues regarding deposing Jon Huntsman. His counsel offered dates for his deposition during the weeks of February 9th, February 16th, and February 23rd. However, each time his availability changed or new reasons were given for rescheduling. On February 9th, his counsel said his health would prevent testifying on merits during the week of February 23rd, though he had no travel conflicts. His counsel offered to make him available on February 24th for only 4 hours to discuss settlement issues. The opposing counsel responded they would use the full 4 hours on February 24th to also question him on merits.

    Copyright:

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    of 1

    SUBMITTED IN CHAMBERS WITHOUT REDACTIONS AND

    FILED ELECTRONICALLY WITH REDACTIONS

    promised dates "by the end of the day" No dates were offered at that time. On the following

    day, Huntsman's counsel, Kathy Patrick, called the Banks' counsel, David Sterling, to discuss

    Jon Huntsman's deposition. Ms. Patrick reported that Mr. Huntsman was "waiting on a call"

    from the king of Saudi Arabia and from another head of state in the Middle East to arrange for a

    business trip for the week of either February 9 or February 16. She offered the Banks dates for

    Mr. Huntsman during the week of February 23. Mr. Sterling suggested that they could make

    plans to depose Mr. Huntsman on February 9 and 10, and if it turned out that he was not

    available then, the deposition could be reset to February 16 and 17. Ms. Patrick said that this

    arrangement would not work because Ms. Patrick would be unavailable on February 9 and

    10. Mr. Sterling then suggested that the Banks could notice Mr. Huntsman for February 16 and

    17, and if it turned out that Mr. Huntsman was abroad that week, the deposition could be

    rescheduled for February 23 and 24. Ms. Patrick said she would consider that approach.

    On February 9, Huntsman's counsel presented yet another reason for not

    presenting Mr. Huntsman: his health. Ms. Patrick informed Mr. Sterling that evening that Mr.

    Huntsman suffers from a variety of health issues which would prevent Mr. Huntsman from

    giving any testimony on the merits during the week of February 23, notwithstanding the fact that

    he has no travel conflicts that week. According to Ms. Patrick, all Mr. Huntsman's health would

    allow that week was a deposition limited to settlement (not merits) issues on February 24

    beginning at 10 a.m. and concluding by 4 p.m.

    Tn a letter the next day, Mr. Sterling noted that the Banks would finish questioning

    Mr. Huntsman on settlement issues during the limited hours Ms. Patrick offered on February 24,

    and that the Banks would then proceed to questions on the merits on that same day within the

    hours allotted by Huntsman. Mr. Sterling offered in the letter to complete Mr. Huntsman's

    HOUJ2: 11 ()2303.6 -4-

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