`Benton County Circuit Court
`Brenda DeShields, Circuit Clerk
`2022-Aug-25 14:44:35
`04CV-22-771
`C19WD07 : 3 Pages
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`IN THE CIRCUIT COURT OF BENTON COUNTY, ARKANSAS
`CIVIL DIVISION
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`SUSAN E. MASON, as Executor of the Estate of
`WANDA M. WOOLARD, Deceased
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`VS.
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`SILOAM HEALTHCARE, LLC;
`WELLSPRING HEALTHCARE, LLC;
`And JOHN DOE DEFENDANTS 1-5
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`CASE NO. 04CV-22-771
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`PLAINTIFF
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` DEFENDANTS
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`SECOND AMENDED NOTICE TO TAKE DEPOSITION AND
`SUBPOENA DUCES TECUM TO SUSAN MASON
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`TO:
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`Susan Mason
`c/o Rainwater, Holt & Sexton, P.A.
`801 Technology Drive
`Little Rock, AR 72223
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`PLEASE TAKE NOTICE that on Friday, September 23, 2022, at 9:30 a.m., counsel for
`Defendants, Siloam Healthcare, LLC and WellSpring Healthcare, LLC, will take the deposition of
`Susan Mason, in-person, before a duly qualified court reporter. Defendants reserve the right to
`change the in-person nature of this deposition to a deposition to be conducted via Zoom, or some
`alternative virtual platform.
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`Said deposition upon oral examination is taken pursuant to Rule 30 of the Arkansas Rules
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`of Civil Procedure governing depositions. This deposition shall begin at the time specified and
`shall continue thereafter until completed.
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`The witness is requested to produce through counsel at the time specified the items listed
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`in the Subpoena Duces Tecum attached hereto as Exhibit A.
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`DATE/TIME:
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`Friday, September 23, 2022, beginning at 9:30 a.m.
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`PLACE:
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`RAINWATER, HOLT & SEXTON, P.A.
`767 S. 48th Street, Suite C
`Springdale, Arkansas 72762
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`COURT
`REPORTER:
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`Counsel is invited to attend and cross-examine.
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`Alexander Reporting
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`Respectfully submitted,
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`MITCHELL, WILLIAMS, SELIG,
`GATES & WOODYARD, P.L.L.C.
`4206 South J.B. Hunt Drive, Suite 200
`Rogers, Arkansas 72758
`(479) 464-5670 phone
`(479) 878-6930 fax
`lvechik@mwlaw.com
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` By: ____________________________
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`Lindsey C. Vechik, Ark. Bar No. 2007081
`Attorneys for Siloam Healthcare, LLC
`and WellSpring Healthcare, LLC
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`CERTIFICATE OF SERVICE
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`I certify that I have served a true and correct copy of the above document on the following
`person(s) via the court’s electronic filing system and via electronic mail on this 25th day of August,
`2022.
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`Jeff R. Priebe
`Patrick Lee
`Rainwater, Holt & Sexton, P.A.
`P.O. Box 17250
`Little Rock, AR 72222
`jpriebe@rainfirm.com
`plee@rainfirm.com
`Attorney for Plaintiff
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`_________________________________
`Lindsey C. Vechik
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`2
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`EXHIBIT A
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`SUBPOENA DUCES TECUM
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`1. Copies of any notes, diaries, journals and/or calendars in your possession reflecting any
`matters relating to claims made against Defendant(s) in the above action.
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`2. Except communications with your attorney in this matter, copies of all communications,
`writings, statements or correspondence in your possession that relate to the matters alleged
`against Defendant(s) in the above action.
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`3. Except communications with your attorney in this matter, copies of any and all
`electronically stored information, recordings, videotapes, photographs, or other audio,
`audiovisual or photographic material in your possession that depicts, describes or in any
`way related to any claims made against Defendant(s) in the above action.
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`4. Copies of each and every document that you may, will or intend to testify to, quote from,
`refer to, or attempt to use at anytime during your testimony at the trial of this case.
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`5. Except communications with your attorney in this matter, copies of any and all documents,
`statements, notes, emails, content, or commentary in your possession referring or relating
`to the allegations brought against any of the above-named Defendants in the above action,
`including any statements or posts made or otherwise published by Wanda Woolard, her
`family members, or other individuals on or from any social media network source of
`Internet site of any kind, including a blog, chat room, or social media forum of any kind.
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`3
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