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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`
`
`
`Plaintiff,
`
`
`
`
`
`
`C.A. No. 2019-0365-JTL
`
`Drivetrain, LLC, as Litigation Trustee of
`the Adeptus Litigation Trust,
`
`
`
`
`
`THOMAS S. HALL, TIMOTHY L.
`FIELDING, GRAHAM B.
`CHERRINGTON, DANIEL W.
`ROSENBERG, DANIEL J. HOSLER,
`RICHARD COVERT, STEVEN M.
`TASLITZ; MERRICK M. ELFMAN;
`DOUGLAS L. BECKER; ERIC D.
`BECKER; CHRISTOPHER HOEHN-
`SARIC; SCP III AIV THREE-FCER
`CONDUIT, L.P.; SCP III AIV THREE-
`FCER, L.P.; SC PARTNERS III, L.P.;
`STERLING FUND MANAGEMENT,
`LLC, STERLING CAPITAL
`PARTNERS III, LLC; and COVERT
`FAMILY LIMITED PARTNERSHIP,
`
`
`
`Defendants.
`
`
`
`v.
`
`
`
`
`
`
`NOTICE OF DEPOSITION OF BRANDON LEWIS
`
`
`TO: Matthew E. Fischer
`Matthew F. Davis
`Andrew H. Sauder
`Mathew A. Golden
`Potter Anderson & Corroon LLP
`1313 N. Market Street, 6th Floor
`Wilmington, DE 19801
`
`John D. Hendershot
`Kevin M. Gallagher
`Alexander M. Krischik
`Ryan D. Konstanzer
`Andrew L. Milam
`Christian C.F. Roberts
`Richards, Layton & Finger, P.A.
`920 North King Street
`Wilmington, Delaware 19801
`(302) 651-7700
`
`EFiled: Apr 01 2021 09:54AM EDT
`Transaction ID 66475589
`Case No. 2019-0365-JTL
`
`

`

`PLEASE TAKE NOTICE THAT pursuant to Chancery Court Rules 26 and
`
`30, Defendant Larry Richard Covert in the above-captioned action, by and through
`
`his undersigned counsel, will take the deposition of Brandon Lewis regarding Mr.
`
`Covert’s defense of release and relevant issues related thereto. The deposition will
`
`commence on April 12, 2021, beginning at 10:30 a.m. or at such other day and time
`
`or at such other location mutually agreed to by the parties. The deposition will be
`
`conducted by videoconference and in accordance with the Joint Stipulation and
`
`Order Governing Remote Depositions, dated January 14, 2021.
`
`The deposition, or portions thereof, will continue from day to day until
`
`completed, and may be recorded by any means permitted under the Chancery Court
`
`Rules, including videotaping and stenographic recording. All counsel of record are
`
`invited to attend and participate. No commission is required because the deponent
`
`listed above is under the control of a party to the above-referenced action.
`
`
`
`OF COUNSEL
`
`Bryan J. Wick
`Jeffrey L. Mills
`WICK PHLILIPS
`3131 McKinney Ave., Suite 500
`Dallas, Texas 75204
`(214) 692-6200
`
`
`April 1, 2021
`
`MORRIS NICHOLS ARSHT &
`TUNNELL LLP
`
`
`/s/ Alexandra M. Cumings
`S. Mark Hurd (#3297)
`Alexandra M. Cumings (#6146)
`1201 North Market Street, 16th Floor
`Wilmington, DE 19801
`(302) 658-9200
`Attorneys for Larry Richard Covert
`
`
`
`
`
`2
`
`

`

`CERTIFICATE OF SERVICE
`I hereby certify that on April 1, 2021, the foregoing was caused to be
`
`served upon the following counsel of record via File and ServeXpress:
`
`Andrew H. Sauder
`Matthew E. Fischer
`Matthew Davis
`POTTER ANDERSON & CARROON LLP
`1313 N. Market Street, 6th Floor
`Wilmington, DE 19801
`
`John D. Hendershot
`Kevin M. Gallagher
`Ryan D. Konstanzer
`Alexander M. Krischik
`RICHARDS, LAYTON & FINGER, P.A.
`One Rodney Square
`920 N. King Street
`Wilmington, DE 19801
`
`/s/ Alexandrda M. Cumings
`Alexandra M. Cumings (#6146)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

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