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IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`BURKE AMERICA PARTS GROUP LLC,
`
`
`
`
`
`
`Plaintiff and
`Counterclaim Defendant,
`
`
`
`C.A. No. 2021-0245-JTL
`
`
`
`v.
`
`
`F3C PARTS LLC,
`
`
`Defendant and
`Counterclaim Plaintiff.
`BURKE AMERICA’S NOTICE OF DEPOSITIONS OF
`MICHAEL J. HALL, JAMES A. GUADIANA, AND JAMES P. SILLERY
`PLEASE TAKE NOTICE that, pursuant to Court of Chancery Rules 26 and
`
`30, Burke America Parts Group LLC, by and through its undersigned attorneys, will
`
`take the following depositions upon oral examination, at the times and locations
`
`listed below, or at such other times and locations as agreed upon by the parties:
`
`DEPONENT
`Michael J. Hall
`(F3C’s Expert)
`James A. Guadiana
`(F3C’s Expert)
`James P. Sillery
`(F3C’s Expert)
`
`LOCATION
`Remote Deposition
`
`Remote Deposition
`
`Remote Deposition
`
`DATE & TIME
`February 18, 2022
`at 9:30 a.m. EST
`February 22, 2022
`at 9:30 a.m. EST
`February 24, 2022
`at 9:30 a.m. EST
`
`The depositions may be recorded by any means permitted under the Court of
`
`Chancery Rules, including videotaping and stenographic recording, and will
`
`continue from day to day until completed. The depositions may be used at trial or
`
`
`
`
`
`EFiled: Feb 09 2022 01:11PM EST
`Transaction ID 67300580
`Case No. 2021-0245-JTL
`
`

`

`any other proceeding in the above-captioned case in any circumstance permitted by
`
`the Delaware Rules of Evidence. All counsel of record are invited to attend and
`
`participate.
`
`Pursuant to Paragraph 9 of the Stipulation and Order Governing Expert
`
`Discovery, granted on January 13, 2022 (Dkt. 161), the parties have agreed that they
`
`will make their experts available for deposition without the need for subpoenas.
`
`
`
`
`
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`
`
`
`
`
`
`February 9, 2022
`
`
`
`
`
`
`
`ROSS ARONSTAM & MORITZ LLP
`
`/s/ Garrett B. Moritz
`Garrett B. Moritz (Bar No. 5646)
`Anthony M. Calvano (Bar No. 6265)
`Thomas C. Mandracchia (Bar No. 6858)
`100 S. West Street, Suite 400
`Wilmington, Delaware 19801
`(302) 576-1600
`
`Attorneys for Plaintiff and
`Counterclaim Defendant
`Burke America Parts Group, LLC
`
`
`2
`
`

`

`CERTIFICATE OF SERVICE
`
`
`
`I, Garrett B. Moritz, hereby certify that on February 9, 2022, I caused a true
`
`and correct copy of Burke America’s Notice of Depositions of Michael J. Hall, James
`
`A. Guadiana, and James P. Sillery to be served through File & ServeXpress on the
`
`following counsel of record:
`
`Eric Lopez Schnabel
`Alessandra Glorioso
`DORSEY & WHITNEY (DELAWARE) LLP
`300 Delaware Avenue, Suite 1010
`Wilmington, Delaware 19801
`
`
`
`
`
`
`
`
`
`
`
`/s/ Garrett B. Moritz
`Garrett B. Moritz (Bar No. 5646)
`
`
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`

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