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`EFiled: Mar 18 2005 5:24PKREST ON
`Filing ID 5395640
`[Sieveae as si
`weeS F
`“GFDEL
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`IN AND FOR NEW CASTLE COUNTY
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`BLACKMORE PARTNERS, L.P.,
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`Plaintiff,
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`v.
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`;
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`C.A. No. 454-N
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`LINK ENERGY LLC, J. ROBERT CHAMBERS,
`JULIE H. EDWARDS, THOMASM.
`MATTHEWS, ROBERT E. OGLE, JAMES M.
`TIDWELL, 8. WIL VANLOHLJR., and DANIEL
`J. ZALOUDEK,
`
`:
`Defendants.
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`PLAINTIFF’S MOTION FOR COMMISSION TO TAKE THE
`OUT-OF-STATE DEPOSITION OF SANDELL ASSET MANAGEMENT CORP,
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`Plaintiff Blackmore Partners, LP (“Plaintiff’) hereby moves this Court, pursuant
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`to Court of Chancery Rules 30(b)(6) and 45, and 10 Del. C, § 368, for an Order, in the form
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`attached hereto, directing that a Commission be issued directly to any Notary Public of the State
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`of New York or other officer authorized to administer oaths under the laws of said State,
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`empowering such person to take the deposition ad testificandum and duces tecum of Sandell
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`Asset Management Corp., 40 West 57th Street, 26th Floor, New York, New York 10019 (by the
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`person or persons most knowledgeable concerning the subject matter of the documents requested
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`in Schedule A to the Order accompanying this motion) commencing at 1:00 p.m. on April 11,
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`
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`EFiled: Mar 18 2005 5:24PM EST
`Filing ID 5395640
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`
`
`
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`2005, or at such other time as may be agreed upon by the parties, at the offices of Abbey Gardy,
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`LLP, 212 East 39" Street, New York, New York 10016."
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`The grounds for this Motion are that the above party is an out-of-state resident
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`that is not a party to this action; the testimony and documents sought are relevant and material to
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`the prosecution of this action; and that compulsory process is necessary to compel the attendance
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`of the witness at deposition and the production of such documents.
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`WHEREFORE,Plaintiff respectfully requests that
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`the Court
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`issue an Order
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`directing that a Commission be issued for the issuance of a subpoena ad testificundum and duces
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`tecum upon the aforementioned party.
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`ROSENTHAL, MONHAIT, GROSS
`& GODDESS, P.A.
`
`
`
`Wilmington, DE 19899
`(302) 656-4433
`Attorneys for Plaintiff
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`OF COUNSEL:
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`Stephen T. Rodd
`Stephanie Amin-Giwner
`Rebecca A. Sheinberg
`ABBEY GARDY, LLP
`212 East 39" Street
`New York, NY 10016
`
`March 18, 2005
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`Deponent need not appearat the scheduled time if the requested documents are produced
`at least 5 business days in advanceof the referenced date. Plaintiff reserves the right to
`schedule a deposition at a later date at the convenience of the deponent and counsel.
`
`
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