`Circuit Court
`Sullivan County, Indiana
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`SULLIVAN COUNTY CIRCUIT COURT1
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`CAUSE NO. 77C01-1904-CT-000204
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`STATE OF INDIANA
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`COUNTY OF SULLIVAN
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`MICHAEL D. HICKINGBOTTOM,
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`Petitioner,
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`V.
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`ROBERTE. CARTER,et al.,
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`Defendants.
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`MOTION FOR LEAVE TO DEPOSE
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`Defendants by counsel, Marley G. Hancock, Deputy Attorney General, in accordance
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`with Ind. R. Trial P. 30, respectfully request the Court grant them leave to depose Plaintiff, a
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`prisoner confined at the Wabash Valley Correctional Facility, and in support state the following:
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`1. The Plaintiff has not previously been deposedin this action.
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`2. Plaintiffis an inmate within the Indiana Department of Correction and is currently
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`incarcerated at Wabash Valley Correctional Facility.
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`3. Defendants have not communicated with Plaintiff, who is acting pro se, regarding this
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`request as he is currently incarcerated.
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`4. Arrangements will be made throughthe litigation liaison at the Pendleton
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`Correctional Facility to accommodate said deposition. The undersigned counsel as
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`advisory counsel to the Indiana Department of Correction/Wabash Valley
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`Correctional Facility informs the Court that there is no objection to a deposition
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`taking place at the facility and that adequate arrangements as to space and security
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`can be made.
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`5. Once leave is granted, Defendants will notice the deposition in accordance with Ind.
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`R.Trial P. 30(B).
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`WHEREFORE,Defendants request that the Court grant leave to depose the Plaintiff, a
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`prisoner confined at the Pendleton Correctional Facility.
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`Respectfully submitted,
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`CurTIs T. HILL, JR.
`Indiana Attorney General
`Attorney No. 13999-20
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`By:
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`/s/ Marley G. Hancock
`Marley G. Hancock
`Attorney No. 34617-32
`OFFICE OF ATTORNEY GENERAL
`Indiana Government Center South, 5Floor
`302 West Washington Street
`Indianapolis, IN 46204-2770
`Telephone: (317) 232-6287
`Facsimile: (317) 232-7979
`E-mail: Marley.Hancock@atg.in.gov
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`CERTIFICATE OF SERVICE
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`I hereby certify that on November 30, 2020, I electronically filed the foregoing with the
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`Clerk of the Court using the CM/ECFsystem. Further, I certify that a copy of the foregoing has
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`been duly served uponthe party of record listed below by United States mail, first-class postage
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`prepaid, on November30, 2020:
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`Michael Hickingbottom
`DOC # 147099
`Wabash Valley Correctional Facility
`6908 S. Old US Highway 41
`Carlisle, IN 47838
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`OFFICE OF ATTORNEY GENERAL
`Indiana Government Center South, 5“° Floor
`302 West Washington Street
`Indianapolis, IN 46204-2770
`Telephone:
`(317) 232-6287
`Facsimile: (317) 232-7979
`E-mail: Marley.Hancock@atg.in.gov
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`/s/Marley G. Hancock
`Marley G. Hancock
`Deputy Attorney General
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