Greg

Thank you for offering to be of assistance in a recent email message. I would appreciate your assistance in the following issues and questions as they pertain to the deposition I am currently ordered to attend. This information is offered in a fair and gentlemanly manner seeking your response in enough time to be received before departure. 

1: I observe in your notice of deposition that no means of recording the deposition is identified. As I read FRCP Rule 30 (b)(2) "The party taking the deposition shall state in the notice the method by which the testimony shall be recorded." The only thing the notice says is that you "will take the oral deposition". I presume the deposition will be recorded by stenographer. If this is true please let me know.

2: According to FRCP Rule 30 (b)(3) I am informing you that I will record the deposition on an audio recording device. Do you find this agreeable?

3: The flight arrangements I am able to make, both due to time and the financial hardship this trip places upon my family at the start of the Christmas season has me arriving in Charleston at 11AM Wednesday the 8th. Your current notice of appeal has the time moved to 9AM. I would like to move it back to 1PM as your original notice of appeal had stipulated as I am unable to arrive earlier in the day without an additional expense and hardship (and hoping I can get some rest on the plane overnight). I will be leaving near noon on the 9th so you will have your complete seven hour period available to you should circumstances warrant. Do you find this agreeable?

4: Would you be so kind as to inform me of who will conduct the deposition and what persons are anticipated to be present?

Have a great weekend

Lee