Case 1:05-cv-01034-RMU^,,QaQygiQQtJA-4^,. filed 06/13/2007 Page 1 of 16
TRANSMISSION REPORT
(THU) MAY 3 2007 17:15
BETA
DOCUMENT #
TIME STORED
TIME SENT
DURAT I ON
PAGE tS]
MODE RESULT
4861 391-061
5. 3 17:13
5. 3 I 7 1 1 3
r 26"
13
ECM OK
DESTINATION
DST. TEL #
93015877002 | 93015877002
U.S. Department of Justice
United States Attorney
District of Columbia
Judicinry Center
5'55 Fourth SlNM.
Wit;hmpon, IXC 205J(i
USAO-DC
FAX
Cover
To:
Sukari Hardnett
Fax:
Fax: (301) 587-7002
Date:
May 3, 2007
Re:
Short V. Chertoff
Page(s);
17;] including cover
COMMENTS:
From; Rhonda Fields
Phone: 202-514^6970
Defendant's Discovery requests arc attached
FW: Short V,
^M 9W?^%SMl--Mb Document 1 0-4 Filed 06/1 3/2007 Page 2 of^l^^ ^ ^^ ^
Fields, Rhonda (USADC)
From: Sukari Hardnett [s.hardnett@verizon.net]
Sent: Tuesday, June 05, 2007 5:00 PM
To: Fields, Rhonda (USADC)
Subject: RE; Short v, Chertoff CA 05-1 034
I do not believe that this is at issue.
Original Message
From: Fields, Rhonda (USADC) [mailto:Rhonda.Fields@usdoj.gov]
Sent: Tuesday, June 05, 2007 4:23 PM
To: s,hardnett@ver[zon.net
Subject: FW: Short v, Chertoff CA 05-1034
Here is the e-mail which was sent to you on May 3, 2007. You also were sent this by fax and regular mail
Fn>iti; Fields, Rhonda (USADQ
Sent: Thursday, May 03, 2007 4:21 PM
To: 's.hardr>ett{@)verizon.net
Sul^ect: Short v. Chertoff CA 05-1034
Attached please find the defendant's first set of interrogatories and document requests «our discovery
requests,pdf>>
EXHIBIT
II 6
6/12/2007
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 3 of 1 6
Fields, Rhonda (USADC)
From: Fields, Rhonda (USADC)
Sent; Tuesday, June 05, 2007 10:43 AM
To: Fields, Rhonda (USADC); 's.hardnett@verizon,net'
Subject: RE: Short v. ChertoffCA 05-1034
Have you sent your responses to defendant's requests for discovery to me yet?
From: Relds, Rhonda (USADC)
Sent: TTiursday, May 03, 2007 4:21 PM
To; 's,hardnett@verizon.nef
Subject: Short v, Oiertoff CA 05-1034
Attached please find the defendant's first set of interrogatories and document requests « File: our discovery requests.pdf
»
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 4 of 1 6
Fields, Rhonda (USADC)
From; Fields, Rhonda (USADC)
Sent: Tuesday, June 05, 2007 2:18 PM
To: 's.hardnett@verizon.net'
Subject: Short v, Chertoff re scheduling deposition of the defendant
Discovery closes on June 22, and I would like to schedule the plaintiffs deposition. Please let me know when you and
your client can be available for a deposition between June 11-21.
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 5 of 1 6
Fields, Rhonda (USADC)
From: Fields, Rhonda (USADC)
Sent: Wednesday, June 06, 2007 12:12 PM
To: *s.hardnelt@verizon.net'
Subject: Short v, Chertoff
Attachments; Notice.depo.pdf
My client is not willing to consent to an extension of time for discovery. Attached please find a Notice of Deposition for
Not]ce,depo.pdf
(34 KB)
your client.
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 6 of 1 6
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
GEORGE A. SHORT,
Plaintiff
MICHAEL CHERTOFF, SECRETARY
UNITED STATES DEPARTMENT OF
HOMELAND SECURITY,
Defendant
avfl Action No. 05-01034 (RMU)
RECEIPT
A copy of Notice of Deposition was delivered by courier to:
GEORGE SHORT, Plaintiff
C/O C. Sukari Hardnett
1111 Bonifant Street
Silver Spring, MD 20910 (tracking no. 1380463)
from Rhonda C. Fields, Assistant United States Attorney for the District of Columbia.
Enclosures
I HEREBY ACKNOWLEDGE RECEIPT OF THE ABOVE-DESCRIBED ON JUNE
6^ . 2007.
C. Sukari Hardnett
1111 Bonifant Street
Silver Spring, MD 20910
Tyrell Gam
Legal Assistant
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 7 of 1 6
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
GEORGE A. SHORT,
Daintiff
MICHAEL CHERTOFF, SECRETARY
UNITED STATES DEPARTMENT OF
HOMELAND SECURITY,
Defendant
Civil Action No. 05-01034 (RMU)
NOTICE OF DEPOSITION
To: GEORGE SHORT, Plaintiff
C/O C. Sukari Hardnett
1111 Bonifant Street
Silver Spring, MD 20910
Fax: (301) 587-7002
Email: s.hardnett@verizon.ne
PLEASE TAKE NOTICE that the defendant will take the deposition of George Short pursuant to Rule 30
(b) of the Federal Rules of Civil Procedure, on oral examination before a notary public or other officer
authorized to administer oaths, via stenography and oral report the IS* day of June, 2007, commencing
at 9:00 a.m. and continuing thereafter until the deposition is completed, at the Office of the United States
Attorney for the District of Columbia, 501 3rd Street, N.W., 4th"' Floor, Washington, D.C. 20530.
RHONDA C. FIELDS
Assistant United States Attorney
Judiciary Center Building
555 4* Street, N.W
Washington, DC. 20530
202/514-6970
<qJ^—
Case 1:05-cv-01034-RMU :..DaGUQT.SQtJjPl-4.*^.filecl 06/13/2007 Page 8 of 16
TBANSMrSSION REPORT
(WED) JUN 6 2007 12:34
BETA
DOCUMENT #
TIME STORED
TIME SENT
DURAT I ON PAGE ( S )
MODE
RESULT^
4861 391-300 6, 6 12 :34
6. 6 12:34
17" 2
ECM
OK
DESTINATION
DST. TEL n
93Q13877QQ2 |g30l5877002
To:
Fax:
Date:
Re:
Page(s):
U,S- Dq>arUiicnt of Justice
United States Attorney
District of Columbia
Judiciary Ceftier
SJS Fourth Sr. N.W.
Wo^ihinpon, D.C. 20SSQ
Sulcari Hardnett]
301-587-7002
June 6, 2007
George Short
2 including cover
USAO-DC
FAX
Cover
From: Rhonda Firelds
Phone: 202-514-6970
COMMENTS:
Notice of Deposition Attached
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 9 of 1 6
U.S. Department of Justice
United States Attorney
District of Columbia
Judiciofy Center
555 Fourth St. N.W.
Washington, D.C 20530
USAO-DC
FAX
Cover
To:
Sukari Hardnett]
Fax:
301-587-7002
Date:
June 6, 2007
Re:
George Short
Page(s):
2 including cover
COMMENTS:
Notice of Deposition Attached
From: Rhonda Firelds
Phone: 202-514-6970
U.S. ATTORNEY FACSIMILE COMMUNICATION
WARNING: Information attached to this cover sheet is U.S. Government Property,
If you are not the intended recipient of this information, disclosure^ reproduction,
distribution, or use of this information is prohibited. Piease notify the originator
Immediately to arrange for proper disposition.
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 1 of 1 6
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
GEORGE A. SHORT,
Flaintiff
V.
MICHAEL CHERTOFF, SECRETARY
UNITED STATES DEPARTMENT OF
HOMELAND SECURITY,
Defendant
CivU Action No. 05-01034 (RMU)
NOTICE OF DEPOSITION
To: GEORGE SHORT, Plaintiff
C/O C. Sukari Hardnett
1111 Bonifant Street
Silver Spring, MD 20910
Fax:(301)587-7002
Email: s.hardnett@verizon.ne
PLEASE TAKE NOTICE that the defendant will take the deposition of George Short pursuant to Rule 30
(b) of the Federal Rules of Civil Procedure, on oral examination before a notary public or other officer
authorized to administer oaths, via stenography and oral report the U"" day of June, 2007, commencing
at 9:00 a.m. and continuing thereafter until the deposition is completed, at the Office of the United States
Attorney for the District of Columbia, 501 3rd Street, N.W., 4th* Floor, Washington, D.C. 20530.
^qJ^-
RHONDA C. FIELDS
Assistant United States Attorney
Judiciary Center Building
555 4* Street, N.W
Washington, D.C. 20530
202/514-6970
^' ^teSl^'ft^^dl^(?l-"l^*i^6 Document 10-4 Filed 06/13/2007 Page 1 1 ofP^^ 1 of 1
Fields, Rhonda (USADC)
From: Fields, Rhonda (USADC)
Sent: Monday, June 1 1, 2007 4:59 PM
To: 'Sukari Hardnett'
Subject: RE: Short v. ChertoffCA 05-1034
In our conversation you stated that you would not be available for deposition following June 14 and suggested
dates in July. Those dates are beyond the cut off for discovery. As I advised you, my client will not consent to an
extension of discovery. Pursuant to the local rules notice of depositions is reasonable with service 5 days in
advance of the date set for deposition.
From: Sukari Hardnett [mailto;s.hardnett@verizon,net]
Sent: Monday, June 11, 2007 4:44 PM
To: Fields, Rhonda (USADC)
Subject: RE: Short v. Chertoff CA 05-1034
Enclosed you will find the letter that I suggested that you should review.
Original Message
From: Fields, Rhonda (USADC) [maittD:Rhonda.Fields@usdoj-gov]
Sent: Monday, June 11, 2007 3:45 PM
To: s,hardnett@verizon,net
Subject: RE: Short v. Chertoff CA 05-1034
When we spoke last week, we agreed that you would send to me the responses to defendant's discovery
requests by the end of last week. The response to our discovery requests has not arrived. Please e-mail
or fax them to me today. My lax number is 202-514-8780. I need the documents so that lean review
them before the deposition of your client on June 13.
FHom: Relds, Rhonda (USADC)
Sent Tuesday, June 05, 2007 ^-23 PM
To: 's,hardrKlt@verizon.nef
Subject: FW: Short v. Chertoff 0\ 05-1034
Here is the e-mail which was sent to you on May 3, 2007, You also were sent this by fax and regular mail
From: Fields, Rhonda (USADQ
Sent Thureday, May 03, 2007 4:21 PM
To: 's.hardnett@veft2Dn.net'
Subject: Short v. Chertsoff CA 05''1034
Attached please find the defendant's first set of interrogatories and document requests « File: our
discovery requesls.pdf »
EXHIBIT
II a
6/13/2007
^' ^^M 9!!^f-6^fb9^-Mj Document 1 0-4 Filed 06/1 3/2007 Page 1 2 oft^ ^ ^^ ^
Fields, Rhonda (USADC)
From: Sukari Hardnelt [s, hardnett@verizon.net]
Sent: Monday, June 1 1 , 2007 4:44 PM
To: Fields, Rhonda (USADC)
Subject: RE: Short v. Chertoff CA 05-1034
Attachments: Letter to Fieldsl .pdf
Enclosed you will find the letter that I suggested that you should review.
Original Message
From: Fields, Rhonda (USADC) [mailto: Rhonda, Fields@usdoj.gov]
Sent: Monday, June 11, 2007 3:45 PM
To: s.hardnett@verizon.net
Subject: RE: Short v, Chertoff CA 05-1034
When we spoke last week, we agreed that you would send to me the responses to defendant's discovery
requests by the end of last week. The response to our discovery requests has not anived. Please e-mail
or fax them to me today. My fax number is 202-514-8780. I need the documents so that 1 can review
them before the deposition of your client on June 1 3,
Fkom: Fields, Rhonda (USADQ
Sent; Tuesday, June 05, 2007 ^:23 PM
To; ■s.handnett@verizon.nfif
Subject: FW: Short v. Chertoff CA 05-103^
Here is the e-mail which was sent to you on May 3, 2007. You also were sent this by fax and regular mail
From: Fields, Rhonda [USADC)
Sent Thursday, May 03, 2007^:21 PM
To: 's.hardr>ett@verizon,nef
Subject: Short v, CtiertofT CA 05-1034
Attached please find the defendant's first set of Interrogatories and document requests « File: our
discovery requests.pdf »
6/13/2007
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 1 3 of 1 6
LAW OFFICE OF
C. SUKARI HARDNETT
IIU BONIFANT STREET
SILVER SPRING, MARYLAND 20910
s .hardnett@V6rizon.nct
Telephone (301) 587^7001
Facsimile (301) 587-7002
June 10, 2007
VIA FACSIMILE AND ELECTRONIC & US MAIL:
Rhonda C, Fields
Assistant United States Attorney
Judiciary Center Building
555 4* Street, NW
Washington DC 20530
Re: Short v, Chertoff
Civil Action Mo. 05-01034 (RMU)
Dear Ms, Fields:
I am in receipt of the Notice of Deposition that you issued to take the deposition
of the Plaintiff. I was quite surprised to receive your notice, for I informed you on June
6, 2007, that I am not available for depositions on June 13, 2007. I notified you of my
dates of availability by telephone, and you indicated that you woxild get back to me.
Instead at the twelfth hour, you issued a Notice of Deposition for one of the dates that 1
previously informed you that I was not available. Your last minute fex and dehveiy of
the deposition notice (which notably does not have a certificate of service) does not
constitute reasonable notice under Rule 30(b)(1). Please advise whether you will
voluntarily withdraw your notice, or whether I will have to file an emergency motion for
protective order.
If you wish to conduct the deposition of the Plaintiff then, as I already discussed
with you, we will have to file a consent motion to extend the discovery deadlines to
conduct the deposition on one of the dates that I informed you on which I am available. I
also intend to conduct depositions of your client's 30(b)(6) designee and other agents and
representatives.
Please instruct me how you wish to proceed as soon as possible.
Sincerely yours.
C. Sukari Hardnett, Esq.
Case 1:05-cv-01034-RMU *.DaGLi0iaQtm-4...^ Filed 06/13/2007 Page 14 of 16
TRANSMISSION REPORT
(MON) JUN !1 2007 16:56
BETA
DOCUMENT #
TIME STORED
TIME SENT
DURATION
PAGE (S)
MODE
RESULT
4661391 -336
6. I 1 16 : 55
6. 1 1 1 6:55
18"
2
ECM
OK
DESTINATION
5301 5S77002
DST. TEL #
93015877002
U.S. Department of Justice
United Stales Aiiomey
District of Columbia
Judicifffy C€fJter
S55 Fourth Si. NM
Wajfiir^Ofi, D.C 20SiQ
USAO-DC
FAX
Cover
To:
C. Sukari Hardnett
Fax:
(301)587-7002
Date:
June 11, 2007
Re;
Short V, Chertoff discovery responses
Page(s):
2 including cover
COMMENTS:
From: Rhonda Fields
Phone: 202-514-6970
Please see attached letter requesting delivery of yoxir responses today
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 1 5 of 1 6
U,S, Department of Justice
United States Attorney
District of Columbia
Judiciary Center
555 Fourth St. N.W.
Wushingiofty D.C. 20530
USAO-DC
FAX
Cover
To:
C. Sukari Hardnett
Fax:
(301) 587-7002
Date:
June 11,2007
Re:
Short V. Chertoff discovery responses
Page(s):
2 including cover
COMMENTS:
From: Rhonda Fields
Phone: 202-514-6970
Please see attached letter requesting delivery of your responses today
U.S. ATTORNEY FACSIMILE COMMUNICATION
WARNING: Information attached to this cover sheet is U.S. Government Property.
If you are not the intended recipient of this information, disclosure, reproduction,
distribution, or use of this information is prohibited. Please notify the originator
Immediately to arrange for proper disposition.
Case 1 :05-cv-01 034-RMU Document 1 0-4 Filed 06/1 3/2007 Page 1 6 of 1 6
U.S. Department of Justice
Jeffrey A, Taylor
United States Attorney
District of Columbia
Judiciary Center
555 Fourth St., N.W.
Washington, D.C. 20530
June 11,2007
C. Sukari Hardnett
1 11 1 Bonifant Street
Silver Spring, MD 20910
ByFax: (301) 587-7002
Re: Short v. Chertoff CA 5-1034
Dear Ms. Hardnett:
As of 3:00 pm on June 1 1 , 2007, I have not received responses to the Interrogatories and
Document Requests served on you on May 3, 2007. Last week we agreed that you would get the
responses to me by the end of last week. The deposition of the plaintiff has been noticed for June
13, 2007, at 9:00 am. You have stated that you will be unavailable for depositions fix)m June 14
until July. Discovery in this case closes on June 22, 2007.
Please PDF or fax your discovery responses to me today. My fax number is 202-5 1 4-
6970* Should you fail to respond to defendant's written discovery requests, I will be forced to
seek action from the Court pursuant to F*R*Civ.P. 37,
Sincerely
By:
JEFFREY A. TAYLOR,
United States Attorney
RHONDA C. FIELDS
Assistant United States Attorney
Civil Division
555 Fourth Street, N.W.
Washington, D.C, 20530
202/514/6970
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