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Full text of "court-test-06.gov.uscourts.dcd.115041"

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