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Case 1:04-cv-00048-T -U f PENNSYLVANIA GENERAL INSURANCE tJ COMPANY, a/s/o JOHN STROIS and SAFEGUA, mSURANCE COWANY 4 a/s/o RUI HENRIQUES Plaintiffs, & BANKS, LTD.
c and COTTAGE PLAZA, LLC +J4DefendantdThird-Party Plaintiff e L 3 + 3 "L.
J.H LYNCH & SONS, INC.
\ Page 1 of 1 ) :'
1 .
- \ 1 1 1 1 C.A. No.: 04-48T 9 .:
r <\ 41 ) ) Third-Party Defendant ' i z.2 3C Filed 07/19/2005 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT OF RHODE ISLAND 'f 4 3 Document 56 b DEFENDANTS. COTTAGE PLAZA LLc. CHURCHILL & BANKS. LLc. and CHURCHILL & BANKS. LTD'S, MOTION FOR ALTERNATIVE SERVICE Now come defendants, Cottage Plaza Associates, LLC, Churchill & Banks, LLC and Churchill & Banks, Ltd., and move this Court to allow alternative service of subpoena for 3-x deposition of a witness.
In support of this motion, Defendants provide affidavits from Michael Caires (employed by Constable Richard Davis) (Exhibit A) and Constable Ronald Russo (Exhibit 1 q3, '% B), each attesting to having spent several hours at a time throughout the day on several days 4- 6 outside the home of Joseph Tavares, in an effort to serve Tavares with a subpoena for his KJ P L~ C deposition.
Mr. Tavares, a crucial witness in this matter, has evaded service by not Pappearing at the door of his house, or leaving or entering the house at any time while the F 4 t-1 2 $1 c & , "constables watched. Deposition Notices and Subpoenas are attached as Exhibit C. 2 r\- In further support of this motion, defendants rely upon the attached memorandum. 9 -s
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Case 1:04-cv-00048-T
-U
f
PENNSYLVANIA GENERAL INSURANCE
tJ COMPANY, a/s/o JOHN STROIS and
SAFEGUA,
mSURANCE COWANY
4 a/s/o RUI HENRIQUES
Plaintiffs,
& BANKS, LTD.
c and COTTAGE PLAZA, LLC
+J4DefendantdThird-Party Plaintiff
e L
3
+ 3 "L.
J.H LYNCH & SONS, INC.
\
Page 1 of 1
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1
.
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\
1
1
1
1
C.A. No.: 04-48T
9
.:
r
<\
41
)
)
Third-Party Defendant
'
i
z.2
3C
Filed 07/19/2005
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT COURT OF RHODE ISLAND
'f
4
3
Document 56
b
DEFENDANTS. COTTAGE PLAZA LLc. CHURCHILL & BANKS. LLc. and
CHURCHILL & BANKS. LTD'S,
MOTION FOR ALTERNATIVE SERVICE
Now come defendants, Cottage Plaza Associates, LLC, Churchill & Banks, LLC and
Churchill & Banks, Ltd., and move this Court to allow alternative service of subpoena for
3-x
deposition of a witness.
In support of this motion, Defendants provide affidavits from Michael Caires
(employed by Constable Richard Davis) (Exhibit A) and Constable Ronald Russo (Exhibit
1
q3,
'%
B), each attesting to having spent several hours at a time throughout the day on several days
4-
6 outside the home of Joseph Tavares, in an effort to serve Tavares with a subpoena for his
KJ
P
L~
C
deposition.
Mr. Tavares, a crucial witness in this matter, has evaded service by not
Pappearing at the door of his house, or leaving or entering the house at any time while the
F
4
t-1
2
$1 c
&
,
"constables watched. Deposition Notices and Subpoenas are attached as Exhibit C.
2
r\-
In further support of this motion, defendants rely upon the attached memorandum.
9
-s
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