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June 5, 2003
Nine B. Hale, Esq.
Re: U.S. v. Smithfield Foods, Inc. (Case No. 1:03CV00434)
Dear Ms. Hale:
Following up on our correspondence and discussions regarding depositions of various officers of the Smithfield family of entities, we have confirmed that the following individuals identified in your letter of May 19 are available on the dates listed below:
We would propose that these depositions be held at our Norfolk, Virginia office which is located at 500 East Main Street, Suite 1000 (SunTrust Center) in Norfolk. Although the Federal Rules limit the depositions to a total of seven hours (Rule 30(d)(2)), it is our hope that the depositions will not consume a full seven hours. Accordingly, if you could tell us the approximate amount of time you anticipate needing for each of the depositions, we would be most grateful.
Lastly, we would be happy to make arrangements for a court reporting service that our Norfolk litigation group has used regularly and found to be quite reliable (Adams Harris Court Reporters).
I look forward to hearing from you regarding the proposed schedule listed above.
Thomas G. Slater, Jr.
ATLANTA AUSTIN BANGKOK BRUSSELS CHARLOTTE DALLAS HONG KONG KNOXVILLE
LONDON McLEAN MIAMI NEW YORK NORFOLK RALEIGH RICHMOND SINGAPORE WASHINGTON