IN THE FAIRFIELD COUNTY, OHIO COURT OF COMMON PLEAS


Robert A. Nienast
Plaintiff,
-vs-
Board of Trustees of the Fairfield
          County District
Defendant.
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Case No. 09 CV 00657

Judge Martin


NOTICE TO TAKE DEPOSITION DUCES TECUM UPON ORAL EXAMINATION
OF ROBERT A. NEINAST


PLEASE TAKE NOTICE, that on January 28, 2011 at 9:00am pursuant to Rule 30(B) of the Ohio Rules of Civil Procedure Defendant will take deposition duces tecum upon oral examination of Plaintiff Robert A. Neinast ("Plaintiff") at the Fairfield County Hall of Justice, Second Floor Witness Room, 224 East Main Street, Lancaster, Ohio 43130 before a notary public. The Plaintiff shall bring with him to the deposition the documents and other items set forth in Exhibit A, attached hereto. The deposition shall be taken pursuant to the Ohio Rules of Civil Procedure and shall continue from day to day until completed.


  Respectfully submitted,
/s/     Jason M. Dolin          
Jason M. Dolin (0041820)
Assistant Prosecuting Attorney
Fairfield County Prosecutor's Office
201 South Broad Street
Fourth Floor
Lancaster, Ohio 43130
(740) 653-4259
jdolin@co.fairfield.oh.us




EXHIBIT A

PLEASE NOTE: The word "document" is used herein in its broadest sense and refers to any written, typed, printed or other graphic matter of any kind or nature; to any tape, film, disc or other recording or any transcript thereof; to any e-mail; to any information contained in any computer hard drive or on computer diskette or contained in any electronic information storage system and to any other documents as listed by (but not limited to) Rule 34, Ohio Rules of Civil Procedure.

  1. A copy of each and every exhibit that the Plaintiff intends to introduce at the hearing in this action currently scheduled to be held on February 16, 2011.





CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Notice to Take Deposition Duces Tecum Upon Oral Examination of Robert A. Neinast was served upon Robert A. Neinast by hand delivery this 10thth day of January, 2011.



  /s/     Jason M. Dolin          
Jason M. Dolin