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IN THE SUPERIOR COURT FOR
THE DISTRICT OF COLUMBIA ROBERT SIEGEL, INC., and 1352-1354 CORPORATION, and AB ENTERPRISES, INC. Plaintiffs, V. THE DISTRICT OF COLUMBIA, Please serve: CASE NO. VERIFIED COMPLAINT FOR PRELIMINARY AND PERMANENT INJUNCTIVE RELIEFPlaintiffs Robert Siegel, Inc., 1352-1354 Corporation, and AB Enterprises, Inc. by and through their undersigned counsel, hereby bring this action against Defendant and state as follows: JURISDICTION1. This Court has jurisdiction pursuant to D.C. Code § 11-921. PARTIES2. Plaintiff Robert Siegel Inc- ("RSI") is a District of Columbia corporation with its principal place of business located in the District of Columbia. RSI owns in fee simple the real estate and improvements located at 1345 Half Street, S.E., Washington, D.C.; 1339-1341 Half Street, S.E., Washington, D-C-; and 24 0 Street, S-E., Washington, D.C. (all contained in square 702, lot 127). 3. Plaintiff 1352-1354 Corporation ("1352-1354") is a District of Columbia corporation with its principal place of business located in the District of Columbia. 1352-1354 owns in fee simple the real estate and improvements located at 1352-1354 South Capitol Street, S.E., Washington, D.C.; 1356 South Capitol Street, S.E., Washington, D.C.; vacant lots 106, 807, 808, 826, 852, 853, 859, 860, 861, 866, and 869 in Square 702 at South Capitol Street, S.E., Washington, D.C. In addition, 1352-1354 is a joint owner with The Donohoe Companies in the unimproved land located at Lots 855 and 868 in Square 702 at the intersection of south Capitol Street, S.E. and N Street, S.E., Washington, D.C. 4. Plaintiff AD Enterprises, Inc. ("AB") is a District of Columbia corporation with its principal place of business located in the District of Columbia. AB operates the businesses which are located on land and in buildings owned by RSI and 1352-1354. Specifically, AB operates a business located on the first floor of 24 0 Street, S.E., Washington, D.C. (land and building owned by RSI); manages storage and inventory warehouse space located at 1339-41 Half Street, S.E., Washington, D.C. (land and building owned by RSI); and occupies office space located at lot 126 in Square 702 of 1356 South Capitol Street, S.E., Washington, DC (land and building owned by 1352-1354). 5. Defendant District of Columbia ("DC") is a municipal corporation with its principal place of business at 1350 Pennsylvania Avenue, NW, Washington, DC 20004. FACTS6. On or about September 29, 2004, DC, the Commission and Baseball Expos, L.P. (a Delaware limited partnership) (the "Team") entered into a Baseball Stadium Agreement ("Agreement"). The Agreement sets forth these parties' "respective undertakings and responsibilities for the relocation of a Major League Baseball franchise to the District of Columbia." Agreement, at Recital. 7. Article 1 of the Agreement defines "Baseball Stadium Site" as "the area of land described in Exhibit B [to the Agreement] as the site for the Baseball Stadium." Exhibit B to the Agreement describes the Baseball Stadium Site as the area "bounded by N Street SE, Potomac Avenue SE, South Capitol Street and 1st Street S.E. The site consists of approximately 21 acres." Plaintiffs own and operate businesses on land within the Baseball Stadium Site. Portions of the real estate and/or the improvements thereon owned by the Plaintiff RSI and 1352-1354 and operated by Plaintiff AB are encumbered by following leaseholds. 8. On or about December 21, 2004, the DC City Council passed the Ballpark Omnibus Financing and Revenue Act of 2004 (Act 15-717) (the "Act"). The Act creates the Ballpark Revenue Fund and otherwise establishes the means by which DC and the District of Columbia Sports and Entertainment Commission ( the "Commission") will meet their financial obligations under the September 29, 2004 Baseball Stadium Agreement. Section 105(b)(2) of the Act provides, in pertinent part, that "The Mayor, subject to such conditions as the Mayor shall determine, shall: (A) [a]cquire and convey to the Anacostia Waterfront Corporation, for use by the Sports and Entertainment Commission to satisfy its responsibilities under this title, all necessary real property, including rights-of-way or other easements, that shall be required to develop, construct, and complete a ballpark within the site bounded by N Street, S.E., Potomac Avenue, S.E., South Capitol Street, S.E. and 1st Street, S.E.." 9. Section 107 of the Act and Section 3 of the Private or Alternative Stadium Financing And Cost Trigger Emergency Act of 2004 (Act 15-718) ("Emergency Act") require DC to review the costs associated with the building of the Stadium, including land acquisition costs (consisting of appraisals of each parcel, an estimate of the environmental remediation costs, and legal expenses associated with land acquisition) and infrastructure costs (consisting of DC's Department of Transportation's estimate for basic road and sidewalk improvements; the cost of expanding the Navy Yard Metro station; and water and sewer relocation costs). On information and belief, in December 2004, the DC Chief Financial Officer estimated these costs at $115 million. 10. Section 107(d) of the Act and Section 3(c) of the Emergency Act require the Chief Financial Officer of DC, prior to May 15, 2005, to re-estimate the costs to DC for land acquisition and infrastructure and provide a report on this re-estimate to the Mayor and Council of DC. 11. Section 107(e) of the Act and Section 3(d) provide that if the total re-estimated costs to DC exceed $165 million, the primary ballpark site shall be deemed financially unavailable to DC pursuant to the Act and the Mayor of DC as well as the Commission, in that circumstance, are to pursue an alternative site for the Stadium. 12. By letter dated March 30, 2005, Natwar M. Gandhi ("Gandhi"), the Chief Financial Officer of DC, notified DC Mayor Anthony Williams and Linda W. Cropp, Chairwoman of the DC Council, that, as instructed by the Emergency Act, he had conducted the study to re-estimate the costs for land acquisition, environmental remediation, and infrastructure requirements. Gandhi's Cost Re-estimation Study for Baseball Stadium is dated March 2005. 13. Gandhi concludes in his March 30, 2005 letter that the costs for land acquisition, environmental remediation, and infrastructure requirements approximate $161.4 million and that based on this finding the site would be deemed "`financially available."' 14. Based on Gandhi's conclusions in his Cost Re-Estimation Study that the Baseball Stadium Site is financially available, DC has announced its intention to begin acquiring the land at the Baseball Stadium Site and its intention to use its power of eminent domain to do so. Plaintiffs will be irreparably harmed if DC condemns their property by eminent domain. COUNT I(Injunctive Relief- Violation of Act and Emergency Act) 15. Paragraphs 1 through 14 are incorporated herein by reference as if fully set forth herein. 16. The Act and the Emergency Act expressly prohibit DC from pursuing the Baseball Stadium Site if the costs associated with land acquisition, environmental remediation and infrastructure will not exceed $165 million. The purpose of requiring the Cost Re-Estimation is to determine what these costs are and whether the Baseball Stadium Site is financially available (the costs do not exceed $165 million) or financially unavailable (the costs exceed $165 million). If the Baseball Stadium Site is financially unavailable, DC must pursue an alternative site that is substantially less costly. Gandhi was inherently obligated under both the Act and the Emergency Act to undertake his Cost Re-Estimation Study in good faith. 17. On its face, the Cost Re-Estimation Study was not conducted in good faith. Rather, on, information and belief, the Study was designed to lead to a known result - to the result that costs associated with land acquisition, environmental remediation and infrastructure will not exceed $165 million. The conclusions in Gandhi's Cost Re-estimation Study are erroneous, speculative, false and unreasonable. On information and belief, the costs for land acquisition, environmental remediation and infrastructure are likely to far exceed the $161.4 million cost estimate in the Cost Re-estimation Study. 18. Although by undertaking the Study DC and Gandhi have technically complied with the provisions of Section 107 of the Act and Section 3 of the Emergency Act, they are not in substantive compliance with the Act and the Emergency Act because, on information and belief, the Study was not conducted in good faith and the costs associated with land acquisition, environmental remediation and infrastructure are likely to far exceed the $165 million statutory cap. 19. Because the costs associated with land acquisition, environmental remediation and infrastructure are likely to exceed $165 million, DC should be enjoined from pursuing the Baseball Stadium Site, including the acquisition of Plaintiffs' land therefor. 20. If the Defendant is not enjoined from locating the Stadium at the proposed Baseball Stadium Site, the Plaintiffs, as intended beneficiaries of that part of the Act and the Emergency Act which requires DC to re-locate the stadium site if the costs at the proposed site exceed $165 million, will suffer irreparable injury. 21. There is substantial likelihood that Plaintiffs will succeed on the merits of this action. 22. Denial of injunctive relief will cause greater injury to Plaintiffs than granting injunctive relief will cause to Defendant. 23. Injunctive relief will serve the public interest, in that it will prevent Defendant from acting beyond the powers granted to it by virtue of the Act and the Emergency Act. WHEREFORE, Plaintiffs seek Preliminary and Permanent Injunctive Relief restraining and prohibiting the Defendant from pursuing the proposed Baseball Stadium Site as the site for the new ballpark, including the acquisition of Plaintiffs' land therefor; damages against the Defendant in the amount of Plaintiffs' costs and attorneys fees in bringing this action; and for such other and further relief as the Court deems just and proper. VERIFICATIONI HEREBY VERIFY, under the penalties of perjury, that, upon personal knowledge or information and belief, the facts set forth in the foregoing Complaint are true and accurate. Robert Siegel as President and Sole Shareholder of Robert Siegel, Inc., 1352-1354 Corporation, and AB Enterprises, Inc. Respectfully submitted, IN THE SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA ROBERT SIEGEL, INC., et al., Plaintiffs, v. DISTRICT OF COLUMBIA, Defendant Civil Action No. MOTION FOR EXPEDITED ANSWERPlaintiffs Robert Siegel, Inc., et al., by and through counsel, hereby move this Court to order Defendant the District of Columbia to file an expedited answer to the Complaint for Preliminary and Permanent Injunction filed herewith, and grounds therefore state as follows: 1. Rule 12(a)(3)(A) of the Superior Court Rules of Civil Procedure provides that the District of Columbia shall serve an answer to a complaint within 60 days after service upon the Corporation Counsel. 2. A copy of the Complaint is being served on the Corporation Counsel contemporaneous herewith. 3. Accordingly, pursuant to Rule 12(a)(3)(A), the District of Columbia's Answer to Plaintiffs' Complaint is due on or about June 7, 2005. 4. It is imperative that an answer to Plaintiffs' Complaint be filed promptly, preferably within the next ten (10) days, so that this case can be expeditiously resolved. Plaintiffs have an interest in expeditious resolution because they have a right to own and enjoy their property and a right that their property should not be acquired for a stadium site which is "financially unavailable" under the Ballpark omnibus Financing and Revenue Act of 2004 (the "Act") and the Private or Alternative Stadium Financing and Cost Trigger Emergency Act of 2004 ("Emergency Act"). The District of Columbia has an interest in expeditious resolution because of the timetables which have been established in the pertinent legislation and in the Baseball Stadium Agreement which the District of Columbia has entered into. The public also has an interest in expeditious resolution because there could be a huge waste of taxpayer dollars if public funds are spent on land acquisition, environmental remediation and infrastructure for the new baseball stadium, and it is determined that the cost estimate to do so exceeds a total of $165,000,000 (whereby under Section 107 of the Act and Section 3 of the Emergency Act, a new site for the stadium would have to be identified). WHEREFORE, Plaintiffs Robert Siegel, Inc., et al., respectfully request that their Motion for Expedited Answer be granted. COOTER, MANGOLD, TEMPERT & KARAS, L.L.P. POINTS AND AUTHORITIES1. Rule 12(a)(3)(A) of the Superior Court Rules of Civil Procedure. 2. Section 107 of the Ballpark Omnibus Financing and Revenue Act of 2004 (Act 15-717) 3. Section 3 of the Private or Alternative Stadium Financing and Cost Trigger Emergency Act of 2004 (Act 15-718). James E. Tompert, Esq. RULE 12-I CERTIFICATIONDespite diligent efforts consent could not be obtained to the relief requested in the foregoing Motion James E. Tompert, Esq. CERTIFICATE OF SERVICEI HEREBY CERTIFY that a copy of the foregoing MOTION FOR EXPEDITED ANSWER was served via hand delivery on this 8th day of April 2005, to: Office of the Corporation Counsel James F. Tompert THE DISTRICT OF COLUMBIA ROBERT SIEGEL, INC., et al., Plaintiffs, v. DISTRICT OF COLUMBIA, Defendant. Civil Action No. ORDERUpon consideration of the Motion for Expedited Answer, and the opposition thereto, it is this _____ day of April 2005 hereby ORDERED that said Motion is granted, and it is further ORDERED that Defendant the District of Columbia shall file an Answer or other responsive pleading to Plaintiffs' Complaint on or before April _____, 2005. Superior Court Judge COPIES TO: Dale A. Cooter, Esq. Office of the Corporation Counsel IN THE SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA ROBERT SIEGEL, INC., et al., Plaintiffs, v. DISTRICT OF COLUMBIA, Defendant. Civil Action No. MOTION FOR EXPEDITED DISCOVERYPlaintiffs Robert Siegel, Inc., et al,, by and through counsel, hereby move this Court to order expedited discovery in this matter, and as grounds therefore state as follows: 1. Plaintiffs need to conduct the deposition duces tecum of Natwar M. Gandhi, Chief Financial Officer of the District of Columbia on an expedited basis. A Notice of Deposition Duces Tecum of Natwar M. Gandhi is attached hereto as Exhibit 1. 2. Mr. Gandhi prepared the Cost Re-estimation Study dated March 30, 2005, which estimates the costs for land acquisition, environmental remediation and infrastructure for the new Baseball Stadium to be $161,400,000. 3. Discovery into the factual basis of the Cost Reeestimation Study is essential to this dispute. In their Complaint, Plaintiffs have challenged the accuracy of the cost estimate and have alleged that a realistic good-faith cost estimate would far exceed the statutory limit of $165,000,000. 4. Rule 34(b) of the Superior Court Rules of Civil Procedure provides, in pertinent part, that the District of Columbia shall have "75 days after service of the summons and complaint" to respond to a document request.1 5. It is imperative that discovery herein be conducted promptly, so that this case can be expeditiously resolved. Plaintiffs have an interest in expeditious resolution because they have a right to own and enjoy their property and a right that their property should not be acquired for a stadium site which is "financially unavailable" under the Ballpark Omnibus Financing and Revenue Act of 2004 (the "Act") and the Private or Alternative Stadium Financing and Cost Trigger Emergency Act of 2004 ("Emergency Act"). The District of Columbia has an interest in expeditious resolution because of the timetables which have been established in the pertinent legislation and in the Baseball Stadium Agreement which the District of Columbia has entered into. The public has an interest in expeditious resolution because there could be a huge waste of taxpayer dollars if public funds are spent on land acquisition, environmental remediation and infrastructure for the new baseball stadium, and it is determined that the cost estimate to do so exceeds a total of $155,000,000 (whereby under Section 107 of the Act and Section 3 of the Emergency Act, a new site for the stadium would have to be identified). 7. Accordingly, Plaintiffs respectfully request leave of Court to conduct the deposition, duces tecum, of Mr. Gandhi on April 25, 2005, as set forth in the attached Notice of Deposition. WHEREFORE, Plaintiffs Robert Siegel, Inc., et al., respectfully request that their Motion for Expedited Discovery he granted. COOTER, MANGOLD, TOMPERT & KARAS, L.L.P. POINTS AND AUTHORITIES1. Rule 34(b) of the Superior Court Rules of Civil Procedure. 2. Rule 30(b)(5) of the Superior Court Rules of Civil Procedure. 2. Section 107 of the Ballpark Omnibus Financing and Revenue Act of 2004 (Act 15-717). 3. Section 3 of the Private or Alternative Stadium Financing and Cost Trigger Emergency Act of 2004 (Act 15-718). James E. Tompert, Esq. RULE 12-I CERTIFICATIONDespite diligent efforts consent could not be obtained to the relief requested in the foregoing Motion. James E. Tompert, Esq. CERTIFICATE OF SERVICEI HEREBY CERTIFY that a copy of the foregoing MOTION FOR EXPEDITED DISCOVERY was served via hand delivery on this 8th day of April 2005, to: Office of the Corporation Counsel James E. Tompert THE DISTRICT OF COLUMBIA ROBERT SIEGEL, INC., et al., Plaintiffs, v. DISTRICT OF COLUMBIA, Defendant. Civil Action No. ORDERUpon consideration of the Motion for Expedited Discovery, and the opposition thereto, it is this _____ day of April 2005 hereby ORDERED that said motion is granted, and it is further ORDERED that Defendant the District of Columbia shall produce Natwar M. Gandhi, the Chief Financial Officer of the District of Columbia for a deposition duces tecum, by April _____, 2005. Superior Court Judge COPIES TO. Office of the Corporation Counsel EXHIBIT 1IN THE SUPERIOR COURT FOR THE DISTRICT OF COLUMBIA ROBERT SIEGEL, INC., et al., Plaintiffs, v. DISTRICT OF COLUMBIA, Defendant. Civil Action No. NOTICE OF DEPOSITION DUCES TECUM OF NATWAR GANDHIPLEASE TAKE NOTICE that Plaintiffs Robert Siegel, Inc., et al., by and through counsel, pursuant to the Superior Court Rules of Civil Procedure, will take the deposition duces tecum of Natwar M. Gandhi, Chief Financial Officer of Defendant the District of Columbia, upon oral examination before a notary public or some other person duly qualified to administer an oath at the offices of COOTER, MANGOLD, TOMPERT & KARAS, L.L.P., 5301 Wisconsin Avenue, N.W., Suite 500, Washington, D.C. 20015 on April 25, 2005 at 10:00 a.m. to continue from day-to-day until completed. The examination will be recorded by stenograph. The deposition is to be taken for purposes of discovery, for use at trial or both, or for any other purpose authorized by the Superior Court Rules. A list of documents to be brought by the deponent is attached hereto as Exhibit "A." COOTER, MANGOLD, TOMPERT & KARAS, L.L.P. CERTIFICATE OF SERVICEI HEREBY CERTIFY that a copy of the foregoing Notice, and Exhibit A, was hand delivered, postage prepaid this day of April 2005, to: Office of the Corporation Counsel James E. Tompert EXHIBIT "A" - DOCUMENTS TO BE PRODUCED AT DEPOSITION OF NATWAR M. GANDHIINSTRUCTIONSA. As used herein "documents" shall mean the original or a copy, regardless of original location, or a copy of the original and any non-identical copy, regardless of original location, or recorded, printed, typed and other graphic material of any kind, variety, type and character, including but not limited to the following: books, records, contracts, agreements, bills, certificates, deeds, bills of sale, certificates of title, financing statements, instruments, expense accounts, canceled checks, bank statements, bank books, receipts and disbursement journals, tax returns, financial statements, check stubs, promissory notes, address books, appointment books or telephone logs,, worksheets, time sheets, pictures, income statements, ledgers, registries, profit and loss statements, balance statements, deposit slips, credit card receipts, records or notations of telephone or personal conversations, conferences of intra-office communications, postcards, letters, telex, partnership agreements, articles of incorporation, leases, subleases, sound, tape or video recordings, memoranda (including written memoranda of telephone conversations, other conversations, discussions, agreements, acts and activities), notebooks, mail, messages, memoirs, publications, resolutions, affidavits, studies, summaries, correspondence, bulletins, minutes, manuals, diaries, calendars or desk pads, scrapbooks, circulars, policies, forms, pamphlets, notices, statements, journals, postcards, telegrams, reports, inter-office communications, photostats, microfilm, microfiche, maps, deposition transcripts, drawings, blueprints, photographs, negatives and other data, information or statistics contained within any data storage modules, tapes, disks or other memory devices (including IBM or similar cards for information, data and programs) or any other information retrievable on storage systems (including computer-generated reports and printouts). B. The term "relate to" or "relating to" shall mean constituting, reflecting, respecting, regarding, concerning, pertaining to, embodying, memorializing, containing, mentioning, studying, analyzing or discussing. C. "You" and "yours" refers to the Deponent named above. D. All documents produced shall be segregated and identified by the request to which they are primarily responsive. E. The documents requested are for the time period and including the date of this request and this is to be considered a continuing request for all future responsive documents through the completion of this proceeding. F. For each document requested herein which is withheld by reason of a claim of privilege, a list is to be furnished identifying each such document for which the privilege is claimed, together with the following information:
G. In producing the documents described below, you are requested to furnish all documents in your possession, custody or control or in the possession, custody or control of any of your representatives and agents, including but not limited to counsel. H. In producing the documents described below, you are requested to furnish the entire file containing the documents, or alternatively to identify the files from which the documents were taken and to produce documents in the same order as existed in those files. I. The phase "all documents" shall mean each and every document within a stated category, and/or documents reasonably subject to identification, and/or documents which can be located on premises leased or owned by you and/or elsewhere. Documents located on premises other than your premises are specifically included. DOCUMENT REQUESTSRequest No. 1: All documents which relate to any of the facts alleged in Plaintiffs' Complaint. Request No. 2: All documents which relate to any of the facts upon which the District of Columbia relies in support of the defenses set forth in its Answer herein. Request No. 3: All documents which relate to your letter dated March 30, 2005 addressed to Anthony A. Williams, Mayor of the District of Columbia and Linda W. Cropp, Chairman of the Council of the District of Columbia ("March 30, 2005 letter"). Request No. 4: All documents which relate to the cost re-estimation of the land acquisition, infrastructure and environmental costs of the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac Avenue, SE, South Capital Street, SE, and 1st Street, SE). Request No. 5: All documents which relate to any cost re-estimation study conducted by you or your office which relate to the land acquisition, infrastructure and environmental casts of the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac Avenue, SE, South Capital Street, SE, and 1st Street, SE). Request No. 6: All documents which relate to the appraisal or valuation of the privately owned real property located in the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac A-venue, SE, South Capital Street, SE, and lst Street, SE). Request No. 7: All, documents which relate to environmental remediation of the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac Avenue, SE, South Capital Street, SE, and 1st Street, SE). Request No. 8: All documents which relate to infrastructure improvements of the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac Avenue, SE, South Capital Street, SE, and 1st Street, SE). Request No. 9: All documents which relate to any contingency costs for the development of the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac Avenue, SE, South Capital Street, SE, and 1st Street, SE) . Request No. 10: All documents which relate to the Property Cost study, the Phase I Environmental Study and/or the Infrastructure Requirements Study prepared by Deloitte & Touche, LLP. Request No. 11: All documents that evidence any communications, including, but not limited to, correspondence, facsimiles, e-Mails or notes of conversations, between you and/or your office, and Deloitte & Touche, LLP, that relate to your March 30, 2005 letter, or your cost re-estimation of the land acquisition, infrastructure and environmental costs of the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac Avenue, SE, South Capital Street, SE, and 1st Street, SE). Request No. 12: All documents that evidence any communications, including, but not limited to, correspondence, facsimiles, e-Mails or notes of conversations, between you and/or your office, and Donn Todd Associates, Inc. that relate to your March 30, 2005 letter, or your cost re-estimation of the land acquisition, infrastructure and environmental costs of the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac Avenue, SE, South Capital Street, SE, and 111C Street, SE). Request No. 13: All documents that evidence any communications, including, but not limited to, correspondence, facsimiles, e-Mails or notes of conversations, between you and/or your office, and Environmental Design & Construction, LLC, that relate to your March 30, 2005 letter, or your cost re-estimation of the land acquisition, infrastructure and environmental costs of the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac Avenue, SE, South Capital Street, SE, and Jar Street, SE). Request No. 14: All documents that evidence any communications, including, but not limited to, correspondence, facsimiles, e-Mails or notes of conversations, between you and/or your office, and any members of the City Counsel of the District of Columbia that relate to your March 30, 2005 letter, or your cost re-estimation of the land acquisition, infrastructure and environmental costs of the proposed site for the new baseball stadium in the District of Columbia (bounded by N Street, SE, Potomac Avenue, SE, South Capital Street, SE, and 111 Street, SE). 1. Rule 30(b)(5) of the Civil Rules of Civil Procedure provides that a deposition "notice to a party deponent may be accompanied by a request made in compliance with Rule 34 for the production of documents." |
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