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11/3/23, 11:51 AM Gmail -
Kirchoff v. Burgess
Filed: 11/3/2023 12:33 PM
Knox Circuit Court
M Gmail
Knox County, Indiana
Cole Kirchoff
Kirchoff v. Burgess
6 messages
Cole Kirchoff Wed, Oct 11, 2023 at 7:01 AM
To: anna.finnerty@libertymutual.com, Jordan Johnson
Anna,
My office has been trying to reach you in regard to scheduling a deposition of your client, Jeff Burgess. If you could let us
know some dates that would work for you that would be great.
Best,
Cole L. Kirchoff
KIRCHOFF & JEWEL
517 Broadway PO Box 944
Vincennes, Indiana 47591
(812) 882-8600 FAX (812) 882-5978
colekirchofflaw@gmail.com
CONFIDENTIALITY NOTICE
The information and/or documents contained in this message is intended only for the personal and confidential use of
the designated recipients named above. This message may be an attorney-client communication, and as such
is privileged and confidential. If the recipient of this message is not the intended recipient or an agent responsible for
delivering it to the intended recipient, you are hereby notified that you have received this message in error, and that
lf have
any review, dissemination, distribution or copying of this message, or any attachments, is strictly prohibited. you
received this telecopy in error, please notify us immediately by telephone at the above number to arrange for the return of
the original documents. Thank you.
Finnerty, Anna Tue, Oct 17, 2023 at 10:48 AM
To: Cole Kirchoff , Jordan Johnson
Cc: "Nicholson, Lenise"
| am adding Lenise to accomplish this. We will also need to take deposition of plaintiff.
Anna C finnerty
Staff Attorney
Liberty Mutual Group Field Legal Offices
A Staff Legal Office of the Liberty' Mutual Group of Insurance Companies
Not a Partnership or Professional Corporation
All Attorneys and Staff Members are Employees of The Liberty Mutual Group, Inc.
Direct Telephone Number: 317-249-2650
Office Telephone Number: 3175820438
1/3
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11/3/23, 11 :51 AM Gmail -
Kirchoff v. Burgess
Cell Plume: 812202-8032
Email Address: Anna.Finnertv©LibertvMutuaLcom
flysical Office Address
350 East 96th Street, Suite 100
Indianapolis, IN 46240
Office Mailing Address
PO Box 6835
Scranton, PA 18505-6835
This e-mail, and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally
privileged and/or confidential information. lf you are not the intended recipient of this e-mail, you are hereby notified that any
dissemination, distribution or copying of this e-mail and attachments thereto, is strictly prohibited. If you have received this e-mail in
error, please notify me via return e-mail and via telephone at 317-249-2650 and permanently delete the original and any copy of any
e-mail and any printout thereof. Please be advised that there is a risk a third party can gain access when sending or receiving
electronic communications using a computer or other device, or e-mail account.
[Quoted text hidden]
Cole Kirchoff Tue, Oct 17, 2023 at 10:53 AM
To: "Finnerty, Anna"
Cc: Jordan Johnson , "Nicholson, Lenise"
Anna,
Adeposition of Mr. Burgess has been scheduled for November 7, 2023, at 1pm.
[Quoted text hidden]
Nicholson, Lenise Tue, Oct 17, 2023 at 12:12 PM
To: Cole Kirchoff , "Finnerty, Anna"
Cc: Jordan Johnson
That date was not coordinated with our office. l am checking with our client as to his availability on this date and will
advise.
Lanai Ware/m
Legal Secretary
Liberty Mutual Group Field Legal Offices
A Staff Legal Office of the Liberty Mutual Group of Insurance Companies
Not a Partnership or Professional Corporation
All Attorneys and Staff Members are Employees of The Liberty Mutual Group, lnc.
Direct Dial: (2 19) 5256067
https://mail.google.com/mail/u/O/?ik=805435e0f5&view=pt&search=all&permthid=thread-asr3459074216244135716&simpl=msg-a:r-30857059842959,.. 2/3
11/3/23, 11:51 AM Gmail -
Kirchoff v. Burgess
Fax: (603) 334-7281
Lenise.Nicholson@Libertymutual.com
Effective immediately and for an indeterminate period of time, please forward ALL documents,
pleading,
etc. to our office via:
Email to: Merrillvillefieldlegal@libertymutual.com
Fax: 603-334-7281
**
Please be advised this office is now a paperless environment **
As such, we will communicate via e-mail and/or e-fax. Please contact this office immediately to provide your preferred
e-mail address for all future communications. Please forward all future correspondence,
including discovery requests,
discovery responses, motions, etc. to MerrillviIleFieldLegal@LibertyMutual.com or via e-fax: (603) 334-7281.
Please be advised that there is a risk a third party can gain access when sending or receiving electronic communications using a
computer or other device, or emaii account.
This e-mail, and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally
privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any
dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-
mail in error, please notify me via return e-mail and via telephone at 219-756-7408 and permanently delete the original and any copy
of any e-mail and any printout thereof.
[Quoted text hidden]
Cole Kirchoff Tue, Oct 17, 2023 at 12:14 PM
To: "Nicholson, Lenise"
Cc: "Finnerty, Anna" , Jordan Johnson
My office reached out and tried to coordinate scheduling a deposition for over two weeks. When we received no response
to our voicemails that were left or email sent, we went ahead and scheduled the deposition.
[Quoted text hidden]
Nicholson, Lenise Tue, Oct 17, 2023 at 12:29 PM
To: Cole Kirchoff , "Finnerty, Anna"
Cc: Jordan Johnson
Our client is available on November 7, 2023 at 1:00 p.m. (EST) .
[Quoted text hidden]
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11/3/23, 11:51 AM Gmail - Kirchoff v. Burgess Filed: 11/3/2023 12:33 PM Knox Circuit Court M Gmail Knox County, Indiana Cole Kirchoff Kirchoff v. Burgess 6 messages Cole Kirchoff Wed, Oct 11, 2023 at 7:01 AM To: anna.finnerty@libertymutual.com, Jordan Johnson Anna, My office has been trying to reach you in regard to scheduling a deposition of your client, Jeff Burgess. If you could let us know some dates that would work for you that would be great. Best, Cole L. Kirchoff KIRCHOFF & JEWEL 517 Broadway PO Box 944 Vincennes, Indiana 47591 (812) 882-8600 FAX (812) 882-5978 colekirchofflaw@gmail.com CONFIDENTIALITY NOTICE The information and/or documents contained in this message is intended only for the personal and confidential use of the designated recipients named above. This message may be an attorney-client communication, and as such is privileged and confidential. If the recipient of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this message in error, and that lf have any review, dissemination, distribution or copying of this message, or any attachments, is strictly prohibited. you received this telecopy in error, please notify us immediately by telephone at the above number to arrange for the return of the original documents. Thank you. Finnerty, Anna Tue, Oct 17, 2023 at 10:48 AM To: Cole Kirchoff , Jordan Johnson Cc: "Nicholson, Lenise" | am adding Lenise to accomplish this. We will also need to take deposition of plaintiff. Anna C finnerty Staff Attorney Liberty Mutual Group Field Legal Offices A Staff Legal Office of the Liberty' Mutual Group of Insurance Companies Not a Partnership or Professional Corporation All Attorneys and Staff Members are Employees of The Liberty Mutual Group, Inc. Direct Telephone Number: 317-249-2650 Office Telephone Number: 3175820438 1/3 https://mai|.google.com/mai|/u/O/?ik=805435e0f5&view=pt&search=all&permthid=thread-a:r3459074216244135716&simpl=msg-a:r-30857059842959... 11/3/23, 11 :51 AM Gmail - Kirchoff v. Burgess Cell Plume: 812202-8032 Email Address: Anna.Finnertv©LibertvMutuaLcom flysical Office Address 350 East 96th Street, Suite 100 Indianapolis, IN 46240 Office Mailing Address PO Box 6835 Scranton, PA 18505-6835 This e-mail, and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. lf you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail and attachments thereto, is strictly prohibited. If you have received this e-mail in error, please notify me via return e-mail and via telephone at 317-249-2650 and permanently delete the original and any copy of any e-mail and any printout thereof. Please be advised that there is a risk a third party can gain access when sending or receiving electronic communications using a computer or other device, or e-mail account. [Quoted text hidden] Cole Kirchoff Tue, Oct 17, 2023 at 10:53 AM To: "Finnerty, Anna" Cc: Jordan Johnson , "Nicholson, Lenise" Anna, Adeposition of Mr. Burgess has been scheduled for November 7, 2023, at 1pm. [Quoted text hidden] Nicholson, Lenise Tue, Oct 17, 2023 at 12:12 PM To: Cole Kirchoff , "Finnerty, Anna" Cc: Jordan Johnson That date was not coordinated with our office. l am checking with our client as to his availability on this date and will advise. Lanai Ware/m Legal Secretary Liberty Mutual Group Field Legal Offices A Staff Legal Office of the Liberty Mutual Group of Insurance Companies Not a Partnership or Professional Corporation All Attorneys and Staff Members are Employees of The Liberty Mutual Group, lnc. Direct Dial: (2 19) 5256067 https://mail.google.com/mail/u/O/?ik=805435e0f5&view=pt&search=all&permthid=thread-asr3459074216244135716&simpl=msg-a:r-30857059842959,.. 2/3 11/3/23, 11:51 AM Gmail - Kirchoff v. Burgess Fax: (603) 334-7281 Lenise.Nicholson@Libertymutual.com Effective immediately and for an indeterminate period of time, please forward ALL documents, pleading, etc. to our office via: Email to: Merrillvillefieldlegal@libertymutual.com Fax: 603-334-7281 ** Please be advised this office is now a paperless environment ** As such, we will communicate via e-mail and/or e-fax. Please contact this office immediately to provide your preferred e-mail address for all future communications. Please forward all future correspondence, including discovery requests, discovery responses, motions, etc. to MerrillviIleFieldLegal@LibertyMutual.com or via e-fax: (603) 334-7281. Please be advised that there is a risk a third party can gain access when sending or receiving electronic communications using a computer or other device, or emaii account. This e-mail, and any attachments thereto, is intended only for the use of the addressee(s) named herein and may contain legally privileged and/or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e- mail in error, please notify me via return e-mail and via telephone at 219-756-7408 and permanently delete the original and any copy of any e-mail and any printout thereof. [Quoted text hidden] Cole Kirchoff Tue, Oct 17, 2023 at 12:14 PM To: "Nicholson, Lenise" Cc: "Finnerty, Anna" , Jordan Johnson My office reached out and tried to coordinate scheduling a deposition for over two weeks. When we received no response to our voicemails that were left or email sent, we went ahead and scheduled the deposition. [Quoted text hidden] Nicholson, Lenise Tue, Oct 17, 2023 at 12:29 PM To: Cole Kirchoff , "Finnerty, Anna" Cc: Jordan Johnson Our client is available on November 7, 2023 at 1:00 p.m. (EST) . [Quoted text hidden] https://mai|.google.com/mai|/u/0/?ik=805435e0f5&view=pt&search=a||&permthid=thread-a:r3459074216244135716&simpl=msg-a:r-30857059842959... 3/3