Party Discovery: Carmel H. Mcloughlin v. Pfizer Inc., Brenntag Specialties, Inc., F/K/A Mineral Pigment Solutions, Inc., Individually And As A Successor-In-Interest To Whittaker, Clark & Daniels, Inc., The Procter & Gamble Company, Bristol-Myers Squibb Company, Brenntag North America Inc., Individually And As A Successor-In-Interest To Mineral Pigment Solutions, Inc., And Whittaker, Clark, & Daniels, Inc., Cosmetic Specialties, Inc., Ltl Management Llc, Idelle Labs, Ltd., Johnson & Johnson, Helen Of Troy Ltd., Coty Us Llc, Coty Inc.;, Charles B. Chrystal Company, Inc;

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                                FILED: NEW YORK COUNTY CLERK 01/09/2024 01:04 PM                                                INDEX NO. 190302/2023
NYSCEF DOC. NO. 29                                                                       RECEIVED NYSCEF: 01/09/2024




          SUPREME COURT OF THE STATE OF NEW YORK
          ALL COUNTIES WITHIN NEW YORK CITY
                                                                             Re: NYCAL
           IN RE: NEW YORK CITY ASBESTOS LITIGATION                          Index No.: 190302/2023
           This Document Applies to:
                                                                             NOTICE TO TAKE THE
           CARMEL H. MCLOUGHLIN,                                             DISCOVERY
                                                                             DEPOSITION OF
                                          v.                                 PLAINTIFF LESLIE A.
                                                                             SAINT-LOUIS
           PFIZER INC, et al.



          TO ALL COUNSEL:


                 PLEASE TAKE NOTICE that pursuant to the CPLR, New York’s Civil Practice Laws

          and Rules, Plaintiff, Carmel H. McLoughlin, will be made available by her attorneys, Maune

          Raichle Hartley French & Mudd, LLC, for his discovery deposition, Monday, January 29,2024

          through Tuesday, January 30th, 2024. The deposition will take place at the Plaintiff’s home,

         4333 Katonah Avenue, Bronx, NY 10470. The deposition will commence at 10:00 am EDT, and

          will be held in person with the exception of one Plaintiff’s attorney and one Defense attorney who

          will be permitted in person. Call in Information Will be Provided Upon Receipt.

                 NOTICE IS FURTHER GIVEN that we reserve the right to conduct this deposition

          utilizing the secure web-based deposition option afforded by Veritext or in the alternative video

          teleconferencing (VTC) services offered by Veritext (“Web Deposition”) or telephonically only to

          provide remote access for those parties wishing to participate in the deposition via the internet

          and/or telephone. Also take notice that, the court reporter may also be remote via one of the options

          above for the purposes of reporting the proceeding and may or may not be in the presence of the

          deponent. To attend the deposition virtually, please contact Priority One/Veritext Solutions at

          P1Steno@veritext.com. Please contact the noticing attorney at least five (5) calendar days prior to

          the deposition to advise that it is your desire to appear via this remote participating means so that



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FILED: NEW YORK COUNTY CLERK 01/09/2024 01:04 PM                                                    INDEX NO. 190302/2023
NYSCEF DOC. NO. 29                                                                          RECEIVED NYSCEF: 01/09/2024




          the necessary credentials, call-in numbers, testing and information, if necessary, can be provided

          to you prior to the proceedings. In addition, we also reserve the right to utilize instant visual display

          technology such that the court reporter’s writing of the proceeding will be displayed simultaneous

          to their writing of same on one’s laptop, iPad, tablet or other type of display device connected to

          the court reporter.

          Dated: New York, New York
                 January 9, 2024
                                                          MAUNE RAICHLE HARTLEY
                                                          FRENCH & MUDD, LLP



                                                          Jessica A. Bussanich, Esq.
                                                          Attorneys for Plaintiff
                                                          150 West 30th Street, Suite 201
                                                          New York, NY 10001
                                                          (800) 358-5922
                                                          Jbussanich@mrhfmlaw.com

          cc:     Veritext Court Reporting Agency (P1)




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FILED: NEW YORK COUNTY CLERK 01/09/2024 01:04 PM         INDEX NO. 190302/2023
NYSCEF DOC. NO. 29                                 RECEIVED NYSCEF: 01/09/2024




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