Letter,Correspondence: JOHNSON, VANDAVEN vs. BATTLEGROUND OIL SPECIALTY TERMINAL COMPANY LLC

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                                CAUSE NO.              41522
                  VANDAVEN JOHNSON                                                              IN THE DISTRICT COURT OF

                           Plaintiff,



                  BATTLEGROUND OIL SPECIALTY                                                     HARRIS COUNTY, T E X A S
                  TERMINAL COMPANY, LLC; KINDER
                  MORGAN BATTLEGROUND OIL, LLC;
                  KINDER MORGAN, INC.; BOONE
                  TOWING, INC.; and ATLANTIC
                  RICHFIELD COMPANY

                           Defendant                                                                       JUDICIAL DISTRICT


                                             RANTING       EFENDANT          ETITION FOR       ETTERS       OGATORY
                                                  TO   NDUSTRIAL        RODUCTS       IMITED



                           The   Court,   having   considered    Defendant’s     Petition  for  Letters  Rogatory,     finds  that the

                  Petition is well   taken and should be, and hereby is, GRANTED.

                           IT  IS  THEREFORE          ORDERED,        that  the  clerk  of  the  court  issue   a Letters   Rogatory

                  under   the  seal  of this  court  to  the       Judicial  District   of Louisiana,    Jefferson   Parish,   for the

                  purpose   of  taking the   deposition    of the  corporate   representative    of  Industrial  Products    Limited,

                  LLC    by   oral  and   videotaped     examination      in  the  State   of  Louisiana.    The   purpose    of   this

                  deposition is to further discover and develop evidence for use at trial and no other purpose. By

                  this Order,   the  Letter  Rogatory     will authorize    the       Judicial  District   of Louisiana,    Jefferson

                  Parish

                           Issue  a  subpoena    duces   tecum    with  the  attached   Exhibit   “A,”   Areas   of  Inquiry   for the

                           Corporate     Representative      of  Industrial    Products     Limited,    LLC,    and    Exhibit    “B,”

                           Documents       Requested,      for   the    appearance      of   the   corporate     representative     or

                           representatives     of   Industrial    Products    Limited,     LLC     for  deposition     on   Monday,
                           November      4, 2019    at 11  a.m.  at  the  office  of  Galloway,    Johnson,    Tompkins,     Burr,   &

                           Smith, 701 Poydras, 40th Floor, New Orleans, Louisiana 70139.

                       2.  Administer      the  oath   to  the  corporate    representative     or  representatives     of  Industrial

                           Products Limited, LLC.

                       3.  Transcribe the questions, answers, and objections and reduce them to writing.

                       4.  Mark and attach exhibits.

                       5.  Certify the accuracy of the transcription, seal it, the exhibits, and a copy of this letter, and

                           send   them   to  the party   asking   the  first question   and   to any   other  party   that requested

                           copies.



                  DONE AND SO ORDERED on this _____ day of ____________________, 2019.



                                                                                 ____________________________________
                                                                                 JUDGE DONNA ROTH
                                                                                 295th JUDICIAL DISTRICT COURT,
                                                                                 HARRIS COUNTY