Jones v. Deutsch Notice of Deposition

    UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK

X
YVONNE JONES, et al.,

Plaintiffs,
-against-

LAURENCE DEUTSCH, et al.,
Defendants.

X

88 Civ. 7738 (GLG) 

NOTICE OF DEPOSITION

PLEASE TAKE NOTICE that pursuant to Rule 30 of the 
Federal Rules of Civil Procedure, plaintiffs will take the 
deposition of defendant Laurence Deutsch, 211 Wood Hampton 
Drive, White Plains, New York 10603, at 10:00 A.M., on 
January 4, 1989, at the offices of the Westchester Coalition, 
1 Prospect Avenue, 2nd Floor, White Plains (Greenburgh), New 
York 10607, before a person authorized by the laws of the 
State of New York to administer oaths.

PLEASE TAKE FURTHER NOTICE that, pursuant to Rules 
30 and 34 of the Federal Rules of Civil Procedure, the



deponent is requested to bring with him to the deposition the 
documents listed in Schedule A for inspection and copying.

You are invited to attend and to cross examine.

Dated: New York, N.Y.
November 30, 1988

PAUL, WEISS, RIFKIND, WHARTON & GARRISON

By — L' / C— _____________
/ Jay L. Himes

1285 Avenue of the Americas 
New York, New York 10019 
(212) 373-3000
Robert M. Hayes 
Virginia Schubert 
COALITION FOR THE HOMELESS 
105 East 22nd Street 
New York, N.Y. 10010 
(212) 460-8110
Andrew M. Cuomo 
2 Park Avenue, Suite 1415 
New York, N.Y. 10026 
(212) 686-1000
Julius L. Chambers 
John Charles Boger 
Sherrilyn Ifill 
NAACP LEGAL DEFENSE FUND 
99 Hudson Street 
New York, N.Y. 10013 
(212) 219-1900

(Continued on next page)

2



Grover G. Hankins 
NAACP SPECIAL CONTRIBUTION FUND 
4805 Mount Hope Drive 
Baltimore, MD 21215 
(301) 486-9191
Edward Hailes, Jr.
NAACP, INC.
4805 Mount Hope Drive 
Baltimore, MD 21215 
(301) 358-8900

Attorneys for Plaintiffs

TO: Attached Service List

3



Service List
Jones, et al. v. Deutsch. et al.

JONATHAN LOVETT, ESQ.
Lovett & Gould
180 E. Post Road
White Plains, N.Y. 10601
Attorney for Defendants Laurence Deutsch, 
Steven Neil Goldrich, Michael James Tone and 
Coalition of United Peoples, Inc.

TIMOTHY QUINN, ESQ.
Quinn & Suhr
170 Hamilton Avenue
White Plains, N.Y. 10601
Attorney for Defendant Colin Edwin Kaufman

PAUL AGRESTA, ESQ.
Town of Greenburgh 
Office of the Town Attorney 
P.O. Box 205 
Elmsford, N.Y. 10523
Attorney for Defendant Anthony F. Veteran

4



Schedule A
Notice of Deposition of Laurence Deutsch

Definitions and Instructions
1. The term "document" is used in the broadest 

sense and includes all writings of every nature and all 
tangible things from which information can be transcribed or 
processed. The term includes, but is not limited to, all 
forms of written or recorded communications, letters, corre­
spondence, telegrams, tapes, recordings, cables, contracts, 
agreements, diaries, memoranda, logs, notes, analyses, 
estimates, projections, work papers, books, charts, maps, 
forms, brochures, bulletins, drawings, reports, digests, or 
any other information or data, records or compilations, 
including all underlying, supporting or preparatory material 
and drafts now or formerly in defendant Deutsch's possession, 
custody or control.

2. "Relating to" means in connection with, 
concerning, reflecting, referring to, describing, analyzing, 
discussing, evidencing, constituting or having as a subject 
matter in part or in whole.

3. If the original of any document is not in the 
deponent's possession, custody or control, this request calls 
for a copy of the original document.

1



4. The terms "and" and "or" shall be construed 
inclusively so as to bring within the scope of the request 
documents that might otherwise arguably be construed as 
outside the scope of the request.

5. The term "Mayfair Knollwood" refers to the 
proposed village to be located within the Town of Greenburgh, 
New York, which is the subject of a petition presented to the 
Town of Greenburgh on or about September 14, 1988.

6. The term "West HELP" refers to the proposed 
housing for homeless families to be built on a site in the 
Town of Greenburgh, New York.

7. The term "COUP" refers to defendant Coalition 
of United Peoples, and each of its directors, officers, 
employees, agents and other persons acting on its behalf.

Documents Requested

Plaintiffs request production of the following
documents:

1. All documents relating to West HELP.
2. All documents relating to the homeless in 

Westchester County.

2



3. All documents relating to Mayfair Knollwood, 
including (by way of example and not limitation) documents 
relating to:

(a) The proposed boundaries of Mayfair
Knollwood.

Knollwood.
(b) The petition to incorporate Mayfair

(c) The actual or estimated tax base of: (i)
Mayfair Knollwood; and (ii) that part of the Town of Green- 
burgh other than Mayfair Knollwood.

(d) The racial, economic, or ethnic composi­
tion of the residents of: (i) Mayfair Knollwood; and (ii) 
that part of the Town of Greenburgh other than Mayfair 
Knollwood.

(e) Meetings or hearings relating to: (i) 
Mayfair Knollwood; and (ii) West HELP.

4. All documents relating to:
(a) The formation of COUP.
(b) The purposes of COUP.
(c) The fundraising efforts of COUP.

3



5. All documents communicated to the press, or 
otherwise distributed publicly, relating, either to West HELP, 
Mayfair Knollwood, or COUP.

6. All documents relating to:
(a) Any discussion with any person, group or 

organization concerning inclusion of any area within, or 
exclusion of any area from, Mayfair Knollwood.

(b) Any alternative to West HELP with respect 
to homeless persons.

4



R
ev

is
ed

 
O

/ft
A

88 Civ. 7738 (GLG)
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK

YVONNE JONES, ET AL.
Plaintiffs,

v.
LAURENCE DEUTSCH, ET AL., 

Defendants.

NOTICE OF DEPOSITION

Paul, Weiss, Rifkind, Wharton & Garrison 

Attorneys for plaintiffs

1 2 8 5  A V EN U E O F  TH E A M ER IC A S •  NEW YO RK. N Y. 1 0 0 1 9  

( 2 1 2 )  3 7 3 - 3 0 0 0

All communications should be referred

Jay L. Himes, Esq.to