Notices to Take Deposition Upon Oral Examination

     [||da9e7802-f7ea-4e99-8612-d8b94716bcfe||] IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

  

BERNICE TERRY, et al., 

Plaintiffs, 

VS. No. H. 76-3173 

METHODIST HOSPITAL OF GARY, INC., [2
] 

  

  

et al., 

Defendants 

RICHARD GORDON HATCHER, et al., : 

Plaintiffs, : 

VS. goes No. H 77-154 

METHODIST HOSPITAL OF GARY, INC., 

  

  

gst-al., 

Defendants 

NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION 

TO: Julian B. Allen Beth J. Lief 
Attorney for Plaintiffs Attorney for Plaintiffs 
2009 Broadway 10 Columbus Circle 

Gary, Indiana New York, New York 10019 

Plaintiff, Metro Corps of Gary, Inc., pursuant to the 

Federal Rules of Civil Procedure, Rules 30 and 30(b) (6), is 

requested to designate one or more officers, directors or managing 

agents, members, executive officers or other persons, duly 

authorized and consenting to testify on its behalf to testify 

 



  

as to matters known or available to said organization at 9:00 

A.M., on Wednesday, October 12, 1977, at the offices of Hodges, 

Davis, Gruenberg, Compton & Sayers, at 5525 Broadway, Gary, 

Indiana, concerning the following matters: 

1. Any allegations or information concerning purported 
violations of the civil rights or rights under the 
Rehabilitation Act of 1973 of its constituent members 
or any citizens of the City of Gary, Indiana, by defendant 
Methodist Hospital of Gary, Inc. or defendant Denis E. 
Ribordy. 

Any studies, reports, findings, or projections with 
regard to civil rights violations or violations of 
Section 504 in the delivery of health care services 
in the City of Gary, Indiana. 

Any studies, reports, findings or projections with 
regard to the optimal or preferable system for the 
delivery of health care services in Lake County, 
Indiana. Such studies, reports, findings or projec- 
tions may be those currently existing, those currently 
being developed, or those which have been developed 
in the past, whether implemented or not. 

Any programs operated by or contemplated by the plaintiff 
with regard to the transportation of minority, elderly 
or handicapped persons to hospitals or other medical 
facilities, whether said facilities are located within 
Lake County or the City of Gary, Indiana, or outside 
of Lake County, Indiana; or any other programs operated 
by or contemplated by the plaintiff which might in 
some way directly or indirectly affect the delivery 
of health care to the citizens of Gary, Indiana, 
and/or the citizens of Lake County, Indiana. 

The history, corporate status, corporate makeup, 
the purposes and the objectives of Metro Corps of 
Cary, Inc. 

The relationship between Metro Corps of Gary, Inc. 
and various governmental and quasi-governmental entities, 
and various entities outlined in Plaintiffs' Memorandum 
in Support of Certification of this action as a class 
action and the interrelationships, if any, with the 
organizations and entities enumerated therein by 
the plaintiffs. 

The financial status of Metro Corps of Gary, Inc. 
and the financial structure utilized by Metro Corps 
of Gary, Inc. 

 



  

Metro Corps of Gary, Inc. is further requested to designate 

in writing the individual or individuals who will appear and 

testify on behalf of Metro Corps of Gary, Inc. as to the matters 

specified above. If more than one individual is named, you 

are requested to identify each person and the matters on which 

they will testify. In the event more than one person is called, 

the other person's deposition will be taken at the conclusion 

of the previous person's deposition. Each deposition will 

be adjourned and continued from hour to hour and day to day 

until completed. Said deposition upon oral examination shall 

be taken by defendants, Methodist Hospital of Gary, Inc. and 

Denis E. Ribordy 

HODGES, DAVIS, GRUENBERG, COMPTON & SAYERS 
Attorneys for Defendant, Methodist 
Hospital of Gary, Inc. 

By: fig pl 
  

Bruce E. Sayefs 
5525 Broadwa, 
Gary, Indiana 46¢ 6 

Phone: 981-2557 

 



  

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

  

BERNICE TERRY, et al., 

Plaintiffs, 

No. HH. 76~-373 VS. 

METHODIST HOSPITAL OF GARY, INC., : 

  

  

et al., 

Defendants 

RICHARD GORDON HATCHER, et al., : 

Plaintiffs, : 

VS. : No. H 77-154 

METHODIST HOSPITAL OF GARY, INC., : 

  

  

et al., 

Defendants 

NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION 

PO: Julian B. Allen Beth J. Lief 
Attorney for Plaintiffs Attorney for Plaintiffs 
2009 Broadway 10 Columbus Circle 

Gary, Indiana New York, New York 10019 

Willie Lee Page 
eponent 

c/o Attorney Julian B. Allen 

2009 Broadway 
Gary, Indiana 

Please take notice that at 9:00 A.M., on Tuesday, October 11, 

1977, at the offices of Hodges, Davis, Gruenberg, Compton & 

Sayers, at 5525 Broadway, Gary, Indiana, The Methodist Hospital 

of Gary, Inc. and Denis E. Ribordy, defendants in the above- 

 



  

entitled action will take the deposition of Willie Lee Page, 

plaintiff in the above-entitled action, pursuant to the Federal 

Rules of Civil Procedure before some officer authorized by 

law to administer oaths. The oral examination will continue 

from day to day until completed. As attorneys for the plaintiffs, 

you are invited to attend and cross-examine. 

HODGES, DAVIS, GRUENBERG, COMPTON & SAYERS 

Attorneys for Defendant, Methodist 

Hospital of Gary, Inc. 
ae 

C7 et? 
By: 1S Eh as AAA AD { 
  

‘Bruce E. Sayers 
5525 Broadway 
Gary, Indiana 46410 
Phone: 931-2557 

 



    

  

  

  

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF INDIANA 

HAMMOND DIVISION 

BERNICE TERRY, et al., $ 

Plaintiffs, : 

VS. : No. H. 76-373 

METHODIST HOSPITAL OF GARY, INC., : 
at ak, 

Defendants 

RICHARD GORDON HATCHER, et al., : 

Plaintiffs, g 

VS. : No. H 77-154 

METHODIST HOSPITAL OF GARY, INC., : 

  

  

et al., 

Defendants 

NOTICE TO TAKE DEPOSITION UPON ORAL XAMINATION 

TO: ‘Julian B. Allen Beth J. Lief 

Attorney for Plaintiffs 
10 Columbus Circle 
New York, New York 

Attorney for Plaintiffs 
2009 Broadway 
Gary, Indiana 10019 

Richard Gordon Hatcher 

Deponent 
Municipal Building 
11 East 4th Avenue 
Gary, Indiana 

A.M., on Friday, October 7, 

of Gary, Inc. and Denis E. Ribordy, defendants 

Davis, Gruenberg, Compton & 

Indiana, The Methodist Hospital 

in the above- 

 



  

entitled action will take the deposition of Richard Gordon 

Hatcher, plaintiff in the above-entitled action, pursuant to 

the Federal Rules of Civil Procedure before some officer authorized 

by law to administer oaths. The oral examination will continue 

from day to day until completed. As attorneys for the plaintiffs, 

you are invited to attend and cross-examine. 

HODGES, DAVIS, GRUENBERG, COMPTON & SAYERS 
Attorneys for Defendant, Methodist 
Hospital of Gary, Inc. 

  

‘Bruce E. Sayers 
5525 Broadway 

  

Gary, Indiana 46410 
Phone: 981-2557 [||da9e7802-f7ea-4e99-8612-d8b94716bcfe||]