Saudi
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SUBMITTED IN CHAMBERS WITHOUT REDACTIONS AND FILED ELECTRONICALLY WITH REDACTIONS
promised dates "by the end of the day" No dates were offered at that time. On the following day, Huntsman's counsel, Kathy Patrick, called the Banks' counsel, David Sterling, to discuss Jon Huntsman's deposition. Ms. Patrick reported that Mr. Huntsman was "waiting on a call" from the king of Saudi Arabia and from another head of state in the Middle East to arrange for a business trip for the week of either February 9 or February 16. She offered the Banks dates for Mr. Huntsman during the week of February 23. Mr. Sterling suggested that they could make plans to depose Mr. Huntsman on February 9 and 10, and if it turned out that he was not available then, the deposition could be reset to February 16 and 17. Ms. Patrick said that this arrangement would not work because Ms. Patrick would be unavailable on February 9 and 10. Mr. Sterling then suggested that the Banks could notice Mr. Huntsman for February 16 and 17, and if it turned out that Mr. Huntsman was abroad that week, the deposition could be rescheduled for February 23 and 24. Ms. Patrick said she would consider that approach. On February 9, Huntsman's counsel presented yet another reason for not presenting Mr. Huntsman: his health. Ms. Patrick informed Mr. Sterling that evening that Mr. Huntsman suffers from a variety of health issues which would prevent Mr. Huntsman from giving any testimony on the merits during the week of February 23, notwithstanding the fact that he has no travel conflicts that week. According to Ms. Patrick, all Mr. Huntsman's health would allow that week was a deposition limited to settlement (not merits) issues on February 24 beginning at 10 a.m. and concluding by 4 p.m. Tn a letter the next day, Mr. Sterling noted that the Banks would finish questioning Mr. Huntsman on settlement issues during the limited hours Ms. Patrick offered on February 24, and that the Banks would then proceed to questions on the merits on that same day within the hours allotted by Huntsman.
HOUJ2: 11 ()2303.6
Mr. Sterling offered in the letter to complete Mr. Huntsman's
-4-
promised dates "by the end of the day" No dates were offered at that time. On the following day, Huntsman's counsel, Kathy Patrick, called the Banks' counsel, David Sterling, to discuss Jon Huntsman's deposition. Ms. Patrick reported that Mr. Huntsman was "waiting on a call" from the king of Saudi Arabia and from another head of state in the Middle East to arrange for a business trip for the week of either February 9 or February 16. She offered the Banks dates for Mr. Huntsman during the week of February 23. Mr. Sterling suggested that they could make plans to depose Mr. Huntsman on February 9 and 10, and if it turned out that he was not available then, the deposition could be reset to February 16 and 17. Ms. Patrick said that this arrangement would not work because Ms. Patrick would be unavailable on February 9 and 10. Mr. Sterling then suggested that the Banks could notice Mr. Huntsman for February 16 and 17, and if it turned out that Mr. Huntsman was abroad that week, the deposition could be rescheduled for February 23 and 24. Ms. Patrick said she would consider that approach. On February 9, Huntsman's counsel presented yet another reason for not presenting Mr. Huntsman: his health. Ms. Patrick informed Mr. Sterling that evening that Mr. Huntsman suffers from a variety of health issues which would prevent Mr. Huntsman from giving any testimony on the merits during the week of February 23, notwithstanding the fact that he has no travel conflicts that week. According to Ms. Patrick, all Mr. Huntsman's health would allow that week was a deposition limited to settlement (not merits) issues on February 24 beginning at 10 a.m. and concluding by 4 p.m. Tn a letter the next day, Mr. Sterling noted that the Banks would finish questioning Mr. Huntsman on settlement issues during the limited hours Ms. Patrick offered on February 24, and that the Banks would then proceed to questions on the merits on that same day within the hours allotted by Huntsman.
HOUJ2: 11 ()2303.6
Mr. Sterling offered in the letter to complete Mr. Huntsman's
-4-
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