1 THE STATE OF NEW HAMPSHIRE HILLSBOROUGH SS SUPERIOR COURT NORTH Docket No. 216-2016-CV-00327 Sanjeev Lath v. Oak Brook Condominium Owners' Association, Board of Directors, Warren Mills, Vickie Grandmaison, Dorothy Vachon, and Scott Sample July 13, 2016 PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO QUASH AND PLAINTIFF’S PETITION FOR ENTRY OF ORDER ON DEPOSITION SCHEDULE NOWCOMES the Plaintiff, Sanjeev Lath in the matter and respectfully submits his opposition to the Motion to Quash the Eight Notices of Deposition served upon eight “nominal” witnesses. In support thereof, he states as follows: 1. The Defendants contend that Plaintiff is a disgruntled owner. Without expanding the reasons of filing several litigations, it is imperative for this Hon’ble Court to know that one of the Defendants in this instant action, Scott Sample, resorted to violence, and have assaulted the Plaintiff in the premises of Oak Brook condominium, since the filing of
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PLAINTIFF S OPPOSITION TO DEFENDANT S … various disputes, citing in many instances, including to Plaintiff’s roommate, his disagreement over the litigations. See Exhibit A. 2.
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1
THE STATE OF NEW HAMPSHIRE
HILLSBOROUGH SS SUPERIOR COURT NORTH
Docket No. 216-2016-CV-00327
Sanjeev Lath
v.
Oak Brook Condominium Owners' Association, Board of
---------- Forwarded message ----------From: >[email protected]<Date: Wed, Jun 22, 2016 at 12:11 PMSubject: Re: "Informational Meeting for Oakbrook"To: Jerry 1 <[email protected]>Cc: "Bisson, John" <[email protected]>
Good Morning, How are you?
The meeting was going to be an informational meeting with some of oak brook suits and on the changes that are taken effect, most of all Scott not working with us anymore and a little bit as to why he isn't here anymore. The board wanted to reassure every one that we do have a new maintenance manager who has just started with us on Monday. Our Attorneys name is John Bisson. He is there for any additional information that he would have spoke about at the meeting. I am forwarding this email to him. Thank you and have a nice day.
1. The first was dated June 1, 2016, as an invitation from "the Board of Directors" for us to attend the "informational meeting in regards to Oak Brook" that was scheduled to "take place at 1pm at the club house." on "June 25, 2016". The notice further stated "This meeting is very important. We want to reassure and keep all owners updated with any changes or occurrences here at Oak Brook."
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Questions. What are the "reassurance"(s) that were to be disclosed to the unit owners? What was the information that would "keep all owners updated with any changes or occurrences here at Oak Brook."?
2. The "short notice" of "having to cancel the Informational meeting that was going to take place on June 25th.." "and if anyone has any concerns or questions", "Zeny", "will then forward your email to our Attorney and he would be happy to reassure your concerns and answer your question."
Questions. Who is the Attorney that the emails are being forwarded to?Please lists the "reassurance"(es) of "concerns" and "questions" the Attorney would "be happy" to "answer" for "anyone"?Why was the "important meeting" information which was "to reassure and keep all owners updated with any changes or occurrences here at Oak Brook" not put in writing and mailed to all unit owners as should be rather than in secrecy?
Thank you for your anticipated co-operation in answering all these questions.Gerard Dufresne, 13 Northbrook Drive, Unit [email protected]
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Why? First, there was no recording, as I told you before, and second, why would your claim require an independent location. Saying so does not make it so.
The private room at the club house is for the convenience of the deponents, as most live right at the location, and therefore don’t have to travel, find parking, or otherwise be inconvenienced. As you and the others live there also, that seems to make the most sense.
Please forward the email to [email protected] as the ones I send don’t seem to reach him.
The following are available on 3/10/16. What time do we start, and how much time between each witness. Note Mr. Clavijo will require an interpreter that you will need to provide.
I will tell you that it has always been the practice in NH for the person taking the deposition to pay for the original plus one for the person deposed.
The location is a convenience to the deponents. In fact, as members of the association, and perhaps officers or directors, they probably have a right to sit in, but they don’t intend to.
There is a private room available at the site in the club house. Finally, I don’t know who Duffy is.
I understand that I pay for my copy and the steno but as far as I know if you need a copy you pay for it
I need the deposition at an independent location . Duffy provides conference room and i have booked it already. The club house is not a private place and other owners come by as it houses gym etc. Additionally I want the deponents independently deposed .
We can have a judge decide that if we have a disagreement
Depositions to take place at the club house at Oak Brook. I understand you are getting steno. I assume you are aware that you pay for an original transcript, plus one for me.
The [email protected] email address seems not to work. Please advise as to correct address.
The following are available on 3/10/16. What time do we start, and how much time between each witness. Note Mr. Clavijo will require an interpreter that you will need to provide.
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the
Page 4 of 5Gmail - RE: Lath et al v. Oak Brook---depositions
addressee(s). Please notify Sanjeev Lath at [email protected] if you are not the intended recipient and destroy all copies of this electronic message and any attachments.
Page 5 of 5Gmail - RE: Lath et al v. Oak Brook---depositions
This is going to take some time to arrange. I don’t have control over residents, only employees, officers, and directors. So to the extent that any below are not employees, officers or directors, you will need to issue subpoenas.
Also, I will need to find some time to arrange these. They will have to be taken over days, and not consecutive days.
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the addressee(s). Please notify Sanjeev Lath at [email protected] if you are not the intended recipient and destroy all copies of this electronic message and any attachments.
This is going to take some time to arrange. I don’t have control over residents, only employees, officers, and directors. So to the extent that any below are not employees, officers or directors, you will need to issue subpoenas.
Also, I will need to find some time to arrange these. They will have to be taken over days, and not consecutive days.
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the addressee(s). Please notify Sanjeev Lath at [email protected] if you are not the intended recipient and destroy all copies of this electronic message and any attachments.
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Sanjeev Lath
7 Northbrook Dr
Unit 710
Manchester NH 03102
6034614936
Statement of Confidentiality
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the addressee(s). Please notify Sanjeev Lath at [email protected] if you are not the intended recipient and destroy all copies of this electronic message and any attachments.
The information contained in this electronic message and any attachments to this message may contain confidential or attorneyclient privileged information and is intended for the exclusive use of the addressee(s). Please notify Sanjeev Lath at [email protected] if you are not the intended recipient and destroy all copies of this electronic message and any attachments.