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April
1, 2003
Sent
Via Facsimile and U.S.Mail
Jacquelyn
Finney
| RE:
|
Jacquelyn
Finney vs. California Department Of Managed Health Care,
et al. - Case No. GIN024734
Enforcement Matter No. 02-105 |
Dear
Mrs. Finney:
The
authority you cite, Nagle v. Superior Court, (1994) 28
Cal. App. 4th 1465 provides no support whatever for our request
to depose Maria Contreras-Sweet, and instead quite plainly holds
that the heads of agencies may not be deposed. Indeed, the court
of appeal granted a writ of mandate directing the trial court
to issue a protective order prohibiting the depositions from
taking place. No other authority supports your extraordinary
request. Accordingly, we will not agree to make the Secretary
available for deposition.
Please
be advised that should you attempt to notice her deposition,
we will seek a protective order and an order requiring you to
pay our attorneys fees for doing so.
Very
truly yours,
SIGNED
PATRICIA
STURDEVANT
Staff Counsel
PS:vb
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