FILED

DALLAS COUNTY
12/23/2014 12:49:55 PM
GARY FITZSIMMONS
DISTRICT CLERK

Freeney Anita

DC-14-14855
CAUSE NO.

IN RE: REX RAMSEY

IN THE DISTRICT COURT

NICHOLS,

Petitioner.

JUDICIAL DISTRICT

DALLAS COUNTY, TEXAS

PETITIONER REX RAMSEY NICHOL'S VERIFIED PETITION TO TAKE
DEPOSITION BEFORE SUIT

Petitioner, Rex Ramsey Nichols ("Nichols" or "Petitioner"), asks the Court for
permission to take depositions by oral examination to obtain testimony in an anticipated
suit, and for production of documents, as allowed as allowed by Texas Rule of Civil
Procedure 202.

I.

INTRODUCTION

1. Petitioner Rex Ramsey Nichols is an individual residing in Dallas, Texas,

who may be contacted through his attorneys, Blake Beckham and Jose Portela, The
Beckham Group, 3400 Carlisle, Suite 550, Dallas, Texas 75204. The last four digits of
Plaintiffs social security number are 1576 and the last four digits of his Texas driver's
license are 0746.

2. The individuals sought to be deposed are as follows:

a. Toni Brinker Pickens ("Toni"), an individual owner of the property

in question. Toni's contact information is her residential address
of 10235 Strait Lane, Dallas, Texas 75229;

b. Thomas Boone Pickens, Jr. ("T. Boone"), an individual and spouse

of Toni Brinker Pickens, and a participant in the transactions made
the basis of this litigation. T. Boone's contact information and

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE 1

location of service is his business address, BP Capital, 8117

Preston Rd., #260, Dallas, Texas 75225;

c. Allie Beth Allman ("Allman"), an individual and owner of Allie

Beth Allman & Associates. Allman's contact information and

location of service is her business address of 5015 Tracy Street,

Dallas, Texas 75205.

II.

FACTS

3. Sadly, this is a matter involving attempted manipulation and price-gouging

by a family who is not afraid to make false representations to add to its considerable
fortune.

4. Rex Ramsey Nichols ("Nichols") lost his wife, Margaret, to cancer

following a lengthy and debilitating decline, and could no longer live in the same home
that his family had shared - the memories were too painful. After taking life a day at a
time following Mrs. Nichols' passing, the family decided it was time to move. Nichols'
daughter successfully signed up for a spot on the basketball team at Cambridge School in
Dallas. Nichols' son attends Providence School, also in Dallas. It was also time to find a

home much closer to school, so that instead of waking up at 4:30am for pre-school
practice, the family could wake up at 5:45am.
5. After scouring MLS listings for nearly eight months looking for a home to
lease, Nichols ran across MLS listing 13034379, an offer to Lease a 10,930 square foot
home, in Dallas which was available for a one-year lease. The MLS listing even
highlights the unique nature of the home:
A fabulous Neiman Marcus Show house located on over an acre comer lot

on one of Dallas most prestigious streets.

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

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6. Not only is the home a lease house on Strait Lane (tmly one of the most
prestigious streets in Dallas), but it also has a very expensive 8 foot privacy fence with
electric gates, not to mention an incredible yard on over a one acre lot, two of many
specialized criteria that Nichols had (which this house met).
7. After seeing the home on or about November 1, 2014, Nichols
unequivocally told his agent, Robert "Bob" Heath ("Heath") that he agreed to lease this

home on the offered tenns. Based on the conversations between Heath (who represented
the lessee in the transaction) and Mary Beth Allman ("Allman") (the listing agent who
represented the lessor in the transaction), Nichols was told by Allman that everything was
"good to go."

8. On November 3, 2014, Nichols submitted his signed credit application

along with a $35.00 fee to qualify his credit, and he was told it came back "approved."
9. Relying on the agreed lease and approval, Nichols helped cancel his
father's lease at his father's home, with the plan of his Dad moving into Nichols' soon-to-

be-former home. Nichols also announced the new home to the children and after many
tears, they were ready and excited to move.
10. Days later, Nichols received the first Residential Lease from Toni,

reflecting the offered and agreed rent in the amount of $12,000 per month. Nichols
signed and returned the lease, and provided the requested two months' rent, as well.
Then, the problems unfortunately began.
11. On November 5, Nichols received a voicemail from Allman stating that
Toni Pickens had "changed her mind" and sought to cancel the agreement to lease. Ms.
Allman stated that based on the elections and discussions with Mr. Pickens, Toni now

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

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really wanted to sell the home instead of leasing it. T. Boone was also alleged to be
involved in the lease vs. sale scheme. Nichols returned the call to Allman and much to

his dismay, he was told the Pickens still might be willing to lease the property and Mr.
Nichols was asked "would you pay $20,000 a month instead?" Suddenly, once a buyer
became interested, the fleecing scheme was put in action. Mr. Nichols refused to pay the
increased amount declaring "that's not right - we had a deal." Mr. Nichols expressed his
fhistration and concern over being stranded without a home.
12. Then Toni instmcted Allman to try to sell the home to Nichols while they
had him over a barrel. The house had previously been listed for sale then pulled off the
market when it didn't sell. For Allman and the Pickens - there was a chance to leverage
Nichols into buying the home using the one year lease as leverage. The parties began
negotiations on a purchase of the home, subject to Nichols' ability to lease the home for a

little less than one year so that the closing would occur late 2015.
13. One sales contract after another was sent to Nichols, with the lease

agreement kept separated. Nichols paid the option fee and jumped through every hoop
requested of him. Toni wanted the move-in day shifted from December 1, 2014 to
December 15, 2014 since the movers she has used for many years could not be available
on December 15. Then, the move-in date changed yet again, allegedly so that Toni could
claim her homestead exemption again.
14. Toni then required a large sum of money (approximately $250,000) be set
aside as default damages in advance of the purchase, which then lowered the purchase
price of the house. Nichols complied with this request, as well.

VEMFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

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15. Nichols hired an inspector for home on Strait Lane and paid for the
inspection himself. Toni now requested a list of references from Nichols, another new
condition with which Nichols complied.
16. Then, Toni was concerned because Nichols had been a named party in a
lawsuit. After speaking with Nichols and his attorney regarding the lawsuit, Toni was
apparently comforted to learn that Nichols was a victorious Plaintiff in the lawsuit (in his
capacity as a representative of the estate of a deceased physician and business partner).
17. The final terms of the purchase agreement were done and during a meeting
on or about December 1, 2014, with Nichols, Heath, and Allman at the home on Strait

Lane (which was supposed to serve as a "final walkthrough before occupancy"), Toni's
bizarre behavior continued. She kept offering to separately sell Nichols various fixtures
in the home - this was of course an oddity since fixtures are traditionally included in
home sales and leases, even when the sale price is not in excess of $5 million, as it was
here.

18. At the same time, Nichols had purchased approximately $75,000 in

furniture for the new home, given the fact that it was an increase in square footage, thus
necessitating additional furnishings. That furniture currently sits in storage, collecting
dust.

19. Then, after being presented with one contract upon another upon another,
the truth was finally revealed to Nichols. The Pickens family simply wants more money
now, and Toni has once again changed her mind on selling the home, even though
Nichols jumped through every hoop requested of him. Even though the home was listed
as a lease product on MLS, Toni never intended to lease the home.

VEMFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGES

20. The Court only has to look at the lawsuit history of the Pickens family in
2013 and 2014 to learn the precise nature of the people that Nichols was involving with
in this transaction and their view on the meaning of contracts and fulfilling legal
commitments. In 2013, T. Boone sued his son, Michael, trying to shut down Michael's
blog which revealed numerous alleged wrongdoings and family secrets. Then, Michael
sued his father in November 2014, alleging that his father failed to live up to his end of a
promised position within one of T. Boone's many companies. It appears the Nichols
family is now an unsuspecting victim of the hurtfiil Pickens family drama.
21. Petitioner is left with no alternative but to seek testimony from Toni, T.
Boone, and Allman, in order to learn details surrounding the above-described scheme,
Toni s true intention, the role that T. Boone and Allman played in the scheme, the precise
communications made among the participants in this scheme, and the scienter related to
the falsify of the various representations.
III. REQUEST FOR DEPOSITIONS

22. In order to investigate this potential claims against Toni, T. Boone, and
Allman to recover the funds incurred as well as for potential specific perfonnance of the
contracts, Petitioner requires the depositions of Toni, T. Boone, and Allman. This Court
has authority under Rule 202 of the Texas Rules of Civil Procedure to authorize this

deposition to investigate Petitioners' anticipated claim.

23. The following are the names, addresses, and telqihone numbers of the
following persons and/or entities that may have an interest adverse to Petitioners' in the
anticipated suit:
a. Toni Brinker Pickens ("Toni"), an individual owner of the
property in question. Toni's contact information is her
VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT PAGE 6

residential address of 10235 Strait Lane, Dallas, Texas

75229;
b. Thomas Boone Pickens, Jr. ("T. Boone"), an individual and

spouse of Toni Brinker Pickens, and a participant in the

transactions made the basis of this litigation. T. Boone's
contact infonnation and location of service is his business

address, BP Capital, 8117 Preston Rd., #260, Dallas, Texas

75225;
c. Allie Beth Allman ("Allman"), an individual and owner of
Allie Beth Allman & Associates. AIlman's contact
information and location of service is her business address

of 5015 Tracy Street, Dallas, Texas 75205.

24. This Petition is filed in Dallas County, Texas, where venue of the

anticipated suit will lie. Not only is the property in question located in Dallas County,
but a substantial portion of the communications and drafting of the contracts in question
(a substantial part of the events giving rise to this litigation) occurred in Dallas County,
Texas.

25. Petitioners ask the Court to issue an Order authorizing Petitioner to

examine the requested individuals by oral deposition, which may also be recorded by
video and by instant visual display of the testimony.
26. Petitioners request that the court order Toni, T. Boone, and Allman to

produce the following documents at the deposition: See Exhibit A.

27. After service of this Petition and notice, Rule 202.3(a) requires the court to
hold a hearing on the Petition.
IV. PRAYER
28. For the reasons stated, Petitioners ask the Court to set this Petition for

hearing and, after the hearing, order the deposition of Toni Brinker Pickens, Thomas

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE?

Boone Pickens, Jr., and Allie Beth Allman, and for the production of documents as
requested herein.

DATED: December 23, 2014.

Respectfully submitted,

/^. Blake L. Beckham

blake(5>.beckham-group.com

State Bar No. 02016500

Jose M. Portela
iosefaibeckham-group.com

State Bar No. 90001241

THE BECKHAM GROUP, P.C.

3400 Carlisle, Suite 500

Dallas, Texas 75204

Telephone: 214-965-9300
Facsimile: 214-965-9301
A TTORNEYS FOR PETITIONER

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGES

CERTIFICATE OF SERVICE

I hereby certify that on December 23, 2014 that a tme and correct copy of this
document was served on the following parties as indicated below.
VIA CMRRR

a. Toni Brinker Pickens

1023 5 Strait Lane,

Dallas, Texas 75229;
VIA CMRRR

b. Thomas Boone Pickens, Jr.

BP Capital, 8117 Preston Rd., #260,

Dallas, Texas 75225;
VIA CMRRR

c. Allie Beth Allman

5015 Tracy Street,

Dallas, Texas 75205.

2^.Blake L. Beckham

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE 9

VERIFICATION

STATE OF TEXAS,

COUNTY OF [)'i{l"?
Before me, the undersigned Notary Public, on this day personally appeared Rex Ramsey
Nichols, who, after being duly sworn, stated under oath that he has read the above

Petition: and that every statement contained in Paragraphs 4-19 therein is within his
persona] knowledge and is true and correct.

Ramsey WicTioIs

SUBSCRIBED AND SWORN TO BEFORE ME on the 2^ day of December, 2014.

*.*..>^Attt^Mta*tM

^ JIMMY BARKER

My Commission Expires
December 11. 2015

.-^

^\^^-

1C
Notary Public in/nd for the State
of Texas

My commission expires

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE 10

EXHIBIT "A"
DOCUMENTS TO BE PRODUCED

Petitioner requests that Toni Brinker Pickens ("Toni"), Thomas Boons Pickens, Jr. ("T.
Boone"), and Allie Beth Allman ("Allman") produce the documents and things described
in the Requests below that are in their possession, custody, or control, and that Defendant
answer the Requests for Production pursuant to the Rule 202 Petition filed. The
requested documents are to be produced or made available for inspection and copying at
the offices of THE BECKHAM GROUP, 3400 Carlisle Street, Suite 550, Dallas, Texas 75204
on or before the date of the ordered depositions. Documents shall be organized and
labeled to correspond with the categories in these Requests.
INSTRUCTIONS REGARDING PRODUCTION OF DOCUMENTS

1. All Documents: These Requests require you to produce all responsive

documents that are in your actual or constructive possession, custody, or
control. This includes constructive possession whereby you have the right to
compel production of the document from a third party, including any agent,
employer, partner, attorney, accountant or other representative. You or your
agents and representatives will be permitted to furnish copies of the subject matter
of these requests as is deemed necessary, in lieu of furnishing originals for
examination or copying. Respondents may elect to furnish clear and readable

color copies of the subject matter of this request where the document contains
several colors, or black and white copies where the documents are only black and
white.

2. Request to be Deemed Continuous: This request for production shall be deemed

to seek documents in your possession, custody or control as of the date hereof,
and shall be deemed to be continuing, so that if at any time after compliance with
this request you acquire possession, custody or control of any additional
documents within the scope of the request, you must furnish such documents to
THE BECKHAM GROUP within ten (10) days of their receipt.
3. Documents to be Identified: All documents shall be labeled to correspond to the
numbers in the requests. In addition, all associated file labels, file headings, and
file folders shall be produced together with the responsive documents from each
file, and each file shall be identified as to its owner or custodian. All documents

that cannot be legibly copied shall be produced in their original form; otherwise,
you may produce photocopies. Each page shall be given a discrete
production number with an identifier of the producing entity.
4. Documents Withheld: If any document is withheld under claim of privilege other
than the attorney client doctrine, furnish a list of such documents and provide:
a. that infonTiation or material responsive to the request has been
withheld.

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE 11

b. the request to which the infonTiation or material relates,

c. the privilege or privileges asserted;
d. the title of the document;

e. the date of the document, or, if not available, its approximate date;
f. the kind of document (e.g., letter, telex, memorandum, etc.);
g. the author(s) of the document;

h. any person(s) who participated in the preparation of the document;

i. the addressee(s) of the document;
j. any other recipient(s) of the document;
k. the number of pages in the document;
1. the present custodian of the document;
m. the present location of the document;
n.

a statement of the general subject matter of the document; and

0.

a statement of the facts that constitute the basis for withholding the
document, in sufficient detail to permit the Courts to adjudicate the
validity of the claim.

5. Entire Documents: For each document requested, produce the entire document,

including all attachments, appendices, and exhibits.

6. Copies of Documents: All non-identical copies of a document are to be
produced.

7. Objections: If you object to any Request or part thereof, you are to identify the
legal nature and extent of your objection and produce all documents to which
your legal objection does not apply.
8. Ambiguity: If in answering these Requests you claim any ambiguity in either the
Request or a definition or instruction applicable thereto, identify in your response
the language you consider ambiguous and state the inteqiretation you are using in
responding.

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE 12

9. Documents No Longer in Possession: If you or your attorneys know of the

existence, past or present, of any document described in a Request, but such

document is not presently in the possession, custody, or control of you or your

agents, representatives, or attorneys, you shall so state in response to the Request,
identify such document in response to the Request, and identify the

individual in whose possession, custody, or control the document was last

kiiown to reside. If such document no longer exists, state when, how, and why
such document ceased to exist. For any requested document that has been
destroyed after the commencement of this suit, you shall identify each document,

set forth the contents of each destroyed document, the date of such destruction,
the identity of any individuals who authorized the destruction, and other
circumstances related to such destruction.

10. Time Period: Unless otherwise specified in the Request, the time period
covered by these Requests is from January 1, 2004 to the current date.
GENERAL DEFINITIONS APPLICABLE TO THESE REQUESTS

1. "Toni" shall refer to Toni Brinker Pickens;

2. "T. Boone" shall refer to Thomas Boone Pickens, Jr.;

3. "Allman" shall refer to Allie Beth Allman;

4. "Heath" shall refer to Robert "Bob" Heath;
5. Petitioner" or Nichols shall refer to Rex Ramsey Nichols as well as any related
persons or entities, and any agent, employee, attorney, or other person acting on
his behalf.

6. "Property in Question" shall refer to 10235 Strait Lane, Dallas, Texas 75229.
7. "Document" and "documents" shall be construed in a broad sense and means,
without limitation, any writing or record of any type or description, whether
printed or recorded (mechanically or electrically), or reproduced by hand,
including, any letters, correspondence, electronic mail (which shall be produced

in its native fonnat), deleted electronic mail (which shall be produced in its native
fonnat), telegrams, memoranda, notes, records, reports, financial statements,
statistical and financial records, minutes, memoranda, notices or notes of

meetings, telephone or personal conversations or conferences, envelopes, intracompany communications, microfilm, tape recordings, videotapes, photographs,

bulletins, studies, plans, analyses, notes, computer runs, programs or software,

and any codes necessary to comprehend such runs, programs or software, books,
pamphlets, illustrations, lists, forecasts, brochures, periodicals, charts, graphs,
indices, bills, statements files, agreements, contracts, sub-contracts, completed

VEWFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE 13

foniis, schedules, work sheets, computer screen-shots, data compilations, policies,

amendments to policies or contracts, calendars, diaries, test results, reports and
notebooks, opinions or reports of consultants, and any other written, printed,
typed, recorded or graphic matter, of any nature, however produced or
reproduced, including copies and drafts of such documents, and any and all
handwritten notes or notations in whatever form.

"Documents" shall specifically include electronic information, papers, books,

accounts, drawings, graphs, charts, photographs, electronic or videotape records,
and any other data compilations from which information can be obtained. By way
of illustration and not limitation, the tenn "Documents" includes any financial
statements, bills, invoices, correspondence, meeting minutes, internal audit

reports, expense reimbursements forms, expense receipts, memoranda, interoffice

comiiiunications, notations of conversations, notations of telephone calls,

notations of meetings, personal notes, other notes, diaries, desk files, calendars,
file folders, files, letters, contracts, reports, studies, checks, cancelled checks,
check drafts, bank statements, painphlets, books, appraisals, printed matters,

computer printouts, invoices, work sheets, delivery and mail receipts.

"Electronic information" means all digital or analog electronic files, including
"deleted" files and file fragments, stored in machine-readable format on magnetic,
optical, or other storage media, including the hard drives or floppy disks used by
RML's computers and their backup media (e.g., other hard drives, backup tapes,
floppies, CD-ROMs) or otherwise, whether such files have been reduced to paper
printouts or not. By way of illustration and not limitation, "Electronic
Information" includes emails, both sent and received, whether internally or

externally; all word-processed files, including drafts and revisions, all

spreadsheets, including drafts and revisions, all databases, all presentation data or
slide shows produced by presentation software (such as Microsoft Powerpoint);
all graphs, charts, and other data produced by project management software (such
as Microsoft Project); all data generated by calendaring, task management, and
personal information management software (such as Microsoft Outlook or Lotus
Notes); all data created with use of personal data assistants (PDAs), such as Palallot, HP Jomada, Cassiopeia, or other Windows CE-based or Pocket PC devices;
all data created with the use of document management software; all data and

created with the use of paper and electronic mail logging and routing software; all
Internet and Web-browser-generated history files, caches, and "cookies" files
generated at the workstation of each employee and/or agent in Defendant's
employ and on any and all backup storage media; and any and all other files and
metadata generated by users through the use of computers and/or
telecommunications, including but not limited to voicemail.
9.

"Metadata" means that electronic bibliographic information that is recorded and

embedded into most Microsoft-compatible electronic file formats. Metadata is

data about the content, quality, condition, and other characteristics of data files.

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE 14

10. Communication(s)" shall mean and include all discussions, conversations,

interviews, negotiation, cablegrams, mailgrams, telegrams, telexes, cables, emails, deleted e-mails, electronic interactions, or other forms of written or verbal

interchange, however transmitted, including reports, notes, memoranda, lists,

agenda, and other documents and records of communication. "Communication(s)"
shall include all correspondence, letters, e-mail, memoranda, facsimile cover
sheets, notes, or personal or telephone conferences or communications, and any
document that in any way relates to such items.

11. The terms "evidencing," "reflecting," "showing" or "mentioning" mean, in

addition to their customary and usual meaning, pertain or pertaining, allude or
alluding, concern or concerning, connect or connected with, contain or containing,
dealing with, in respect of, in respect to, about, regard or regarding, discuss or
discussing, measure or measuring, support or supporting, embody or embodying,
identify or identifying, analyze or analyzing, explain or explaining, constitute or
constituting, refer or referring, reflect or reflecting, assess or assessing, record or
recording, and comment or commenting.
12. The term "including" shall mean "including but not limited to."
13. The singular includes the plural and the plural includes the singular where
appropriate to the sense of this request.

14. "Any" and "all" means "each and every" as well as "any one."
15. Person means the plural as well as the singular and includes natural persons,
corporations, firms, associations, partnerships, joint venturers or any other fonn of
business entity, and govenimental agencies, departments, units or any subdivision
thereof.

16. Date" means the exact day, month and year, if ascertainable, or if not, the best
approximation (including chronological relationship to other events).
17. "Or" means "and/or."

REQUESTS FOR PRODUCTION

REQUEST NO. 1: Any and all communications (including electronic data whether or
not deleted) among Allman, Heath, Toni, T. Boone, or Nichols related to the Property in
Question.
RESPONSE:

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE 15

REQUEST NO. 2: Any and all proposed Lease Contracts or Sales Contracts with
Nichols related to the Property in Question.
RESPONSE:

REQUEST NO. 3: The complete file of Allie Beth Allman & Associates related to
10235 Strait Lane, Dallas, Texas 75229.
RESPONSE:

REQUEST NO. 4: Any and all cominumcations or contracts between Toni, T. Boone,
or Allman with any other potential buyer or lessee of the Property in Question.
RESPONSE:

REQUEST NO. 5: Any and all contracts or agreements between Toni or T. Boone (or
anyone on their behalf) and Allman or Allie Beth Allman & Associates.
RESPONSE:

REQUEST N0.6: Any and all documents and information supplied the Multi Listing
Service related to the Property in Question.
RESPONSE:

REQUEST NO. 7: Copies of any and all payments made by Nichols to Toni, T. Boone,
or Allman, related to the Property in Question.
RESPONSE:

REQUEST NO. 8: Copies of tax records showing the Property in Question as being the
homestead ofToni or T. Boone.
RESPONSE:

REQUEST NO. 9: Any correspondence between Toni, T. Boone, or Allman and any
potential title company which might be utilized to close the transaction.
RESPONSE:

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

PAGE 16

REQUEST NO. 10: Any invoices, cancelled checks, or wire transfer confinnations

which reflect any monies paid by Toni, T. Boone, or Allman with regard to the potential
lease or sale of the Property in Question.
RESPONSE:

REQUEST NO. 11: Any invoices, cancelled checks, or wire transfer confirmations

which reflect any monies paid by Toni or T. Boone to Allman with regard to the potential
lease or sale of the Property in Question.
RESPONSE:

REQUEST NO. 12: Copy of the complete files ofAllman or Allie Beth Allman &
Associates related to any other transactions involving Allman and Toni or T. Boone
RESPONSE:

REQUEST NO. 13: Documents supporting any contention by Toni, T. Boone, or

Allman that Nichols was not qualified as a lessee or purchaser of the home.
RESPONSE:

VERIFIED PETITION TO TAKE DEPOSITION BEFORE SUIT

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