Edward S. Rogers
President and Chief Executive Officer
Rogers Communications Inc.
333 Bloor Street East
Toronto, Ontario
M4W 1G9
Dear Mr. Rogers, June 9, 2006
As you may recollect, I initiated a Small Claims Court action (Susan G. Drummond v. Rogers Wireless Inc., SC-05-24949-00) against Rogers Wireless Inc in September of 2005. The case is set for trial on September 11, 2006. Yesterday, the judge denied my motion on the case to strike a particular paragraph from Rogers’ Statement of Defense – a motion that, if successful, would have largely precluded the necessity of you providing testimony.
As a consequence, I now need to summons you to testify at the September trial and, towards that end, have prepared a Summons to Witness, to be served personally on you, as per the Rules of Small Claims court.
My partner Harry Gefen suggested to me that you might appreciate the opportunity to make yourself available for service at a time and a place that maximizes your sense of privacy and minimizes any inadvertent disturbance of your daily affairs. Towards that end, please notify me, before June 15, 2006, where and when in the vicinity of Toronto, Ontario, before August 1, 2006, we can have an agent dispatched to serve you with the Summons.
Yours sincerely,
Professor Susan Drummond
June 19, 2006
To: Ms. Siobhan Hyland
[Personal Scheduling Secretary to Mr. Ted Rogers]
Rogers Communications Inc.
333 Bloor Street East
Toronto, Ontario
M4W 1G9
By: Hand / via Gabby, of Rapid Transit Systems Ltd. Courier
Dear Ms. Hyland,
My partner, Susan Drummond, couriered a letter to Mr. Edward S. “Ted” Rogers, on June 9, 2006, regarding a summons to witness in an upcoming Small Claims Court Action (copy attached). We thought that Mr. Rogers would prefer the opportunity to choose the date, time and place of service.
Susan left the country for her research, on June 14th, 2006, and asked me to follow up with you, given, as of today’s date, we’ve received no response from Mr. Rogers.
In your role as Mr. Rogers’ scheduling secretary, would you please be so good as to consult with him and get back to me in writing by Friday, June 23, 2006, with a date, time and place, on or before August 1, 2006, where Mr. Rogers can be properly served with the summons, somewhere in the vicinity of Toronto, Ontario.
Thank you for your assistance.
Sincerely,
Harry Gefen