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1
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DEF PETITION 4 SUB
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EXTRACTED KEY WORDS
NORTH CAROLINA HOUPT PEDERSON DEFENDANT EXHIBIT HERETO CUSTODIAN ILLINOIS NORTH CAROLINA ACTION COURT RULE SUBPOENA ILLINOIS SUPREME COURT PURSUANT COOK COUNTY DEPOSITION REQUESTS CIRCUIT COURT COUNSEL RIDER WITNESS COMPLAINT CLERK PETITIONS PRICEWATERHOUSECOOPERS PENDING PROPOSED ORDER CONVENIENCE WHEREFORE RIDER THERETO |
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\ 525%
IN THE NAME OF THE PEOPLE OF THE STATE OF
*;3
IN THE CIRCUIT COURT OF COOK COUNTY,
BLUE RHINO CORPORATION, )
1
Plaintiff, 1 1 Case No.
V. 1 (For Case No. 99CVS 9706, pending
PRICEWATERHOUSE COOPERS, L.L.P. ) in the General Court
) Court Division, Fors
Defendant. ) North Carolina)
SUBFOEMA
DEFENDANT'S PETITION FOR THE
ISSUANCE OF A SUBPOENA FOR A CASE
PENDING IN A FOREIGN STATE PURSUANT TO
ILLINOIS SUPFWME COURT RULE 2041b)
Defendant, PriceWaterhouseCoopers, L.L.P., by and through its attorneys, Schiff
Hardin & Waite, hereby respectfully petitions this court, pursuant to Illinois Supreme Court Rule
204(b), to order the Clerk of the Circuit Court of Cook County to issue a Subpoena to the Custodian
of Records of Pederson & Houpt, P.C. In support of this Petition, Defendant states as follows:
1. Plaintiff has filed a Complaint in the General Court of Justice, Superior
Division, Forsyth County, North Carolina, entitled Blue Rhino COT. v. PriceWaterhouseCoopers,
..I
L L P Case No. 99 CVS 9706 (the "North Carolina Action"). A copy of the Complaint is attached
hereto as Exhibit A.
2. Defendant has answered Plaintiffs Complaint.
3. Defendant seeks to subpoena certain records and testimony from a material
witness in the North Carolina Action. That witness is the Custodian of Records of Pederson &
Houpt, P.C. The Custodian of Records of Pederson & Houpt, P.C. has material information
regarding the issues in dispute in the North Carolina Action. Pederson & Houpt, P.C. is located at
161 N. Clark Street, Suite 3 100, Chicago, Illinois 60601. Defendant will request in its subpoena
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2
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COMPLAINT
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EXTRACTED KEY WORDS
BLUE RHINO ACCOUNTING PLAINTIFF DEFENDANT BUSINESS SECONDARY OFFERING FILINGS CYLINDERS FINANCIAL STATEMENTS STOCK BISON VALVE ACCOUNTANTS CYLINDER EXCHANGE SERVICE MARKET REGISTRATION STATEMENT NORTH CAROLINA S-L REGISTRATION STATEMENT BISON VALVE LOAN BLUE RHINO CORPORATION PRICEWATERHOUSECOOPERS ACCOUNTING TREATMENT STOCK PRICE PROPANE GAS GRILL COMFORT LETTER ACCOUNTING FIRM PRINCIPALS REPRESENTATIVES UNDERWRITERS CONSOLIDATING |
NORTH CAROLINA ) :: : --: i `: IN THE GENERAL COURT
> SUPERIOR COURT
FORSYTH COUNTY :` :):.._I; - 7 j i : ;; 7 99 cvs
.J . .._
. 2.
>
BLUE RHINO CORPORATION, >
>
Plaintiff, > COMPLAINT
> (Jury Trial
V. >
>
PRICEWATERHOUSECOOPERS, L.L.P., )
>
Defendant. 1
Plaintiff, complaining of the defendant, alleges and says:
THE PARTIES
1.
Blue Rhino Corporation ("the Company" or "Blue Rhino") is a Delaware Corporation
having its principal office and place of business in Winston-Salem, North Carolina. The
Company is a public corporation, and at all times complained of herein, it was in the
providing propane gas grill cylinder exchange service to its customers.
2.
The defendant, PricewaterhouseCodpers, L.L.P. ("PwC," or "defendant"), is a limited
liability partnership registered in the State of North Carolina. The residence of
PricewaterhouseCoopers is the residence of each of its partners. One or more of
residents of the State of North Carolina, and therefore, PwC is a resident of the
Carolina. At all times complained of herein, PricewaterhouseCoopers was an auditing and
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