The proposed order looks acceptable, with the exception of Paragraph 13. Please remove this paragraph from the proposed order. At no time have Defendants ever refused to appear for deposition. In fact, we showed up and you cancelled them during the deposition. As such, it is completely inappropriate to have a discovery order compelling depositions when defendants have never refused to appear for depositions. Additionally, we would be agreeable to the extension of scheduling order dates in order to complete all discovery. Also, Defendants have no intention of refusing to appear for previously requested depositions after the discovery cut-off.
I look forward to hearing from you.
Patrick Sturdy
On 12/9/2011 1:00 PM, Nick Hadous wrote:
Gentlemen,Attached for your review is a Stipulated Order re: Plaintiffs' medical examinations and other discovery.I included a provision re: Defendants' remaining depositions as it appears these will be taken after the discovery cut-off date.Please let me know if this is acceptable and I will file accordingly.Cordially,Nick
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