Free Remark - District Court of Delaware - Delaware

Case 1:05-cv—00891-SLR Document 27 Filed 11/17/2006 Page1 of2
E—MaiI Request for Emergency Relief
1. Case Number: 05 -cv- 891 -SLR
2. Check the box that applies:
J Requesting a teleconference with the parties and the court
Requesting an in-person conference with the parties and the court
Requesting either of the above listed options at the court’s determination
3. BRIEFLY describe the reason for this emergency request:
Plaintiffs counsel has stated that plaintiff, who now lives in Florida, will only appear
by telephone for her deposition on Saturday, December 2 or a half day on Saturday,
December 9. Defendants object to the telephone deposition and have offered as an
accommodation to depose Plaintiff in person on December 2 in his office. Fact
discovery ends on December 29, 2006.
Plaintiff commenced this action in this jurisdiction and cannot complain about
traveling to Delaware. Defendants will be prejudiced by a telephone deposition
because plaintiff will be giving controversial testimony and they will be unable to
observe the impact of their deposition questions or plaintiffs nonverbal responses.
*Any text added beyond the limits of this space will be disregarded by the court.
4. Name of opposing counsel contacted about this request: John LaRosa
5. Response of opposing counsel to this request:
6. Name oflocal counsel making this request: Thad Bracegirdle
7. Today’s Date: November 15, 2006
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|;| A teleconference will be held on to be coordinated and
initiated by
III An in-person discovery conference will be held on:
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Case 1:05-cv—00891-SLR Document 27 Filed 11/17/2006 Page 2 of 2
E-Mail Request for Emergency Relief
1. Case Number: 05 -cv- 891 -SLR
2. Check the box that applies:
J Requesting a teleconference with the parties and the court
Requesting an in-person conference with the parties and the court
Requesting either of the above listed options at the court's determination
3. BRIEFLY describe the reason for this emergency request:
Plaintiffs counsel has stated that plaintiff, who now lives in Florida, will only appear
by telephone for her deposition on Saturday, December 2 or a halfday on Saturday,
December 9. Defendants object to the telephone deposition and have offered as an
accommodation to depose Plaintiff in person on December 2 in his office. Fact
discovery ends on December 29, 2006.
Plaintiff commenced this action in this jurisdiction and cannot complain about
traveling to Delaware. Defendants will be prejudiced by a telephone deposition
because plaintiff will be giving controversial testimony and they will be unable to
observe the impact of their deposition questions or plaintiffs nonverbal responses.
*Any text added beyond the limits of this space will be disregarded by the court.
4. Name of opposing counsel contacted about this request: John LaRosa
5. Response of opposing counsel to this request:
Plaintiff has moved for a Protective Order Under Rule 26(c) and opposes Defendants'
E-mail Request for Emergency Relief for the reasons set forth therein. (D.l. 25
attached).
6. Name of local counsel making this request: Thad Bracegirdle
7. Today’s Date; November 16, 2006
For court use only:
III A teleconference will be held on to be coordinated and
initiated by
III An in—person discovery conference will be held on:
I] Other: