[ Home Page | Condensed Version | The Movie | The Book | News | Blogs | Feedback / Mail List ]

Act 59: Taubman Wants to Depose Me

On January 30, 2002, Taubman's lawyers finally let me know what "discovery" information they want from me.

Way back on November 13 of last year, the judge ordered us to complete the discovery phase of this process by no later than February 15 of this year. It took Taubman two-and-a-half months to figure out what they wanted to ask me, and they've given me one week to comply with their "requests." Federal rules require them to give me 30 days to comply – but they've stalled for so long that 30 days would take them well past the time that Judge Zatkoff gave them. Of course, this flouting of federal rules (and of the judge's order) poses no problem to Taubman's lawyers, who have consistently demanded that I follow the minutiae of all of the rules, while they blithely ignore those same rules themselves.

Anyway, they've decided to take my deposition, rather than having me respond to written questions. And the duces tecum ("bring with you") request in their cover letter indicates that they want me to round up some documents and bring them with me to the deposition next week.

Dear Mr. Mishkoff:

Enclosed please find a Notice of Deposition with accompanying duces tecum request, scheduling your testimony deposition for February 7, 2002.

If this date is not convenient, please contact me or Tammy Mayle from my office and we can reschedule.

Very truly yours,
Julie A. Greenberg

View the Original Letter (in a separate window)

Next: Notice of Deposition

[ Home Page | Condensed Version | The Movie | The Book | News | Blogs | Feedback / Mail List ]

©2002 Hank Mishkoff
All rights reserved.