Plaintiff's Motion to Quash Defendant's Depositions of Ehsan Nayebi - Motion (No Fee) Index # 40

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        NOW    COMES,      Ehsan Nayebi, hereinafter Plaintiff, in the above styled and numbered

cause, and files this Motion to Quash the Deposition of Ehsan Nayebi and Elham Etehadi and in




        Defendant Anih Christopher Chike Jr. unilaterally noticed the deposition of

August 9, 2023 for September 13, 2023            Ehsan Nayebis deposition     at 10:00 a.m. and

s deposition              2:00 p.m. Copies of Defendant Anih Christopher Chike Jr.’s Notice of

Intent to Take the Oral Deposition of Ehsan Nayebi and Elham Etehadi are attached hereto as




        WHEREFORE,         PREMISES       CONSIDERED,        Plaintiff respectfully requests that the

notices of deposition attached as Exhibit “A” hereto, be quashed by virtue of the timely filing of

this objection and for such other further relief, at law or in equity, to which Plaintiff may be justly




                                               AGE   OF
Respectfully submitted,

THE          LAW          PLL…