Plaintiff served a Notice of Deposition for the PMK of GM in 25 categories. The deposition was set without any prior consultation with the Defendant. The Notice was also served shortly before the Covid stay at home measures, which still remain in effect. Plaintiff contends that she has an absolute right to proceed with the deposition on a remote basis and served an amended notice of deposition, again without consulting Defendant on the date. Defendant disagreed with that position and believes that it requires the agreement of both parties. The Defendant indicated in emails that it would be prejudiced in proceeding as their attorney could not be present in the same room as the PMK due to travel and social distancing requirements. The Defendant also objected to the overbreadth of the areas being requested for the PMK deposition. The emails attached to indicate that there had been a good faith effort to resolve this matter primarily involve a non- attorney employee, Josue Montoya, of the
Hearing Date
September 11, 2020
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Plaintiff served a Notice of Deposition for the PMK of GM in 25 categories. The deposition was set without any prior consultation with the Defendant. The Notice was also served shortly before the Covid stay at home measures, which still remain in effect. Plaintiff contends that she has an absolute right to proceed with the deposition on a remote basis and served an amended notice of deposition, again without consulting Defendant on the date. Defendant disagreed with that position and believes that it requires the agreement of both parties. The Defendant indicated in emails that it would be prejudiced in proceeding as their attorney could not be present in the same room as the PMK due to travel and social distancing requirements. The Defendant also objected to the overbreadth of the areas being requested for the PMK deposition. The emails attached to indicate that there had been a good faith effort to resolve this matter primarily involve a non- attorney employee, Josue Montoya, of the