234-0 WT Motion for Protective Order

May 18th, 2023

Full docket text for document 234:
MOTION for Protective Order Pursuant to Fed. R. Civ. P 26(c). Jon A. Wilson appearing for Defendant Watchtower Bible and Tract Society of New York, Inc.. (Wilson, Jon)

“COMES NOW, Defendant Watchtower Bible and Tract Society of New York, Inc. (“WTNY”), by and through its counsel of record, and respectfully moves the Court for a protective order pursuant to Rule 26(c), Fed. R. Civ. P., to preclude the depositions of Messrs. Allen Shuster, Gary Breaux, and Marvin Gene Smalley. As more fully explained in the accompanying Brief in Support, these three men do not have unique knowledge regarding Plaintiffs’ purported deposition topics, two of them are high-level corporate officers whose depositions are subject to the apex doctrine, and Plaintiffs have failed to pursue less intrusive discovery, to include WTNY’ s duly identified alternative witnesses who are better suited to address Plaintiffs’ deposition topics.

The undersigned hereby certifies that WTNY’s counsel has attempted to meet-and-confer in good faith with Plaintiffs’ counsel in an attempt to resolve the subject matter of this motion, including an offer to depose three alternative witnesses better suited to testify about Plaintiffs’ purported topics. Plaintiffs’ counsel has served Notices of Deposition for above-named individuals, and WTNY understands Plaintiffs object to this motion.”