Richard Anderson, Esq
Exhibit A to Motion for Protective Order
GERIATRIC MEDICAL GROUP
123 MIDDLEFIELD ROAD
SEASIDE, CA 95555
March 17, 2004
MEMO TO: Richard Anderson
FROM: YEE HONG, M.D.
RE: RUTH MARTIN
Ruth Martin has been my patient for the past 4 years. She is 92 years old, and currently suffering from diabetes and heart disease, chronic emphysema and anxiety.
She is not in any condition to be deposed, and I do not see that she ever will be. As I understand it, she could be required to answer written questions instead, which she should be able to do within a month or so if her condition continues to improve.
EXHIBIT A
Exhibit B to Motion for Protective Order
Richard Anderson, Esq.
Counselor at Law
THE LAW OFFICES OF RICHARD ANDERSON
999 The Heights, 35th Floor
Vista Del Mar, CA 95555
Tel:(555) 555-5555
Fax: (555) 555-5558
March 14, 2004
By Facsimile: 555-6789
Miller Simons, Esq.
The Simons Law Group
999 the Heights, Suite 301
Vista Del Mar, CA 95555
Re: Smart v. Martin
Dear Mr. Simons,
The purpose of this letter is to attempt to persuade you again to take the deposition of Ruth Martin off calendar until her health returns, and then to reschedule it as a deposition on written questions.
As you know, Ms. Martin is 92, and in poor health. Even as I write this letter my legal assistant is working with her doctor to obtain a declaration regarding her condition. It is Dr. Hong’s adamant position that she cannot be deposed at this time. Once her health returns, which may be in a few weeks, she could be deposed on written questions. Since even your pleadings show that you do not believe that she had any first hand knowledge about the premises, and that any source of fraud would be based on written documents she was given upon inheriting the property, I do not see how a deposition written questions would deprive you of any meaningful discovery.
If you agree to take the deposition on written questions, and later determine that it did not provide you with adequate discovery, we could address the issue again.
If you are not willing to take the deposing off calendar, and consider taking it on written questions, I will have no choice but to seek a protective order, and ask for sanctions against you.
Please contact me at your earliest opportunity to resolve this matter.
Sincerely,
Richard Anderson, Esq.
Counselor at Law
RA/llp\
EXHIBIT B
Exhibit C to Motion for Protective Order
Richard Anderson, Esq.
Counselor at Law
THE LAW OFFICES OF RICHARD ANDERSON
999 The Heights, 35th Floor
Vista Del Mar, CA 95555
Tel:(555) 555-5555
Fax: (555) 555-5558
March 15, 2004
By Facsimile: 555-6789
Miller Simons, Esq.
The Simons Law Group
999 the Heights, Suite 301
Vista Del Mar, CA 95555
Re: Smart v. Martin
Dear Mr. Simons,
This letter will confirm our telephone conversation of today. I had written you March 12, 2004 to ask that you take the deposition of Ruth Martin off calendar until her health returns, and then to reschedule it as a deposition on written questions.
You responded to my letter by telephone call today, and refused to take the deposition off calendar, or to consider taking it on written questions.
You leave me no choice but to seek a protective order, and ask for sanctions against you.
Please let me know if you change your mind.
Sincerely,
Richard Anderson, Esq.
Counselor at Law
RA/llp\
EXHIBIT C
................
................
In order to avoid copyright disputes, this page is only a partial summary.
To fulfill the demand for quickly locating and searching documents.
It is intelligent file search solution for home and business.
Related download
Related searches
- richard feynman biography
- richard feynman biography book
- richard feynman children
- richard rohr podcast
- richard rohr universal christ podcast
- richard rohr enneagram test free
- richard rohr homilies
- richard feynman
- richard rohr archives
- richard wells teaching license tennessee
- richard rumelt
- richard feynman method