Free Order on Motion for Protective Order - District Court of Connecticut - Connecticut

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1 . Case 3:03-cv-00316-JCH Document 96 Filed O3/22/2004 Page 1 of 1
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l UNITED STATES DISTRICT COURT F i L E D
y DISTRICT OF CONNECTICUT
l IGBHMARIS P hifi
1 JOHN J. CHAPMAN
I “sS·Séil’E'“iE3Hl&"
V. CASE No. 3;03Cxf51$(JdH)é g 1
i EXPERIAN INFORMATION SERVICES, INC. l
i CHASE MANHATTAN BANK USA, N.A. March 2, 2004 1
1 MOTION FOR PROTECTIVE ORDER
§ Pursuant to Fed. R, Civ. P. 26(C) and 30(d)(4), Plaintiff moves for a protective order
NN ` Mierminating or limiting the deposition of plaintiff on the basis that Chase conducted the
i § A deposition in bad faith, in such manner as unreasonably to annoy or oppress the deponent; and
1 ("Qn I both Chase and Experian expressly waived any further deposition questions. Chase persisted
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4 J _ I in asking legal questions rather than factual questions, asked argtunentatively, asked l
é ‘ wetitiously, asked deceptively, asked about matters indisputably not within the witness’s
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i knowledge, cut off the witness, persisted in smirking at the witness during questioning, and i
generally aimed at getting answers it wanted rather than gathering facts known to the witness i
not already revealed in the extensive written discovery (Chase has just served its Fourth H
Document demand). This case is largely based on the defendants’ own undisputed documents,
procedgresxand testimony.
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