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

, ,f__ _ Case 3:03-cv-00316-JCH Document 94 Filed 03/17/2004 Page 1 dtjféal 3/ T
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T UNITED STATES DISTRICT COURT F I L E D T
T DISTRICT OF CONNECTICUT I
T -Z|llll1MAR I0 I3 I=5I
T JOHN J. CHAPMAN
T U.S. DISTRICT COURT T
T §\\ »BRiDGEPORT» CON · _
§ v. CASE NO. 3:03CV 316 (JCH) T
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T R EXPERIAN INFORMATION SERVICES, INC. T
I CHASE MANHATTAN BANK USA, N.A. March 2, 2004
MOTION FOR PROTECTIVE ORDER
_ SEC Pursuant to Fed. R. Civ. P. 26(c) and 30(d)(4), Plaintiff moves for a protective order
T`} §t.erminating or limiting the deposition of plaintiff on the basis that Chase conducted the
g osition in bad faith, in such manner as unreasonably to annoy or oppress the deponent; and T
T oth Chase and Experian expressly waived any further deposition questions. Chase persisted T
i T T in asking legal questions rather than factual questions, asked argumentatively, asked T
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§ , _' epetitiously, asked deceptively, asked about matters indisputably not within the witness’s
Qwibggaj ggggff the witness, persisted in smirking at the witness during questioning, and
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` gnerzmy ainTeEat getting answers it wanted rather than gathering facts known to the witness
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it alr"`"`dy r’€i&led in the extensive written discovery (Chase has just served its Fourth
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lhicungrt d§r@1d). This case is largely based on the defenda.nts’ own undisputed documents, T
0% procedures, and testimony. I
THE PLAINTIFF
BY P§H1€n€{~
J OANNE S. FAULKNER ct04 l 37
123 Avon Street T
TQ New Haven, CT 06511-2422
(203) 772—0395
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