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

Case 3:03-cv-00316-JCH

Document 91

Filed 03/15/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOHN J. CHAPMAN v. CASE NO. 3:03CV 316 (JCH)

EXPERIAN INFORMATION SERVICES, INC. CHASE MANHATTAN BANK USA, N.A.

March 2, 2004

MOTION FOR PROTECTIVE ORDER Pursuant to Fed. R. Civ. P. 26(c) and 30(d)(4), Plaintiff moves for a protective order terminating or limiting the deposition of plaintiff on the basis that Chase conducted the deposition in bad faith, in such manner as unreasonably to annoy or oppress the deponent; and both Chase and Experian expressly waived any further deposition questions. Chase persisted in asking legal questions rather than factual questions, asked argumentatively, asked repetitiously, asked deceptively, asked about matters indisputably not within the witness'knowledge, cut s off the witness, persisted in smirking at the witness during questioning, and generally aimed at getting answers it wanted rather than gathering facts known to the witness not already revealed in the extensive written discovery (Chase has just served its Fourth Document demand). This case is largely based on the defendants' own undisputed documents, procedures, and testimony. THE PLAINTIFF

BY___/s/ Joanne S. Faulkner____ JOANNE S. FAULKNER ct04137 123 Avon Street New Haven, CT 06511-2422 (203) 772-0395 1

Case 3:03-cv-00316-JCH

Document 91

Filed 03/15/2004

Page 2 of 3

This is to certify that the foregoing was mailed on March 1, 2004, postage prepaid, to: Thomas Stagg Simmons, Jannace & Stagg 90 Merrick Ave # 102 East Meadow NY 11554 Michelle Blum Jones Day 3 Park Plaza #1100 Irvine CA 92614-5976 ___/s/ Joanne S. Faulkner___ Joanne S. Faulkner

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Case 3:03-cv-00316-JCH

Document 91

Filed 03/15/2004

Page 3 of 3