Wilson v. The Birmingham Public Library Foundation et al

Filing 25

NOTICE by Barbara Ann Wilson of Objection to Notice of Deposition (Morel, Adam)

FILED
2011 May-24 PM 01:56
U.S. DISTRICT COURT
N.D. OF ALABAMA

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ALABAMA
SOUTHERN DIVISION
BARBARA ANN WILSON,

Plaintiff,
v.
THE BIRMINGHAM PUBLIC
LIBRARY FOUNDATION; et al.,
Defendants.

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2:10-cv-02386-KOB

PLAINTIFF’S OBJECTION TO NOTICE OF DEPOSITION
The Plaintiff objects to the Notice of Deposition served on her by the
Defendants as follows:
1.

The Deposition Notice served on the Plaintiff includes the following
language:
“Deponent is requested to bring with her at that time, for examination
and/or copying, the following documents: Any and all records,
documents, photographs, statements, bills or other writing or things
you intend to use or rely on in the trial of this cause.”
The Plaintiff objects to this request as overbroad and vague and because it
seeks information she knows only through communication with her attorney
which is protected by the attorney-client privilege. She further objects
because it calls for information protected by the work-product doctrine. In

addition, the Plaintiff’s counsel, not the Plaintiff will make this
determination, a determination which has not been made at this time.
Respectfully submitted,
s/Adam P. Morel
Adam P. Morel
ATTORNEY FOR PLAINTIFF
OF COUNSEL:
LAW OFFICES OF ADAM MOREL, P.C.
517 Beacon Parkway West
Birmingham, AL 35209
Telephone: [phone]
Facsimile: [phone]

CERTIFICATE OF SERVICE

I hereby certify that a copy of the above has been served on all counsel of
record via electronic filing.

This the 24th day of May, 2011.

s/Adam P. Morel
OF COUNSEL