Wilson v. The Birmingham Public Library Foundation et al
NOTICE by Barbara Ann Wilson of Objection to Notice of Deposition (Morel, Adam)
2011 May-24 PM 01:56
U.S. DISTRICT COURT
N.D. OF ALABAMA
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ALABAMA
BARBARA ANN WILSON,
THE BIRMINGHAM PUBLIC
LIBRARY FOUNDATION; et al.,
PLAINTIFF’S OBJECTION TO NOTICE OF DEPOSITION
The Plaintiff objects to the Notice of Deposition served on her by the
Defendants as follows:
The Deposition Notice served on the Plaintiff includes the following
“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.
s/Adam P. Morel
Adam P. Morel
ATTORNEY FOR PLAINTIFF
LAW OFFICES OF ADAM MOREL, P.C.
517 Beacon Parkway West
Birmingham, AL 35209
Telephone: (205) 252-8841
Facsimile: (205) 252-3727
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
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?