Wilson v. The Birmingham Public Library Foundation et al

Filing 25

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

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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. ) ) ) ) ) ) ) ) ) ) ) 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: (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 OF COUNSEL

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