Bryan Pringle v. William Adams Jr et al

Filing 146

DECLARATION of Dean A. Dickie in opposition to EX PARTE APPLICATION for Protective Order for Postponing Depositions 141 and in support of Memorandum re Opposition to EX PARTE APPLICATION 144 filed by Plaintiff Bryan Pringle. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W)(Hampton, George)

From:
To:
Cc:

Subject:
Date:

Cenar, Kara
George Hampton
Mary Ann Hoyer; Pink, Jonathan Stuart; [e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail]; Colin Holley
Re: Pringle v. William Adams, Jr. et al.
Tuesday, March 22, 2011 3:44:20 PM

George,
Please forward a draft protective order governing confidentiality. As Plaintiff we look to you to provide a
draft or this proposed order.
As for deposition dates, we are willing to work with you to set up an appropriate schedule and location,
but unless the Notices are withdrawn or you indicate unequivocally an agreement to work out in good
faith mutually convenient dates and locations ( our clients may be out of the country on your arbitrarily
selected dates and I have a jury trial) we cannot interpret your actions as an indication to cooperate. 
Let us know. 
Please send the draft protective order, which will be required before any depositions can go forward,
and please provide your written agreement to agree to mutually agreed to dates and locations which
will accommodate schedules of counsel and witnesses work schedules and locations.
Thanks in advance for your cooperation.
Kara
On Mar 22, 2011, at 6:34 PM, George Hampton <[e-mail]> wrote:
> Counsel,
>
> The depositions will remain as noticed unless and until the parties agree to mutually agreeable
alternative dates.  Accordingly, I would appreciate it if you would provide me with proposed alternative
dates for the depositions.
>
> George
>
> -----Original Message----> From: Cenar, Kara [mailto:[e-mail]]
> Sent: Tuesday, March 22, 2011 5:40 AM
> To: Mary Ann Hoyer
> Cc: Pink, Jonathan Stuart; [e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]; [e-mail];
[e-mail]; Colin Holley; George Hampton
> Subject: Re: Pringle v. William Adams, Jr. et al.
>
> Counsel
>
> We will have to discuss alternative dates as the proposed dates conflict with pre set jury trials. I will
talk with my clients as well, but the dates will have to be on a different date for counsel's schedule.  I
reserve all other objections to the Notices as served.
>
>
>
> Kara
>

> On Mar 21, 2011, at 9:18 PM, "Mary Ann Hoyer" <[e-mail]> wrote:
>
>> Please see the attached correspondence and deposition notices.
>>
>> Mary Ann Hoyer
>> Office Manager
>> HamptonHolley LLP
>> 2101 East Coast Highway, Suite 260
>> Corona del Mar, CA 92625
>> [phone]
>> P Please consider the environment before printing this e-mail.
>>
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notify Mary Ann Hoyer immediately by e-mail, at
[e-mail]<mailto:[e-mail]>, and delete the original message.
>>
>> <2011.03.21GLH(Pringle).pdf>
>
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