Jablonski v. Special Counsel, Inc.

Filing 192

ORDER: The Court has reviewed ECF 182, along with Plaintiff's objections to Defendant's proposed 30(b)(6) topic modifications and objections. Defendant's motion to modify and/or object to Plaintiff's proposed 30(b)(6) topics is GRANTED in part and DENIED in part. The parties are directed to refer to the attached annotated version of Plaintiff's List of Proposed Topics for Defendant's Rule 30(b)(6) Deposition. SO ORDERED. (Signed by Magistrate Judge Ona T. Wang on 6/7/2022) (rro)

Case 1:16-cv-05243-ALC-OTW Document 192 Filed 06/07/22 Page 1 of 10

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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TERRI JABLONSKI.,
Plaintiff,
-againstSPECIAL COUNSEL, INC.,
Defendant.

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16-cv-5243 (ALC) (OTW)
ORDER

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ONA T. WANG, United States Magistrate Judge:
The Court has reviewed ECF 182, along with Plaintiff’s objections to Defendant’s
proposed 30(b)(6) topic modifications and objections. Defendant’s motion to modify and/or
object to Plaintiff’s proposed 30(b)(6) topics is GRANTED in part and DENIED in part. The
parties are directed to refer to the attached annotated version of Plaintiff’s List of Proposed
Topics for Defendant’s Rule 30(b)(6) Deposition.
SO ORDERED.

Dated: June 7, 2022
New York, New York

s/ Ona T. Wang
Ona T. Wang
United States Magistrate Judge

Case 1:16-cv-05243-ALC-OTW Document 192 Filed 06/07/22 Page 2 of 10

Jablonski v. Special Counsel, Inc.
LIST OF PROPOSED TOPICS
Rule 30(b )(6) Deposition of Defendant

Plaintiff's Topic 1:
deponent/s.

The background, work history, salary and compensation ofthe Rule 30(b)

SCl's Response:

SCI proposes the following modifications to this topic: The backgroundl

and work history, salary and compensation of the individual testifying pursuant to Rule 30(b) J
deponent/s. 1

Plaintiff's Topic 2: SCI's reasons for rejecting and/or refusing to refer Plaintiff for each of the
51 Paralegal jobs she applied to and the reasons for referring and/or hiring the comparison
applicants and the salary information about those jobs.
SCl's Response:

During a telephonic meeting on May 20, 2022, the parties agreed to the

✓

following topic instead: Explanation for why Plaintiff was not referred or hired for any of the
jobs to which she allegedly applied.

Plaintiff's Topic 3: The age information about the Persons whom Plaintiff named in her Third]
Amended Complaint whom she alleged were hired and/or referred instead of her.
SCl's Response:

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SCI has already produced the information reasonably available to it in

response to Plaintiffs documents requests and the Court's Order dated March 11, 2022 (ECF
No. 158). It is unclear what additional information, if any, Plaintiff is seeking with this topic.

Plaintiff's Topic 4: the name and title of the Supervisors, operation ofSCI's New York City
office during August 2013 through July or supervision ofparalegal recruiters, 2015 including
any monitoring number ofparalegal recrniters (and the name ofthe paralegal recrniters from
August 2013 to July 2015). statistics concerning placement of applicants in paralegal position,
The number of temporary and Direct Placement Paralegal Jobs that SCI placed during the
relevant period in 2013 to 2015, broken down by recrniter and revenue from those placements.

SCI staod s on its previously prop sed topic: General operation ofSCI's \
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New York City office during August 2013 through July 2015 including any monitoring or
SCl's Response'.

J

1

Text with a red font and strike through is being deleted. Text with a green font and underline is being added. Text
with a blue font has the meaning ascribed to it by Plaintiff in her submission of May 13, 2022.
SGR/3 7090660.2

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