248-0 Plaintiffs Motion to Strike

June 29th, 2023

Full docket text for document 248:
MOTION to Strike and Order Depositions Taken as Noticed. Ryan R. Shaffer appearing for Plaintiffs Tracy Caekaert, Camillia Mapley. (Shaffer, Ryan)

PLAINTIFFS’ MOTION TO STRIKE AND ORDER DEPOSITIONS TAKEN AS NOTICED

Plaintiffs Tracy Caekaert and Camillia Mapley, by and through undersigned counsel, hereby respectfully request the Court (1) strike or reject all arguments raised for the first time in Defendant Watchtower Bible and Tract Society of New York, Inc.’s (“WTNY”) Reply Brief in Support of Motion for Protective Order Pursuant to Fed. R. Civ. P. 26(c) (Doc. 247); and (2) order the depositions of Gary Breaux, Allen Shuster, and Gene Smalley taken as noticed for August 30 through September 1, 2023, pursuant to Rule 26(c)(2) of the Federal Rules of Civil Procedure. A supporting brief is filed contemporarily herewith. L.R. 7.1(d)(1)(A). Likewise, the propriety of these depositions has been briefed previously three times by Plaintiffs; such briefs are incorporated by reference. Pls.’ Br. in Supp. of Their Mot. to Compel Deps. (Doc. 154); Pls.’ Reply in Supp. of Their Mot. to Compel Deps. (Doc. 170); Pls.’ Resp. in Opp’n to Def. WTNY’s Mot. for Protective Ord. (Doc. 243). If the Court finds it appropriate to conduct a hearing on these matters before the scheduled depositions, Plaintiffs’ counsel will be available. L.R. 7.1(e). Counsel for WTNY was contacted regarding this motion and indicated that WTNY objects. L.R. 7.1(c)(1).