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Re: navycmdr post# 295021

Tuesday, 03/31/2015 3:49:27 PM

Tuesday, March 31, 2015 3:49:27 PM

Post# of 793430
SWEENEY: There is one exception: if deposition reveals something unforeseen that they could not have anticipated – there may be grounds (for a second bite). Otherwise, it is not fair and it is not efficient.

DINTZER: Thank you. Everything we do is a distraction from our primary job which is production of documents. We are trying to work with plaintiff, but they are threatening the schedule.

SWEENEY: ok Mr. Cooper – “sorry for that wet blanket” you may proceed!

COOPER: I believe there is some confusion. If counsel is saying their only concern is that we wait for document production – which they say they can complete by the end of April – then we agree.

We have two dates set for deposition – April 17 and April 29.

I am happy to reschedule.