📧 from ORDOJ: "there will NOT be Sunday depositions"
I am aware of nothing in the Court’s Order that requires your continued use of arbitrary deadlines. Ms. White will be back in the office on the 12th, but that will be her first day back and dealing with you desire for instant gratification is not feasible. She will respond to you as regards the privilege log as she works through the needs of all her cases.
As Ms. White has told you previously, there will NOT be Sunday depositions. You chose to file this lawsuit. You need to make yourself available during regular business hours. You cannot, because you feel you must not miss your work, require either Ms. White or the witnesses to give up their Sundays, which are their days off or days of worship. You need to make time during the regular hours of 9am to 5pm Monday through Friday. Either close your business or hire temporary support.
As to the idea of filing yet another motion with the Court, as you note, the current notices have been withdrawn, and, accordingly, there are no current notices of deposition. It is incumbent upon you reasonably to confer with Ms. White on her return. No motion practice will be appropriate prior to that.
