Zinovy V. Reytblatt and Natalia B. Romalis-Reytblatt - Page 4




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               (1) On April 11, 2001, an Application for Order To Take                
          Deposition of George Evans was received from petitioner.                    
          Petitioner did not attach a copy of the notice of deposition to             
          the application as required by Rule 75(d), and the application              
          was untimely.  See Rule 70(a)(2).  Respondent objected to the               
          deposition.                                                                 
               (2) Petitioner served a subpoena duces tecum on George Evans           
          (Mr. Evans) to appear for the purpose of taking the deposition.             
          On April 24, 2001, respondent timely filed a Motion to Quash                
          Subpoena Duces Tecum, which the Court granted.                              
               (3) On April 11, 2001, petitioner’s “Motion for the                    
          Protective Order” was received, the gravamen of which is totally            
          unclear except that the motion refers to the deposition of the              
          “sole witness”.  The granting of respondent’s motion to quash               
          disposed of all questions dealing with the deposition.                      
               (4) On April 26, 2001, petitioner filed a “Motion for                  
          Sanctions on Respondent” relating to the deposition of Mr. Evans.           
          That motion was denied at the hearing held on May 17, 2001.                 
               (5) On May 9, 2001, the Court received from petitioner a               
          “Pre-Trial Order” that contained various attachments–-a Motion              
          for Continuation, a proposed Stipulation for Facts, and a                   
          “Request to Admit to Respondent”.  Respondent treated the latter            
          document as a request for admissions and filed a response on May            
          14, 2001.                                                                   






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