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petitioner to respond to our discovery." The letter explained
that factual development was needed not only for purposes of this
case, but also "to set the factual predicate for third party
discovery." Respondent’s counsel suggested that petitioner might
wish to cooperate in depositions of nonparty witnesses under Rule
74. The June 19, 2002, letter further stated:
We are interested in developing the facts in this
case because we believe it is a good candidate for
designation for litigation under IRM 35.3.14.
Accordingly, we do not believe that postponing
discovery until August, as you suggest, is an
appropriate course of action for this case.
On July 5, 2002, petitioner filed the instant motion for a
protective order, seeking a stay of formal discovery "until the
parties have had sufficient time to confer and have engaged in
meaningful informal discovery." On July 11, 2002, this Court
entered an order staying compliance with respondent’s
interrogatories and request for production of documents pending
consideration of the instant motion for a protective order. The
Court subsequently received respondent’s Notice of Objection to
Petitioner’s Motion for a Protective Order. Respondent’s
objection is 23 pages long, exclusive of 6 additional charts and
11 other attachments. Ten days later, on August 1, 2002,
petitioner responded to respondent’s objections by sending to
this Court both a Motion to Strike and a separate Reply to
Respondent’s Objection to Petitioner’s Motion for Protective
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Last modified: May 25, 2011