[brief] **THE TRIAL COURT DID NOT ABUSE ITS DISCRETION IN FINDING THAT THE REQUESTED DEPOSITION SEEKS RELEVANT INFORMATION (AA821)**  As an initial matter, “a non-party deponent may not assert lack of relevancy or materiality since he has no real interest in the outcome of the pending litigation. ”  *Berrie v. Berrie*, 188 N.J. Super. 274, 282-83 (Ch. Div. 1983).  Even assuming [...] can assert a relevance objection, the deposition is plainly relevant, and the Trial Court did not abuse its discretion when making that determination.  The scope of pretrial discovery is extraordinarily broad.  *Marrero v. Feintuch*, 418 N.J. Super. 48 (App. Div. 2011); *Jenkins v. Rainner*, 69 N.J. 50, 56 (1976).  Barring a claim of privilege, “[p]arties may obtain discovery regarding any matter . . . which is relevant to the subject matter involved in the pending action. ”  R. 4:10-2.  “[O]ur courts have held that rules of discovery are to be liberally construed and accorded the broadest possible latitude. ”  *Marrero*, 418 N.J. Super. at 48 (quoting *Blumberg v. Dornbusch*, 139 N.J. Super. 433, 437-38 (App. Div. 1976).  “Our court system has long been committed to the view that essential justice is better achieved when there has been full disclosure so that the parties are conversant with all the available facts. ”  *Jenkins v. Rainner*, 69 N.J. 50, 56 (1976).  When examining a request to restrict pretrial discovery, “the principle guiding the court should be to generally permit the widest latitude in the use of available discovery tools. ”  *Marrero*, 418 N.J. Super at 891.  In its review, a court must also keep in mind “[i]t is not ground for objection that the information sought [in discovery] will be inadmissible at the trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence[.]”  R. 4:10-2(a) (emphasis added); see also *Pfenninger v.* Hunterdon Cent. Reg’l High Sch., 167 N.J. 230, 237 (2001).  “‘Relevant evidence,’ although not defined in the discovery rules, is defined elsewhere as ‘evidence having a tendency in reason to prove or disprove any fact of consequence to the determination of the action. ’”  Payton v. N.J. Turnpike Auth., 148 N.J. 524, 535 (1997) (citing N.J.R.E. 401).  Weighed against these standards, [...]’s testimony is clearly relevant.  “A movant resisting the deposition ordinarily has the burden of proving ‘good cause’ for a protective order—that is, the movant must establish ‘that a protective order is necessary. ”  Horon Holding Corp. v. McKenzie, 341 N.J. Super. 117, 128 (App. Div. 2001) (quoting Kerr v. Able Sanitary & Environmental Servs., 295 N.J. Super. 147 (App. Div. 1996)).  Prohibiting the deposition of a relevant witness is generally an extraordinary remedy.  A.D. v. Ranney Sch. & James Paroline, 2023 N.J. Super LEXIS 605 (App. Div. Dec. 21, 2022) (reversing trial court order prohibiting deposition where “the [trial] court simply reasoned defendants should be precluded from taking the deposition of a clearly essential witness based on vague assertions of putative harm, without regard to defendants’ need for and right to obtain the information C.S. possesses”); Yawger v. Suburban Propane, 27 N.J. Super. Unpub. LEXIS 3764, at *3 (N.J. Super. Aug. 18, 2017) (compelling further party deposition, reasoning “due to the remarkable breadth of [p]laintiff’s claims for damages, this Court finds that [d]efendant’s deposition questions are relevant to the case and that [d]efendant is not attempting to harass [p]laintiff with irrelevant questions”).  *Berrie v. Berrie*, 188 N.J. Super. 274, 282-83 (Ch. Div. 1983), cited by [...], counsels in favor of compelling [...]’s deposition.