The defendant requests that you issue a subpoena to be mailed to John Taylor directing him to appear for a deposition in Atlanta. Plaintiff's expert witness, who will testify at trial, is Karen Lynch of Austin, Texas. After discovery of her name through interrogatories, defendant notifies plaintiff's attorney to produce her at a deposition in Austin. Plaintiff objects to the notice. Defendant requests plaintiff to produce his homeowner's liability insurance policy.
Defendant objects to the propriety of such a request for admission.
The plaintiff requests documents. The defendant responds in a timely fashion by providing some and objecting to the remainder. Plaintiff petitions the court for appropriate sanctions, including the establishment of certain facts. A former employee of the defendant now lives in Memphis, Tennessee. Plaintiff wishes to have a subpoena issued by the clerk in Fort Smith to compel him to be a witness at the trial.