Each petition is properly brought and is properly opposed by the other side. You are the federal judge in Fort Smith. In ruling you should not assume any unique or unusual facts. Two months before filing the action, the plaintiff files a petition to take the deposition of John Taylor. Six weeks after filing the action, the plaintiff notifies the defendant's weedeater engineer to come to Fort Smith for a deposition.
Defendant moves for a protective order.
The defendant requests that the judge issue a subpoena to be mailed to John Taylor directing him to appear for an oral deposition in Henryetta. 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, which reimburses plaintiff for claims against him.