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.
Defendant objects to the issuance of the subpoena.
At trial plaintiff wishes to use the deposition of John Taylor instead of his live testimony. Defendant objects because of the crucial importance of Taylor's testimony. At the deposition of Karen Lynch, the defendant did not object to her qualifications as an expert. At trial she does not testify, but the plaintiff off,,ers her deposition. Ernie filed an answer denying his negligence.