All deponents are residents of the Netherlands.
Alternatively, Generale Bank requests an order allowing the defendant to obtain information from the deponents only by written interrogatories. In its self-executing disclosure, Generale Bank identified the deponents as persons reasonably likely to have information that bears significantly on its claim. In fact, Generale Bank attached R.J. de Haas's affidavit in support of its Motion for Summary Judgment. Accordingly, this Court finds that the deponents have information which may be relevant to the subject matter involved in the pending action. The party seeking a protective order bears the burden of demonstrating 'good cause' required to support such an order.