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 and her opinions through interrogatories, defendant sends a written notice to plaintiff's attorney to produce her for a deposition in Austin, which will be videotaped. Defendant requests plaintiff to produce her homeowner's liability insurance policy, which reimburses plaintiff for claims against her.
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 because the documents are privileged. Plaintiff petitions the court for the imposition of immediate sanctions, including the establishment of certain facts. 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.