Each of the following petitions, motions or requests is directed to the federal judge in Fort Smith. 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.
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.