Plaintiffs' counsel finally conferred with Defendants' counsel, Kristen CaverlyĪnd Philip Sechler, on Wednesday, April 23, 2008, at which time Plaintiffs' counsel stated that she was unavailable for various periods between then and July, so the depositions could not begin as promptly as Defendants wanted them to begin. Caverly's April 16 email confirming her availability for a telephone conference at Ms. Otherwise respond to Defendants' April 16 letter, and also failed to acknowledge Ms. MacIvor failed to schedule the conference call or Caverly, dated July 20, 2008, at ¶ 3, attached as Exhibit B.) 5. MacIvor was unavailable, but that a conference call would be set on her return to the office Monday, April 21, to discuss the deposition schedule proposed in Defendants' April 16 letter. The following day, on April 17, 2008, a paralegal with Ms. Regarding location, order and dates," indicating that Defendants "are open to considering any reasonable means to complete these in the short time available but we need to move quickly in order to have the depositions completed by July 31" so as to "be ready to respond to your anticipated class certification motion." (Id.) 4. Caverly invited Plaintiffs' counsel to offer "some other proposal Plaintiffs' counsel, Catherine MacIvor, proposing dates, order and times of depositions of each of the 33 named plaintiffs in this action on successive days in Miami, Florida, beginning the week of May 12, 2008. Albertsons LLC PETCO Animal Supplies Stores, Inc. Menu Foods Income Fund Publix Supermarkets, Inc. Defendants moving here are: Mars, Incorporated Mars Petcare US, Inc. This Motion is made on behalf of all Defendants, with the exception of Defendant Kroger Co. On behalf of all Defendants with respect to coordination of Plaintiffs' depositions, sent a letter to On April 16, 2008, counsel for Natura Pet Products Inc., Kristen Caverly, acting In its ApOrder on Motion to Dismiss, this Court ordered that "lassĪnd merits discovery shall commence." 2.
_/ DEFENDANTS' MOTION TO COMPEL THE DEPOSITIONS OF PLAINTIFFS AND INCORPORATED MEMORANDUM OF LAW Defendants1 hereby move pursuant to Rules 30 and 37 of the Federal Rules of Civil Procedure to compel the depositions of all Plaintiffs named in this action on the dates, at the locations and under the terms identified in Exhibit A hereto, and state: FACTUAL AND PROCEDURAL BACKGROUND 1. 07-21221-CIV-ALTONAGA/BROWN RENEE BLASZKOWSKI, et al., individually and on behalf of others similarly situated, Plaintiffs, vs. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO.
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