Blake Lively- Jason Baldoni and NYT - False Light claims

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Everybody gets a one day dep under the federal rules unless there is cause for additional time.

Liman caused this pile up inadvertently by releasing his Wallace decision today.

Am I correct that Fritz was not agreeing to reserve any portion of the 7 hours for Wallace if Wallace came back in to the case? That was said on Reddit. If so, that was strategic from Fritz because he didn’t want to lose any of his time. Which he would have been losing as of yesterday, when Wallace was still in the case.

Likewise, Lively doesn’t want to be deposed any longer than necessary lol.

Wallace being in weird party/non party limbo caused the issue. Liman seemed to want to find a way for everyone to depose Lively tomorrow to stick to the schedule (THE SCHEDULE ABOVE ALL!!!) but couldn’t work out a way that was legally defensible. Could he have ordered, under the rules, for the dep to proceed without Wallace, and Wallace to convene later if he was still in the case, in excess of seven hours? That’s the only other solution I’m aware of besides what they did. Is the fact that he didn’t do that what others are saying is unfair? Would you be okay with Baldoni’s or Heath’s deps being extended in the same way?

This is incorrect. The judge offered and Babcock agreed to a dummy complaint against Wallace. In that scenario, he asked if Gottlieb added new claims to a subsequent complaint, he get a chance to depose Blake in the future on those claims, IF ANY, only. This was the solution that made sense, and Gottlieb would not agree to it.

Everyone was being mildly inflexible, and that's what led to the postponement. Babcock actually pushed back a bit on the "dummy complaint" suggestion (he's the one who said "depends on how stupid it is" which was funny) because he really only wants to depose Blake after the SAC. Which is reasonable, but means a delay. Blake doesn't want to delay her deposition (she's probably been in full prep mode for at least a week, so delaying last second is a mental and scheduling annoyance) but also doesn't want to sit for two depositions, for the same reason. All of that is also reasonable despite what pro-JB people will say (Baldoni would also push back against being deposed twice for the same reasons). And Wayfarer doesn't want to give up any of their time to Babcock.

So the only possible solution was to push it back even though that's not really what anyone but Babcock wanted. This is being portrayed as Lively trying to get out of her depo, which makes no sense, she's going to be deposed and that was always the case, you cannot bring a lawsuit and then avoid deposition. Or as Gottlieb being unreasonable on multiple depositions but no lawyer agrees to multiple depos for their client without extraordinary circumstances -- I'm talking an earthquake or something, not a procedural quandary posed by a judge dismissing one defendant without prejudice at a bad time. Freedman/Fritz and Babcock would also refuse to have their clients deposed multiple times. The rules allow parties to push back on that so they will.

Yes, hard agree on ALL OF THIS, thank you! Honestly, if Lively had wanted to postpone the dep, Gottlieb would have acquiesced to Garofalo (I disagree with the PP who thought Gottlieb kinda wanted to delay but didn't want to make it look like it was their responsibility. No. He threatened sanctions! That's not someone who wants to push this off.).

Frankly, this really, really helps Baldoni's team if they are switching up the attorney who is taking this dep and decided that switch recently. They now have a lot more time to prepare. And if it's still Freedman, that's probably still helpful because he gets more time to distance himself from whatever weird crisis he was going through in late June.

Guess Lively headquarters finally sent out new talking points and they remain utter bullshit that are entirely inconsistent with what occurred at the hearing. Try again, ladies.

I’m not working with anyone or communicating with some team, but honestly your completely wild conspiracy theories and continued bad reads of wtf is going on with this case work great for me, because you will continue to make wrong calls about what will happen in the case which ultimately just makes you look foolish, and I will continue to be more correct than you.*

*I will sometimes get it wrong. Though I mostly haven’t so far ha. :p

[Anonymous]

Anonymous wrote:

Anonymous wrote:Lively definitely wanted to postpone the deposition, don’t insult our intelligence. Gottlieb shut down every other option at the hearing. Babcock wanted to go ahead with it, was already in route.

Why did Gottlieb then threaten to file sanctions against Garofalo if she tried to delay the deposition that Gottlieb really deep in his heart wanted so very much to delay. It makes no sense, but you don't care about that.

That was weeks ago, yesterday, he requested the delay. Technically, I believe Esra submitted the letter and he rejected every other option at the hearing. My guess is Lively’s prep is going horribly.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

How can this "represent bias" in favor of Lively if she didn't even get what she wanted?

I don't think we can say that unless we know who approached the court and what relief was requested. The tweet threat makes it sound like it was Gottlieb who did. This hearing popped up randomly on the docket, so whatever request must have been made via email. Actually, the InnerCityPress guy who live tweeted also did the Diddy trial and actually noticed they kept discussing emails that weren't on the docket, and moved for the court to enter all the emails onto the docket, which they actually granted! Too bad that did not happen here.

It's really something that Lively was threatening sanctions and attorney's fees for costs on Friday because they might need to reschedule Thursday flights (at their insistence on changing the deposition location which had not yet been ruled on by the court or requested) but it's ok that Wallace and Wayfarer wasted time and money flying to New York for nothing.

We do know who approached the court, Lively’s attorneys filed a letter yesterday afternoon. The gaslighting from the Lively side today is quite something.

I must have missed that, I only saw a letter after the hearing, saying the deposition had been rescheduled.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Everybody gets a one day dep under the federal rules unless there is cause for additional time.

Liman caused this pile up inadvertently by releasing his Wallace decision today.

Am I correct that Fritz was not agreeing to reserve any portion of the 7 hours for Wallace if Wallace came back in to the case? That was said on Reddit. If so, that was strategic from Fritz because he didn’t want to lose any of his time. Which he would have been losing as of yesterday, when Wallace was still in the case.

Likewise, Lively doesn’t want to be deposed any longer than necessary lol.

Wallace being in weird party/non party limbo caused the issue. Liman seemed to want to find a way for everyone to depose Lively tomorrow to stick to the schedule (THE SCHEDULE ABOVE ALL!!!) but couldn’t work out a way that was legally defensible. Could he have ordered, under the rules, for the dep to proceed without Wallace, and Wallace to convene later if he was still in the case, in excess of seven hours? That’s the only other solution I’m aware of besides what they did. Is the fact that he didn’t do that what others are saying is unfair? Would you be okay with Baldoni’s or Heath’s deps being extended in the same way?

This is incorrect. The judge offered and Babcock agreed to a dummy complaint against Wallace. In that scenario, he asked if Gottlieb added new claims to a subsequent complaint, he get a chance to depose Blake in the future on those claims, IF ANY, only. This was the solution that made sense, and Gottlieb would not agree to it.

Everyone was being mildly inflexible, and that's what led to the postponement. Babcock actually pushed back a bit on the "dummy complaint" suggestion (he's the one who said "depends on how stupid it is" which was funny) because he really only wants to depose Blake after the SAC. Which is reasonable, but means a delay. Blake doesn't want to delay her deposition (she's probably been in full prep mode for at least a week, so delaying last second is a mental and scheduling annoyance) but also doesn't want to sit for two depositions, for the same reason. All of that is also reasonable despite what pro-JB people will say (Baldoni would also push back against being deposed twice for the same reasons). And Wayfarer doesn't want to give up any of their time to Babcock.

So the only possible solution was to push it back even though that's not really what anyone but Babcock wanted. This is being portrayed as Lively trying to get out of her depo, which makes no sense, she's going to be deposed and that was always the case, you cannot bring a lawsuit and then avoid deposition. Or as Gottlieb being unreasonable on multiple depositions but no lawyer agrees to multiple depos for their client without extraordinary circumstances -- I'm talking an earthquake or something, not a procedural quandary posed by a judge dismissing one defendant without prejudice at a bad time. Freedman/Fritz and Babcock would also refuse to have their clients deposed multiple times. The rules allow parties to push back on that so they will.

Yes, hard agree on ALL OF THIS, thank you! Honestly, if Lively had wanted to postpone the dep, Gottlieb would have acquiesced to Garofalo (I disagree with the PP who thought Gottlieb kinda wanted to delay but didn't want to make it look like it was their responsibility. No. He threatened sanctions! That's not someone who wants to push this off.).

Frankly, this really, really helps Baldoni's team if they are switching up the attorney who is taking this dep and decided that switch recently. They now have a lot more time to prepare. And if it's still Freedman, that's probably still helpful because he gets more time to distance himself from whatever weird crisis he was going through in late June.

Guess Lively headquarters finally sent out new talking points and they remain utter bullshit that are entirely inconsistent with what occurred at the hearing. Try again, ladies.

I’m not working with anyone or communicating with some team, but honestly your completely wild conspiracy theories and continued bad reads of wtf is going on with this case work great for me, because you will continue to make wrong calls about what will happen in the case which ultimately just makes you look foolish, and I will continue to be more correct than you.*

*I will sometimes get it wrong. Though I mostly haven’t so far ha. :p

You get a ton wrong actually, and everything you’ve posted for the past 18 hours ignores the hearing transcript and letter filed by Lively’s attorneys yesterday.

[Anonymous]

Daily Mail has another article about the public backlash against the Lively content subpoenas. Brands her a “toxic diva.” https://www.dailymail.co.uk/tvshowbiz/article-14912645/blake-lively-toxic-legal-justin-baldoni-feud.html

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Everybody gets a one day dep under the federal rules unless there is cause for additional time.

Liman caused this pile up inadvertently by releasing his Wallace decision today.

Am I correct that Fritz was not agreeing to reserve any portion of the 7 hours for Wallace if Wallace came back in to the case? That was said on Reddit. If so, that was strategic from Fritz because he didn’t want to lose any of his time. Which he would have been losing as of yesterday, when Wallace was still in the case.

Likewise, Lively doesn’t want to be deposed any longer than necessary lol.

Wallace being in weird party/non party limbo caused the issue. Liman seemed to want to find a way for everyone to depose Lively tomorrow to stick to the schedule (THE SCHEDULE ABOVE ALL!!!) but couldn’t work out a way that was legally defensible. Could he have ordered, under the rules, for the dep to proceed without Wallace, and Wallace to convene later if he was still in the case, in excess of seven hours? That’s the only other solution I’m aware of besides what they did. Is the fact that he didn’t do that what others are saying is unfair? Would you be okay with Baldoni’s or Heath’s deps being extended in the same way?

This is incorrect. The judge offered and Babcock agreed to a dummy complaint against Wallace. In that scenario, he asked if Gottlieb added new claims to a subsequent complaint, he get a chance to depose Blake in the future on those claims, IF ANY, only. This was the solution that made sense, and Gottlieb would not agree to it.

Everyone was being mildly inflexible, and that's what led to the postponement. Babcock actually pushed back a bit on the "dummy complaint" suggestion (he's the one who said "depends on how stupid it is" which was funny) because he really only wants to depose Blake after the SAC. Which is reasonable, but means a delay. Blake doesn't want to delay her deposition (she's probably been in full prep mode for at least a week, so delaying last second is a mental and scheduling annoyance) but also doesn't want to sit for two depositions, for the same reason. All of that is also reasonable despite what pro-JB people will say (Baldoni would also push back against being deposed twice for the same reasons). And Wayfarer doesn't want to give up any of their time to Babcock.

So the only possible solution was to push it back even though that's not really what anyone but Babcock wanted. This is being portrayed as Lively trying to get out of her depo, which makes no sense, she's going to be deposed and that was always the case, you cannot bring a lawsuit and then avoid deposition. Or as Gottlieb being unreasonable on multiple depositions but no lawyer agrees to multiple depos for their client without extraordinary circumstances -- I'm talking an earthquake or something, not a procedural quandary posed by a judge dismissing one defendant without prejudice at a bad time. Freedman/Fritz and Babcock would also refuse to have their clients deposed multiple times. The rules allow parties to push back on that so they will.

Yes, hard agree on ALL OF THIS, thank you! Honestly, if Lively had wanted to postpone the dep, Gottlieb would have acquiesced to Garofalo (I disagree with the PP who thought Gottlieb kinda wanted to delay but didn't want to make it look like it was their responsibility. No. He threatened sanctions! That's not someone who wants to push this off.).

Frankly, this really, really helps Baldoni's team if they are switching up the attorney who is taking this dep and decided that switch recently. They now have a lot more time to prepare. And if it's still Freedman, that's probably still helpful because he gets more time to distance himself from whatever weird crisis he was going through in late June.

Guess Lively headquarters finally sent out new talking points and they remain utter bullshit that are entirely inconsistent with what occurred at the hearing. Try again, ladies.

I’m not working with anyone or communicating with some team, but honestly your completely wild conspiracy theories and continued bad reads of wtf is going on with this case work great for me, because you will continue to make wrong calls about what will happen in the case which ultimately just makes you look foolish, and I will continue to be more correct than you.*

*I will sometimes get it wrong. Though I mostly haven’t so far ha. :p

You get a ton wrong actually, and everything you’ve posted for the past 18 hours ignores the hearing transcript and letter filed by Lively’s attorneys yesterday.

There's more than one person you're responding to here. I didn't ask who called for the hearing. You are, again, conflating multiple posters and generally continuously failing to learn from past mistakes here that you repeat over and over again.

[Anonymous]

Just wanted to remind everyone that Jed Wallace has already been deposed even though he shouldn’t have even still been in the case. Do we think Liman would prevent a retake of his deposition? My guess is no.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Everybody gets a one day dep under the federal rules unless there is cause for additional time.

Liman caused this pile up inadvertently by releasing his Wallace decision today.

Am I correct that Fritz was not agreeing to reserve any portion of the 7 hours for Wallace if Wallace came back in to the case? That was said on Reddit. If so, that was strategic from Fritz because he didn’t want to lose any of his time. Which he would have been losing as of yesterday, when Wallace was still in the case.

Likewise, Lively doesn’t want to be deposed any longer than necessary lol.

Wallace being in weird party/non party limbo caused the issue. Liman seemed to want to find a way for everyone to depose Lively tomorrow to stick to the schedule (THE SCHEDULE ABOVE ALL!!!) but couldn’t work out a way that was legally defensible. Could he have ordered, under the rules, for the dep to proceed without Wallace, and Wallace to convene later if he was still in the case, in excess of seven hours? That’s the only other solution I’m aware of besides what they did. Is the fact that he didn’t do that what others are saying is unfair? Would you be okay with Baldoni’s or Heath’s deps being extended in the same way?

This is incorrect. The judge offered and Babcock agreed to a dummy complaint against Wallace. In that scenario, he asked if Gottlieb added new claims to a subsequent complaint, he get a chance to depose Blake in the future on those claims, IF ANY, only. This was the solution that made sense, and Gottlieb would not agree to it.

Everyone was being mildly inflexible, and that's what led to the postponement. Babcock actually pushed back a bit on the "dummy complaint" suggestion (he's the one who said "depends on how stupid it is" which was funny) because he really only wants to depose Blake after the SAC. Which is reasonable, but means a delay. Blake doesn't want to delay her deposition (she's probably been in full prep mode for at least a week, so delaying last second is a mental and scheduling annoyance) but also doesn't want to sit for two depositions, for the same reason. All of that is also reasonable despite what pro-JB people will say (Baldoni would also push back against being deposed twice for the same reasons). And Wayfarer doesn't want to give up any of their time to Babcock.

So the only possible solution was to push it back even though that's not really what anyone but Babcock wanted. This is being portrayed as Lively trying to get out of her depo, which makes no sense, she's going to be deposed and that was always the case, you cannot bring a lawsuit and then avoid deposition. Or as Gottlieb being unreasonable on multiple depositions but no lawyer agrees to multiple depos for their client without extraordinary circumstances -- I'm talking an earthquake or something, not a procedural quandary posed by a judge dismissing one defendant without prejudice at a bad time. Freedman/Fritz and Babcock would also refuse to have their clients deposed multiple times. The rules allow parties to push back on that so they will.

Yes, hard agree on ALL OF THIS, thank you! Honestly, if Lively had wanted to postpone the dep, Gottlieb would have acquiesced to Garofalo (I disagree with the PP who thought Gottlieb kinda wanted to delay but didn't want to make it look like it was their responsibility. No. He threatened sanctions! That's not someone who wants to push this off.).

Frankly, this really, really helps Baldoni's team if they are switching up the attorney who is taking this dep and decided that switch recently. They now have a lot more time to prepare. And if it's still Freedman, that's probably still helpful because he gets more time to distance himself from whatever weird crisis he was going through in late June.

Guess Lively headquarters finally sent out new talking points and they remain utter bullshit that are entirely inconsistent with what occurred at the hearing. Try again, ladies.

I’m not working with anyone or communicating with some team, but honestly your completely wild conspiracy theories and continued bad reads of wtf is going on with this case work great for me, because you will continue to make wrong calls about what will happen in the case which ultimately just makes you look foolish, and I will continue to be more correct than you.*

*I will sometimes get it wrong. Though I mostly haven’t so far ha. :p

You get a ton wrong actually, and everything you’ve posted for the past 18 hours ignores the hearing transcript and letter filed by Lively’s attorneys yesterday.

There's more than one person you're responding to here. I didn't ask who called for the hearing. You are, again, conflating multiple posters and generally continuously failing to learn from past mistakes here that you repeat over and over again.

Nope.

[Anonymous]

Anonymous wrote:Lively definitely wanted to postpone the deposition, don’t insult our intelligence. Gottlieb shut down every other option at the hearing. Babcock wanted to go ahead with it, was already in route.

Why? To what end? She will have been preparing for this deposition for some time now, she's probably quite nervous about it. There is no advantage for her to a sudden delay.

[Anonymous]

Anonymous wrote:Just wanted to remind everyone that Jed Wallace has already been deposed even though he shouldn’t have even still been in the case. Do we think Liman would prevent a retake of his deposition? My guess is no.

Of course not, just like a Sunday deadline had to be set because of the risk Wilkie attorneys might have to change Thursday flights, but Babcock calling in at 5 30 the night before from the airport while Baldoni was mid flight was acceptable.

[Anonymous]

Anonymous wrote:

Anonymous wrote:Lively definitely wanted to postpone the deposition, don’t insult our intelligence. Gottlieb shut down every other option at the hearing. Babcock wanted to go ahead with it, was already in route.

Why? To what end? She will have been preparing for this deposition for some time now, she's probably quite nervous about it. There is no advantage for her to a sudden delay.

Well she mutually agreed to it so I guess she wanted it.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

How can this "represent bias" in favor of Lively if she didn't even get what she wanted?

I don't think we can say that unless we know who approached the court and what relief was requested. The tweet threat makes it sound like it was Gottlieb who did. This hearing popped up randomly on the docket, so whatever request must have been made via email. Actually, the InnerCityPress guy who live tweeted also did the Diddy trial and actually noticed they kept discussing emails that weren't on the docket, and moved for the court to enter all the emails onto the docket, which they actually granted! Too bad that did not happen here.

It's really something that Lively was threatening sanctions and attorney's fees for costs on Friday because they might need to reschedule Thursday flights (at their insistence on changing the deposition location which had not yet been ruled on by the court or requested) but it's ok that Wallace and Wayfarer wasted time and money flying to New York for nothing.

We do know who approached the court, Lively’s attorneys filed a letter yesterday afternoon. The gaslighting from the Lively side today is quite something.

Yes, Lively's attorneys requested the emergency hearing. But not because they wanted to postpone the hearing. They wanted the hearing because they realized that Babcock (Wallace's attorney) could no longer take part in the hearing as scheduled due to the dismissal, and Babcock likely let them know he intended to depose Lively if/when they refile against Wallace. So they went to the court to see if there was a way to still have Babcock participate in the deposition and present Lively being re-deposed.

This is very typical. Any other attorney would also seek to prevent their client from being deposed twice. Double depositions are not only very burdensome (it takes weeks of prep before a deposition, both for the witness and the attorneys) but also put you at a serious disadvantage because it gives the other side time to adjust tactics based on the witness's first responses. While in this case the depositions would be done by different parties, there's every reason to assume Wayfarer's and Wallace's teams would collaborate to try and trip Lively up the second time. It is basically malpractice to let your client be deposed twice.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

How can this "represent bias" in favor of Lively if she didn't even get what she wanted?

I don't think we can say that unless we know who approached the court and what relief was requested. The tweet threat makes it sound like it was Gottlieb who did. This hearing popped up randomly on the docket, so whatever request must have been made via email. Actually, the InnerCityPress guy who live tweeted also did the Diddy trial and actually noticed they kept discussing emails that weren't on the docket, and moved for the court to enter all the emails onto the docket, which they actually granted! Too bad that did not happen here.

It's really something that Lively was threatening sanctions and attorney's fees for costs on Friday because they might need to reschedule Thursday flights (at their insistence on changing the deposition location which had not yet been ruled on by the court or requested) but it's ok that Wallace and Wayfarer wasted time and money flying to New York for nothing.

We do know who approached the court, Lively’s attorneys filed a letter yesterday afternoon. The gaslighting from the Lively side today is quite something.

I must have missed that, I only saw a letter after the hearing, saying the deposition had been rescheduled.

Sorry, you are right, the Hudson letter was after. Here is the tweet where Gottlieb thanks the Court for granting his request for an emergency hearing. He’s the first attorney to speak, which also confirms it’s his motion.

Inner City Press
@innercitypress
·
20h
Judge Liman: Mr. Gottlieb?
Lively's lawyer Gottlieb: Thanks for setting this on an emergency basis. Ms. Lively should only sit for on deposition, seven hours. At 10:30 am this morning your Honor granted motions to dismiss, for Wallace- now they offer us 3 options.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:Lively definitely wanted to postpone the deposition, don’t insult our intelligence. Gottlieb shut down every other option at the hearing. Babcock wanted to go ahead with it, was already in route.

Why? To what end? She will have been preparing for this deposition for some time now, she's probably quite nervous about it. There is no advantage for her to a sudden delay.

Well she mutually agreed to it so I guess she wanted it.

To avoid being deposed twice. A delay is better than being deposed twice. But holding the deposition as scheduled would have been preferable to both options, which is why Gottlieb scrambled to try and find a way have the depo happen as scheduled. This was obvious from the hearing. Gottlieb was advocating for ways in which Babcock could participate in the scheduled deposition, he was not advocating for a delay.

[Anonymous]

Anonymous wrote:

Anonymous wrote:

Anonymous wrote:

How can this "represent bias" in favor of Lively if she didn't even get what she wanted?

I don't think we can say that unless we know who approached the court and what relief was requested. The tweet threat makes it sound like it was Gottlieb who did. This hearing popped up randomly on the docket, so whatever request must have been made via email. Actually, the InnerCityPress guy who live tweeted also did the Diddy trial and actually noticed they kept discussing emails that weren't on the docket, and moved for the court to enter all the emails onto the docket, which they actually granted! Too bad that did not happen here.

It's really something that Lively was threatening sanctions and attorney's fees for costs on Friday because they might need to reschedule Thursday flights (at their insistence on changing the deposition location which had not yet been ruled on by the court or requested) but it's ok that Wallace and Wayfarer wasted time and money flying to New York for nothing.

We do know who approached the court, Lively’s attorneys filed a letter yesterday afternoon. The gaslighting from the Lively side today is quite something.

Yes, Lively's attorneys requested the emergency hearing. But not because they wanted to postpone the hearing. They wanted the hearing because they realized that Babcock (Wallace's attorney) could no longer take part in the hearing as scheduled due to the dismissal, and Babcock likely let them know he intended to depose Lively if/when they refile against Wallace. So they went to the court to see if there was a way to still have Babcock participate in the deposition and present Lively being re-deposed.

This is very typical. Any other attorney would also seek to prevent their client from being deposed twice. Double depositions are not only very burdensome (it takes weeks of prep before a deposition, both for the witness and the attorneys) but also put you at a serious disadvantage because it gives the other side time to adjust tactics based on the witness's first responses. While in this case the depositions would be done by different parties, there's every reason to assume Wayfarer's and Wallace's teams would collaborate to try and trip Lively up the second time. It is basically malpractice to let your client be deposed twice.

It has been said multiple times that Babcock was willing to limit any further deposition to any new claims in the amended complaint against Wallace. WF would not be participating and the scope of any further deposition would be extremely limited, if it happened at all. This is the normal procedure, the seven hour, one day is often overruled for good cause. Further, it is widely recognized that the plaintiff is expected to bear a greater burden in discovery than other parties. No so here.