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Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 27 of 32 fact through her errata sheet on May 31, and she refused to answer material questions at her deposition on the advice of counsel, including for example, which of Ms. Churcher’s many quotes attributed to her were incorrect. See,e g., Menninger Decl. Ex. D, referenced supra. As with Ms. Churcher’s deposition, the re-opened deposition of Plaintiff could occur in early July, assuming she provides the Court-ordered documents timely. VI. ALTERNATIVELY, ALL OTHER DEADLINES NEED TO BE EXTENDED Finally, Plaintiff glibly asserts that she seeks only 30 extra days to conduct her depositions, but does not want any other dates moved. Of course, that inures to her benefit and to Ms. Maxwell’s detriment. July already was scheduled for expert disclosures (Plaintiff has yet to disclose her retained expert, and thus the defense has been unable to secure a rebuttal expert). Likewise, should any new information be learned in these late depositions that requires rebuttal, Ms. Maxwell will be unable to secure such evidence on a timely basis. Further, summary judgment motions are due in this case on August 3. If depositions continue throughout August, Ms. Maxwell’s ability to include any late-learned information in her anticipated motion will be jeopardized. Finally, the trial is scheduled for October, continuing fact discovery until August seriously impinges on Ms. Maxwell’s ability to prepare for that trial, including preparing witnesses, exhibits and testimony. WHEREFORE, Ms. Maxwell requests that the Motion to Extend the Deadline to Complete Depositions be denied; alternatively, if the deadline is extended for any of the listed six witnesses, Ms. Maxwell requests that the dates for expert discovery, dispositive motions and the trial date by extended as well. Further, Ms. Maxwell requests sanctions for Plaintiff's failures to comply with the notice provisions of Rule 45(a)(4). apparently having been put on the slow boat to the US. One can only imagine where on the high seas the boxes may be located now. Of course, there were many alternative methods to search the boxes. The unknown custodians in Australia for example could have simply looked in them to see whether they contained any responsive documents. 24