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STATE OF RIDGEWAY
BRXKEN_NOOB
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CASE NO. RSC-CV-2273
Plaintiff,
v.
COLINTHEGREATEST
Defendant.
DEFENDANT’S MOTION TO LIMIT THE SCOPE OF INQUIRIES AT DEPOSITION
I. COURT IS EMPOWERED TO LIMIT INQUIRIES PRESENTABLE AT DEPOSITION
1. Pursuant to Ridg. R. Civ. Pro. 19(c) “Upon motion by a party or by the person from whom discovery
is sought, and for good cause shown, the court in which the action is pending or alternatively, on matters
relating to a deposition, the court, as the case may be, where the deposition is to be taken may make any
order which justice requires to protect a party or person from annoyance, embarrassment, oppression, or
undue burden or expense[.]” Ridg. R. Civ. Pro supra allows the court to order “that certain matters not
be inquired into, or that the scope of the discovery be limited to certain matters[.]”
II. COURT SHOULD PROTECT DEPONENT FROM UNDUE BURDEN
2. Video evidence of the incidents described by the Plaintiff in his complaint is found in the Plaintiff’s
initial disclosures. qLostful (hereinafter regarded as “Deponent”) first entered the frame of the initially
disclosed video at 00:31 operating a brown truck marked with the identification of the Sheriff’s Office.
Brxken_Noob (hereinafter regarded as “Plaintiff”) fled the scene in his green Corobal after the Deponent
tried to stop the Plaintiff. Plaintiff left the Deponent’s view at approximately 00:52 of the initially
disclosed video. Plaintiff does not bring any cause of action before this court against the Defendant for
what the Deponent could have possibly witnessed.
3. Deponent is at risk of suffering undue burden by being compelled to provide testimony at their
deposition for what they have not witnessed. This falls squarely within the interests of a Ridg. R. Civ.
Pro. supra protective order because the Deponent must undergo a series of abusive conduct by the
Plaintiff’s counsel before the Deponent may move for limitations or sanctions.
III. CONCLUSION
4. Defendant moves this court to limit what may be inquired into at the Deponent’s deposition to what
the Deponent personally witnessed. This court should exercise their discretion as to preemptively protect
the Deponent from any abusive lines of questioning regarding what they cannot answer, which is what
they have not witnessed.
Respectfully submitted,
Derogatoryyy
Clarke and Associates, LLP.
RSB#19119
D: @racoontimes
E: [email protected]
Submitted and dated: 02/19/2024
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Feb 9, 2024 12:00 PM
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COMPLAINT
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Notes
Motion to Limit the Scope of Inquiry [ brxken_noob v. colinthegreatest ].pdf — archived from the Trello docket (https://trello.com/c/K3zmOz4h)
