`**E-FILED**
`19EV000055
`3/11/2020 12:19 PM
`LeNora Ponzo, Clerk
`Civil Division
`
`1N THE STATE COURT OF FULTON COUNTY
`STATE OF GEORGIA
`
`Civil Action File No.
`19EV000055
`
`) )
`
`) )
`
`)
`)
`) .
`)
`
`) )
`
`DEANDREA CALLOWAY,
`
`Plaintiff,
`
`vs.
`CONSTANTIN GUTIERREZ-RIOS
`and LIBERTY MUTUAL INSURANCE
`COMPANY,
`
`Defendant.
`DEFENDANT’S MOTION FOR PROTECTIVE ORDER
`Defendant Constantino Gutierrez Rios (incorrectly designated in the case caption as
`
`)
`
`“Constantin Gutierrez—Rios”), by and through counsel, moves this Court for a protective order
`relieving him from being deposed by plaintiffs counsel under O.C.G.A. § 9-1 1-45 and 9-1 1-30.
`Defendant shows that his deposition has been noticed to take place at plaintiff’s counsel’s office
`in Macon, Georgia, but defendant resides in Adel, Georgia. As such, having defendant appear
`for a deposition at plaintiff’s counsel’s office in Macon is unduly burdensome. Accordingly,
`
`defendant is under no obligation to appear for plaintiffs unilaterally noticed deposition,
`
`scheduled for March 13, 2020. Moreover, defendant has a pending Motion to Dismiss, and
`
`discovery is stayed for ninety (90) days or until the Court’s ruling on the Motion pursuant to
`
`O.C.G.A. § 9-1 1-12 (i). Plaintiff has already served defendant with written discovery requests.
`An in-person deposition in addition to written discovery would be unduly burdensome and
`
`exceed the circumstantially necessary “limited discovery” as permitted by O.C.G.A. § 9-1 1-12
`
`OX4)-
`
`[SIGNATUREAPPEARS 0NFOLLOWING PAGE]
`
`
`
`WALDON ADELMAN CASTILLA
`
`HIESTAND & PROUTMvfiw
`
`Marcia S. Freeman
`Georgia Bar No. 430923
`Ashley L. Yagla
`Georgia Bar No. 238843
`Attorneys for Defendant Gutierrez Rios
`
`This
`
`k
`
`K
`
`day ofMarch,2020.
`
`900 Circle 75 Parkway
`Suite 1040
`Atlanta, Georgia 30339
`(770) 953-1710
`mfreeman@wachp.com
`ayagla@wachp.com
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that on March 11, 2020, I electronically filed PLEADING with the Clerk
`of the Court using an O.C.G.A. § 15-6-11 electronic filing service provider which will
`
`automatically send e-mail notification of such filing to the following attorney(s) of record:
`
`Nadia Nickerson, Esq.
`Law Offices of McLaughlin, Ream & Wyrick
`360 Interstate North Parkway SE
`Suite 375
`Atlanta, GA 30339
`mclau hlinelectronicmail
`liber mutual.com
`
`WALDON ADELMAN CASTILLA
`
`HIESTAND & PROUTM&«W
`
`Marcia S. Freeman
`Georgia Bar No. 430923
`Ashley L. Yagla
`Georgia Bar No. 238843
`Attorneys for Defendant Gutierrez Rios
`
`David T. Dorer, Esq.
`Dozier Law Firm, LLC
`327 Third Street
`P.O. Box 13
`Macon, GA 3 1202
`dorer@dozierlaw.com
`This!
`
`day of March, 2020.
`
`900 Circle 75 Parkway
`Suite 1040
`Atlanta, Georgia 30339
`(770) 953-1710
`mfreeman@wachp.com
`ayagla@wachp.com
`
`
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