#IStandwithVic The Irony/Paradox of Casey S Erick

On Wednesday, May 8, 2:09 p.m., Plaintiff’s email stated:
Casey, five days ago, I asked you to give me availability dates to
depose your clients. You have failed to do so. So please provide me
with availability dates for two days from May 15 thru May 29,
2019.
In the alternative, please advise whether you will agree to a Rule
11 agreement to (a) depose Mr. Mignogna first; and (b) to not file
a motion to dismiss under the TCPA until we’ve the opportunity to
depose your clients.
Finally, will you agree to a Confidentiality Agreement that in
which your clients and Mr. Mignogna will agree to not publicly
discuss any of the deposition testimony? I think this is in
everyone’s best interest, since the matters discussed will be very
personal for each deponent.
If I don’t hear from you by noon tomorrow, I will interpret your
silence to mean that you will not provide the availability dates, that
you do not agree to the proposed Rule 11 agreement, and that you
won’t agree to a Confidentiality Agreement. In that case, we will
file motions for a protective order and to quash the May 30
deposition of Mr. Mignogna. Please feel free to call me if you think
we can work this out.
--Ty

Google Drive with all the Court docs (You're Welcome)
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