EFTA00286335.pdf
EFTA00286335
Epstein v. Rothstein & Edwards
Case No.: 50-2009 CA 040800 AG
SCHEDULE OF UPCOMING DEPOSITIONS
DATE TIME LOCATION DESCRIPTION NOTES
5/17 (Tentative) 10:00am FWB -Miami Office Our Dego of
5/23 9:00am Los Angeles, CA Edwards' depo of We are filing a Motion
(PST)/ Alfred Seckel to Quash the
12:00 pm Subpoena
(EST)
5/25 10:30 am Dewey a LeBouef Our Deposition duces
(NY) 1301 Avenue of the tecum of AJ DiScala
Americas
NY NY
EFTA00286336
Epstein v. Rothstein
Case No.: 50-2009 CA 040800 AG
SCHEDULE OF UPCOMING HEARINGS
DATE TIME DESCRIPTION NOTES
5/10 1:30pm Bankruptcy Court Hearing on Qtask's Motion for Stay of
Order Denying Reconsideration of Order Granting TTEE's
Motion to Compel and Qtask's Compliance with Deposition
EFTA00286337
5/19 9:30am Case Management Conference - Judge Crow will hear all
(all day) pending discovery motions and motions re privilege issues
as follows:
Our Motions:
1). Motion to Compel/Motion to Determine if Priv Claims
are Waived;
2). Motion for Protective Order re Video Depo of JEE;
3). Motion to Quash Subpoena and For Protective Order re
Depo of Alfred Seckel;
4). Amended and Supplemental Motion to Overrule
Objections and Compel Edwards to Answer Questions and
Appear for Further Deposition;
5). Motion for Protective Order to Preclude Scarola Et
Edwards from making Extra Judicial Statements and
Commentary to the Media and Press (Judge Crow)
Edwards' Motions:
1). Motion to Dismiss the Amended Complaint;
2). Motion for Protective Order and Objections to
Canceled Notice of Taking Deposition and Appointment of
Special Master;
3). Motion to Assert Punitive Damage Claims;
EFTA00286338
4). Motion for Reconsideration of Order Sustaining
Plaintiff's Objections to Discovery dated December 22,
2010;
5). Motion to Compel and Impose Sanctions for Epstein's
Failure to Appear for Deposition;
Non-Party Motions:
1). Spencer Kuvin's Motion for Protective Order and
Objection to Subpoena for Joint Privilege Documents;
2). Non-Party Podhurst a Orseck, P.A.'s Motion for
Protective Order and Stay Order.
EFTA00286339
Epstein v. Rothstein
Case No.: 50-2009 CA 040800 AG
CALENDARED DEADLINES
DATE DEADLINE DESCRIPTION NOTES
5/2 Epstein must file and serve his response to Edwards' Addt'l
Interrogatory served by fax on 4/1/11
5/2 All parties must file any addt'l motions relating to discovery
or privilege issues per Case Management Order
5/6 All parties must deliver an updated list on all motions to be
heard at the 5/19 Case Managment Conference
5/9 All parties must file their responses to any addt'l motions
relating to discovery or privilege issues which were filed by
5/2 and will be heard at the 5/19 Case Mgmt. Conference
5/11 Each party must deliver a copy of each of their motions and
any responses filed thereto to the court in advance of the
5/19 Case Management Conference
5/16 Epstein's Response to Edwards RTP due (Faxed 4/15)
Epstein v. Rothstein & Edwards
Case No.: 50-2009 CA 040800 AG
SCHEDULE OF UPCOMING DEPOSITIONS
DATE TIME LOCATION DESCRIPTION NOTES
5/17 (Tentative) 10:00am FWB -Miami Office Our Dego of
5/23 9:00am Los Angeles, CA Edwards' depo of We are filing a Motion
(PST)/ Alfred Seckel to Quash the
12:00 pm Subpoena
(EST)
5/25 10:30 am Dewey a LeBouef Our Deposition duces
(NY) 1301 Avenue of the tecum of AJ DiScala
Americas
NY NY
EFTA00286336
Epstein v. Rothstein
Case No.: 50-2009 CA 040800 AG
SCHEDULE OF UPCOMING HEARINGS
DATE TIME DESCRIPTION NOTES
5/10 1:30pm Bankruptcy Court Hearing on Qtask's Motion for Stay of
Order Denying Reconsideration of Order Granting TTEE's
Motion to Compel and Qtask's Compliance with Deposition
EFTA00286337
5/19 9:30am Case Management Conference - Judge Crow will hear all
(all day) pending discovery motions and motions re privilege issues
as follows:
Our Motions:
1). Motion to Compel/Motion to Determine if Priv Claims
are Waived;
2). Motion for Protective Order re Video Depo of JEE;
3). Motion to Quash Subpoena and For Protective Order re
Depo of Alfred Seckel;
4). Amended and Supplemental Motion to Overrule
Objections and Compel Edwards to Answer Questions and
Appear for Further Deposition;
5). Motion for Protective Order to Preclude Scarola Et
Edwards from making Extra Judicial Statements and
Commentary to the Media and Press (Judge Crow)
Edwards' Motions:
1). Motion to Dismiss the Amended Complaint;
2). Motion for Protective Order and Objections to
Canceled Notice of Taking Deposition and Appointment of
Special Master;
3). Motion to Assert Punitive Damage Claims;
EFTA00286338
4). Motion for Reconsideration of Order Sustaining
Plaintiff's Objections to Discovery dated December 22,
2010;
5). Motion to Compel and Impose Sanctions for Epstein's
Failure to Appear for Deposition;
Non-Party Motions:
1). Spencer Kuvin's Motion for Protective Order and
Objection to Subpoena for Joint Privilege Documents;
2). Non-Party Podhurst a Orseck, P.A.'s Motion for
Protective Order and Stay Order.
EFTA00286339
Epstein v. Rothstein
Case No.: 50-2009 CA 040800 AG
CALENDARED DEADLINES
DATE DEADLINE DESCRIPTION NOTES
5/2 Epstein must file and serve his response to Edwards' Addt'l
Interrogatory served by fax on 4/1/11
5/2 All parties must file any addt'l motions relating to discovery
or privilege issues per Case Management Order
5/6 All parties must deliver an updated list on all motions to be
heard at the 5/19 Case Managment Conference
5/9 All parties must file their responses to any addt'l motions
relating to discovery or privilege issues which were filed by
5/2 and will be heard at the 5/19 Case Mgmt. Conference
5/11 Each party must deliver a copy of each of their motions and
any responses filed thereto to the court in advance of the
5/19 Case Management Conference
5/16 Epstein's Response to Edwards RTP due (Faxed 4/15)