[Epah], I am not prepared to proceed with the deposition of [client] on January 23, 2025 absent being in receipt of the further and better responses to the requests for admission, requests for productions and interrogatories, together with any further documents to be produced in furtherance of such further and better responses, as set forth in this letter, by no later than January 17, 2025. If that cannot occur, please let me know that by January 15, 2025 and I will then cancel the deposition and reschedule it for a time after the receipt of the further and better supplemental responses (and nay corresponding documents to be produced) are received, either voluntarily from [client] and/or after any necessary motions to have them compelled. Notwithstanding the above, we will likely need to address this with the Judge at the Case Management Conference on January 10, 2025 in terms of letting the Court know what is going on in terms of discovery so hopefully you will have some idea how your client intends to respond by then.

In terms of your substantive response to this correspondence (absent your indication by January 15, 2025 that the further and better responses to the requests for admission, requests for productions and interrogatories, together with any further documents to be produced in furtherance of such further and better responses, as set forth in this letter, will be provided and produced by no later than January 17, 2025), then please provide a response by no later than January 20, 2025 as to which further and better supplemental responses will provided any by what dates, and which will not, so I can determine what will need to be compelled by motions seeking appropriate relief, including without limitation, sanctions.

(http://www.autoadmit.com/thread.php?thread_id=5661725&forum_id=2:#48537793)

That's how you know he's serious.

(http://www.autoadmit.com/thread.php?thread_id=5661725&forum_id=2:#48537806)