Epstein v. Rothstein &

Epstein v. Rothstein & Case No.: 50-2009 CA 040800 AG SCHEDULE OF UPCOMING DEPOSITIONS DATE TIME LOCATION DESCRIPTION NOTES 5/17 (Tentative) 10:00am FWB -Miami Office igro of 5/23 9:00am (PST)/ 12:00 pm (EST) Los Angeles, CA Edwards' depo of Alfred Seckel We are filing a Motion to Quash the Subpoena 5/25 10:30 am (NY) Our Deposition duces tecum of AJ DiScala EFTA00614736 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 EFTA00614737 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 ■ 3). Motion to Quash Subpoena and For Protective Order re Depo of Alfred Seckel; 4). Amended and Supplemental Motion to Overrule Objections and Compel to Answer Questions and Appear for Further Deposition; n for Protective Order to Preclude Scarola Et from making Extra Judicial Statements and Commentary to the Media and Press (Judge Crow) 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; EFTA00614738 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. EFTA00614739 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 t. Interrogatory served by fax on 4/1/11 5/2 All parties must file any 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 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 t0(TP due (Faxed 4/15) EFTA00614740