gollumm
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- 2 de Sep, 2024
It just dropped: https://www.courtlistener.com/docket/69650487/177/doe-v-bonnell/Did she submit a response? Or try to? Doesn't seem like it from the docket.
Based queen waiting until the very last few hours
Edit:
Case Update: Jane Doe v. Steven K. Bonnell II (Destiny) — Plaintiff Responds to Defendant’s Motion for Protective Order
Filing: Plaintiff’s Response to Defendant’s Motion for Protective OrderCourt: U.S. District Court, Southern District of Florida
Case No.: 1:25-cv-20757-JB/Torres
Date Filed: November 2025
Full Document: Link to PDF
Background
- The Defendant (Bonnell/Destiny) filed a Motion for Protective Order asking the court to block or reschedule certain depositions.
- The Plaintiff (Jane Doe) just filed her response, arguing that the Defendant is misrepresenting the situation and that his request should be denied.
The Dispute
The issue is mainly about scheduling depositions — when and how both parties and witnesses will be questioned under oath.- Plaintiff’s counsel says they repeatedly offered reasonable dates for everyone’s depositions.
- Plaintiff (a student living in Illinois) couldn’t attend an in-person deposition in Miami in October, so she suggested:
- Remote options, or
- In-person dates around Thanksgiving (Nov 21, 24, 25) to avoid missing class and minimize travel costs.
- Defendant’s counsel insisted on early November, then unilaterally noticed her deposition for Nov 3, even though she’d said she wasn’t available.
- Plaintiff’s team had already confirmed Defendant’s own deposition for Nov 6, but on the eve of it, Defendant’s side refused to appear unless Plaintiff first showed up on Nov 3.
Plaintiff’s Argument
- No good cause for a protective order under Rule 26(c).
- Discovery abuse: Defendant’s side ignored agreed-upon scheduling, imposed one-sided conditions, and demanded depositions be back-to-back purely for convenience.
- Plaintiff says she’s acted in good faith and shouldn’t be sanctioned — she’s just trying to get the depositions done within the existing deadlines.
Plaintiff’s Proposed Schedule
Plaintiff offers new dates to finish discovery by the Dec 16 deadline:| Event | Proposed Date | Location |
|---|---|---|
| Plaintiff’s Deposition | Nov 24 or 25 | Miami |
| Non-party witness (TX) | Dec 3 | Remote |
| Non-party witness (DC) | Dec 8 | Remote |
| Defendant’s Deposition | Dec 10 or 11 | Miami |
| Plaintiff’s Expert | Dec 16 | Miami |
| Mediation | Dec 17 or 19 | Miami |
What Plaintiff Wants the Court to Do
- Deny Defendant’s motion for protective order
- Reject Defendant’s request for sanctions
- Order the parties to set reasonable, mutually agreed dates for depositions
TL;DR
Plaintiff says Defendant’s motion is based on a false narrative — that he’s the one refusing to cooperate. She argues she’s offered multiple reasonable dates, while his team is using scheduling tactics to delay discovery and pressure her. She asks the court to deny his motion and let the depositions proceed fairly.Archivos adjuntos
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