Case: Jane Doe v. Steven K. Bonnell II
Court: U.S. District Court, Southern District of Florida
Filing: Defendant’s reply regarding deposition scheduling dispute
What This Filing Is About
The Defendant (Bonnell) filed a reply arguing that the Plaintiff (Doe) improperly failed to show up for her scheduled deposition. He says she never filed a protective-order motion to delay or change the deposition and instead just refused to attend.
The court had ordered Doe to explain why she didn’t move for a protective order earlier and to show “good cause” for missing the deposition. Bonnell’s reply responds to her explanation.
Key Points From the Defendant
1. Plaintiff never filed a protective order when the dispute arose.
- Defendant argues that under Rule 26(c) and Rule 37(d), a party must seek a protective order if they want to avoid or alter a scheduled deposition.
- Doe didn’t do this—she simply didn’t show up.
- He says the cases she relied on (like Iguana LLC) don’t excuse her non-appearance.
2. Plaintiff’s reasons don’t meet the “good cause” standard.
Doe claimed she couldn’t attend because:
- She had university classes
- Travel was expensive
- She wanted to be deposed remotely or in Illinois
- She only offered dates during Thanksgiving week
Bonnell argues:
- Personal inconvenience isn’t a valid legal excuse.
- Plaintiffs who choose the forum (here, South Florida) are generally expected to appear there for deposition.
- Her alternative dates weren’t reasonable and didn’t comply with the scheduling order.
3. Defendant was prejudiced by the missed deposition.
- His legal team prepared for the deposition and incurred fees, travel costs, and other expenses.
- He argues the Plaintiff’s actions wasted resources and delayed case progress.
What the Defendant Wants the Court to Do
- Order the depositions to take place in Miami during the same week (he suggests Nov. 24–25, 2025).
- Award attorney’s fees and costs associated with bringing the motion.
- Confirm that Plaintiff must comply with deposition obligations in the chosen forum.
Bottom Line
Bonnell’s filing argues that Doe:
- skipped her deposition without filing the required motion,
- failed to show good cause after the fact,
- offered unreasonable alternative dates,
- and caused unnecessary costs.
He asks the court to enforce the deposition schedule and impose fees.
