Contract analysis

I. Introduction and Purpose of Letter Defendant Stonefield Logistics Group Inc. ("Stonefield" or "SLG"), by and through its counsel Calderwood & Harkness LLP, respectfully submits this letter brief in response to Plaintiff Vantor Holdings Corp.'s ("Vantor" or "Plaintiff") motion to compel the completion of the deposition of Nikolai Vantorovich, Chief Executive Officer and Founder of Vantor Holdings Corp., filed on Se

II. Background and Procedural History of the Vantorovich Deposition A. Scheduling and Notice Consistent with the deposition schedule agreed upon by the parties during discovery and discussed at the parties' Rule 26(f) conference and at subsequent meet-and-confer sessions, Stonefield served a notice of deposition on Vantor for the deposition of Nikolai Vantorovich. The deposition was properly noticed pursuant to Feder

III. Stonefield Does Not Oppose Completion of the Deposition To be clear and to remove any ambiguity, Stonefield states unequivocally that it does not oppose the completion of Mr. Vantorovich's deposition. Stonefield affirmatively desires to complete the examination of this witness, and the instant motion is in complete alignment with Stonefield's own position that the deposition must go forward. The deposition testi

IV. Request for Full Seven Hours of Examination Time A. The Circumstances Warrant Expanded Time Under Federal Rule of Civil Procedure 30(d)(1), "[u]nless otherwise stipulated or ordered by the court, a deposition is limited to 1 day of 7 hours." The Rule further provides that "[t]he court must allow additional time consistent with Rule 26(b)(1) and (2) if needed to fairly examine the deponent or if the deponent, anot

V. Proposed Scheduling Stonefield respectfully requests that the Court order the completion of Mr. Vantorovich's deposition on or before October 20, 2023. The deposition should take place at a location to be agreed upon by the parties or, absent agreement, at the offices of Calderwood & Harkness LLP, 200 Park Avenue, 38th Floor, New York, New York 10166, which is where the August 18 session was conducted and which pr

VI. Conclusion For the foregoing reasons, Defendant Stonefield Logistics Group Inc. does not oppose Plaintiff Vantor Holdings Corp.'s motion to compel the completion of the deposition of Nikolai Vantorovich. However, Stonefield respectfully requests that the Court enter an order providing the following relief: (1) Ordering the completion of the deposition of Nikolai Vantorovich on or before October 20, 2023, at a loc