Plaintiff Lisa Behrens filed a second “Motion for a Protective Order and Sanctions” as well as a related “Motion to Compel Production” in her lawsuit against the MSB on March 12, 2019.
In these motions, Ms. Behrens complains that the MSB legal team is interfering with her ability to depose witness Sonya Conant, the MSB’s Director of Human Resources.
The motion accuses the MSB of “repeated efforts to disrupt, delay, interfere with, and harass prosecution of Ms. Behren’s case. Two remarkably important depositions have been prevented: first, by (Perkins Coie Attorney) Jared Gardner’s witness tampering/intimidation (of Wm Gamble) and now by Ms. Ryman (Danielle Ryman, the Perkins Coie attorney/partner representing the MSB)’s self-initiated refusal to timely voice objections to deposition dates” for Ms. Conant’s deposition. “Ms. Ryman and her firm are playing games.”
Ms. Behrens is requesting an order from the court “which will allow Ms. Conant’s deposition freed of any consquence the defendants’ have previously orchestrated through their counsel.”
She is also requesting an order compelling the MSB to produce all material related to the MSB’s Human Resources’ investigation of Ms. Behrens’ HR complaint (following the MSB’s notice to her that they planned to terminate her employment.)
The MSB has not yet filed responses to these motions. (Their responses are not due yet.)
Update: The MSB did file a response – but the copy wasn’t in the file yesterday when I copied it. The MSB has also filed a cross motion for sanctions. (Why are the tax payers paying for all of this litigation?! )
Herewith are the Plaintiff’s twin motions re: the HR witness and materials: