in Re Allen J. Jones
The plaintiff, Cearth Faire, filed a reply to the defendants' response regarding her motion to compel the deposition of defendant Allen J. Jones. Faire argues that Jones has a history of legal misconduct, including judicially admitted human trafficking and holding his infant son hostage, which indicates he will not appear for a deposition without a court order. She asserts she has shown due diligence in attempting to depose Jones and refutes the defendants' allegations that her motion is merely an attack on Jones' character. Faire requests the court to deny the defendants' request for attorney fees and grant her motion to compel Jones' deposition, which is noticed for October 27, 2015.