Liaison Counsel

Deposition Scheduling Under the New CMO 

10/31/18 - Due to the recent inordinate number of requests for emergency depositions of in extremis plaintiffs, please be reminded that the CMO mandates that all depositions require at least 20 days notice.  No deposition can be noticed in a case that is not clustered and where answers to interrogatories and authorizations have not been served.  Scheduling liaison does not have authority to approve depositions that do not comply with the provisions of the CMO.  All applications for depositions that do not comply with the provisions of the CMO must be made to the Special Master with a copy to scheduling liaison and all named defendants.

ref: CMO Section XI Depositions, pages 19-24

From the Special Master - 

As you know Section  XI , subsection B  of the CMO dated June 20, 2017 provides that" all depositions of parties and witnesses shall be held in New York City unless otherwise ordered by the Special Master" (emphasis added).  Plaintiff counsel who wish to depose a witness or party outside of a 50 mile radius of New York County must provide medical certification as to why the witness or party is unable to travel, unless plaintiff is diagnosed with mesothelioma in which case proof of diagnosis is sufficient.  Certification is required for co-worker depositions as well as plaintiff depositions. 

Pursuant to Section  XI , subsection C of the CMO dated June 20, 2017  "Except for good cause shown to the Special Master no more than 6 depositions shall be scheduled for a single day". In order to comply with the Court's order regarding the number of depositions on any given day,  any party wishing to schedule a deposition  must specify to scheduling liaison the number of days they wish to reserve for  each deposition. Continuations will be included within the maximum number of depositions that can be scheduled in a single day.

All procedures outlined above shall be in effect for all depositions scheduled to occur after July 20, 2017. Scheduling liaison continues to be Marshall Dennehey Warner Coleman & Goggin.  Contact Danielle DiMauro: This email address is being protected from spambots. You need JavaScript enabled to view it.

Authorizations Reminder

Please send authorizations for all cases to Recordtrak. The only group where authorizations should be sent to American Legal Records is the October 2017 in extremis group.

Liaison counsel assigned to individual in extremis clusters:
(unless otherwise indicated, the designated liaison will be handling both discovery and medical issues)

Plaintiffs,

Effective immediately, please submit documents for the upcoming October 2017 Cluster ONLY to the below company either via email or regular mail.

Recordtrak will still be the service provider for all of the other clusters.

American Legal Records
Corporate Headquarters
3748 West Chester Pike
Newtown Square, PA 19073

Contact person: Paul McCarthy (This email address is being protected from spambots. You need JavaScript enabled to view it.)

Direct: (888) 519-8565
Fax: (877) 861-9459 

 Liaison Update: 

Please be advised that for the April 2022 In Extremis clusters and forward, Heather Janis Gaw of Segal McCambridge Singer & Mahoney is handling the Weitz & Luxenberg In Extremis matters (M-Z) as defense Medical and Discovery liaison. Should you have inquiries regarding these cases, please forward them to her attention and not to Diane Miller. Heather’s contact information is located on the Liaison Counsel page. Diane Pompei of Lynch Daskal Emery LLP will continue to handle the A-L matters.