Virginia GAMBALE, Plaintiff, v. DEUTSCHE BANK AG and Bankers Trust Company, Defendants No. 02 Civ.4791 HB DFE United States District Court, S.D. New York November 21, 2002 Eaton, Douglas F., United States Magistrate Judge MEMORANDUM AND ORDER *1 On November 13, 2002, Judge Harold Baer, Jr. referred this case to me for general pretrial supervision and for a ruling on any discovery motion or other motion which does not require a report and recommendation. This means that I will make decisions about the discovery phase of the litigation, but not about motions to dismiss such as motions pursuant to Rule 12(b) or Rule 56. Judge Baer has given me no power to change his discovery deadline of January 17, 2003. I have reviewed Ms. Raskin's November 8 letter to Judge Baer and Ms. Cohen's November 18 letter to me. I make the following rulings. Requests Nos. 10 and 21. I rule that the defendants need not produce any more documents in response to these two requests. Requests Nos. 14 and 19. By December 2 (by fax or by hand), the defendants must serve an affidavit explaining (a) what steps they have taken to search their paper and electronic files for documents responsive to Requests Nos. 14 and 19, and (b) the feasibility and cost of retrieving e-mails sent by or to Michael Cohrs concerning the E–Business Steering Committee, and (c) the feasibility and cost of retrieving e-mails responsive to Request No. 19. At that point, plaintiff has two options: (1) she can consent to the protocol set forth by Magistrate Judge Francis in Rowe Entertainment v. William Morris Agency, 205 F.R.D. 421 (S.D.N.Y.2002), with the slight modification set forth in Murphy Oil USA, Inc. v. Fluor Daniel, Inc., 2002 WL 246439 at *7–9 (E.D.La. Feb. 19, 2002), or (2) she can argue for a different protocol by conferring with her adversary and sending me a single joint letter outlining the parties' positions on this issue. Requests Nos. 15 and 16. I hereby combine and modify these two requests into a Modified Request No. 15, which reads as follows: “Provide copies of the following documents from the personnel file of Michael Cohrs: his performance reviews (formal or informal) as well as drafts or versions of those reviews; documents concerning his educational background and other qualifications; documents reflecting the termination of his employment in any position from the beginning of his career with the defendants; and documents reflecting the number and/or titles of employees whom Cohrs supervised in each of his positions.” I direct the defendants to provide these documents by December 2 (by hand). Request No. 24. The defendants have agreed to produce the quarterly reports reflecting the performance of DBCVP investments. I direct them to do so by November 25 (by hand). Request No. 25. I rule that the defendants need not produce any more documents in response to this request. Request No. 26. I sustain the defendants' objection. Requests Nos. 27 and 28. I hereby combine and modify these two requests into a Modified Request No. 27, which reads as follows: “Provide copies of the following documents from the personnel file of William Burgess: his performance reviews (formal or informal) as well as drafts or versions of those reviews; documents concerning his educational background and other qualifications; documents reflecting the termination of his employment in any position from the beginning of his career with the defendants; and documents reflecting the number and/or titles of employees whom Burgess supervised in each of his positions.” I direct the defendants to provide these documents by December 2 (by hand). *2 Request No. 29. I rule that the defendants need not produce any more documents in response to this request. Request No. 35. By December 2 (by hand) each defendant must produce “a financial affidavit containing a statement of its total net worth and listing its income, assets, and liabilities for the past three years.” Hamm v. Potamkin, 1999 WL 249721 at *3 (S.D.N.Y. Apr. 28, 1999) (Sweet, J.). Interrogatories Nos. 2 and 4. I direct the defendants to answer these two interrogatories completely, by November 25 (by hand). Interrogatory No. 12. I rule that the defendants' answer is adequate. Sundaram v. Brookhaven Nat. Laboratory, 1996 WL 563829 at *2 (E.D.N.Y. Mar. 11, 1996) (Pohorelsky, M.J.). Interrogatory No. 23. In view of the answers to Interrogatories Nos. 10, 11, 14–16, 21 and 22, I sustain the defendants' objection to Interrogatory No. 23. Location of the Deposition of William Burgess. Plaintiff does not dispute that her current supervisor, William Burgess, lives and works in Boston and is the single father of three young children. I direct that the deposition take place in Boston. The defendants shall reimburse the plaintiff for either (a) the cost of holding the deposition by video or (b) the cost of one attorney's transportation plus $300 toward any hotel expense. I enclose (by mail) a copy of my Standing Order for Discovery Disputes. The Standing Order sets out my rules for disputes about discovery, including disputes about scheduling. In the event any such disputes arise in the future, the parties must follow that Standing Order.