The motion court erred in denying plaintiff's motion to compel the deposition of Agnes Zamor. Ms. Zamor was defendant's only locker room attendant on the day of the incident in which plaintiff was injured. Obtaining her testimony as to the condition of the bathroom on that date was therefore vital. Defendant suggests that Ms. Zamor's deposition is unnecessary because according to Mr. Mulroy, defendant's Executive Director of Facility Operations, other employees reported to...
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