Thank you for your question. Please allow me to assist you with your concerns.It is not necessary to file a motion to quash in this instance. It is not a subpoena, it is a request to depose, which is somewhat different. There is no requirement under Ohio rules to respond to this 'notice of discovery', you can simply choose to be deposed as the opposing party is requesting.Good luck.
Thank you for your follow-up.In that case you would need to file for a quash of notice of deposition on the basis of the deposition being inconvenient. Typically if you have to travel more than 250 miles, a request to do the deposition via teleconference, or at the expense of the deposing party (travel, time, etc...) are reasonable demands. You can demand that they come to you but as that travel is unreasonable and expensive, you can request instead that the judge either permit you to testify via skype or other mediums, or they come to you for the deposition.Good luck.
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