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	Bishop Richard Sklba's Brief in Support of Motion for Protective Order By Patrick W. Brennan Circuit Court November 23, 2010 http://www.bishop-accountability.org/legal/2010_11_23_Brennan_pro_Skbla_Protective_Order.pdf [full story] Bishop Richard J. SkIba has legitimate, protectable, personal interests in not having his deposition taken while appeals and mediation are pending. A protective order that his deposition not be had at this time is necessary to prevent oppression, undue burden, expense and prejudice to the Bishop. His deposition should not go forward while appeals of other Archdiocese of Milwaukee cases are pending, and until such time as he can be deposed once and for all, in each filed case. Wisconsin Statutes preclude depositions while appeals are pending, and an order permitting depositions of witnesses who are 75 years of age or older has only been entered in Case No.07-CV-10888. If Bishop Sklba's deposition is permitted at this time, the Court should further order that his deposition transcript, exhibits and video be sealed, and that the scope of the deposition be limited. Such an order is necessary because Bishop SkIba has recently retired and should not be put to the undue personal burden, expense and prejudice of multiple deposition appearances. Personal prejudice and reputational harm to Bishop SkIba may result from public dissemination of deposition transcript, exhibits and video. By its very nature the cross examination in a deposition is a one-sided process that does not permit a full airing of the evidence that ultimately will be revealed at trial. Plaintiffs' counsel has already publicly posted Archbishop Rembert Weakland's deposition transcript and exhibits on their law firm's website, as well as posting the deposition video on YouTube.. . . For all of the reasons stated above, the Archdiocese respectfully requests that the Court grant its motion for a protective order.
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