Case 09-34791-RBR Doc 3002 Filed 04/18/12 Page 1 of 19 UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov In re: ROTHSTEIN ROSENFELDT ADLER, ■., Debtor. CASE NO.: 09-34791-BKC-RBR CHAPTER 11 TRUSTEE'S PROPOSED PROTOCOLS FOR ROTHSTEIN SECOND DEPOSITION Herbert Stettin, Chapter 11 Trustee ("Trustee") for Rothstein Rosenfeldt Adler, ■. ("RRA") submits the following proposed protocols for use in the Second Deposition of Scott Rothstein (the "Deposition"): I. EXISTING ADMINISTRATIVE ISSUES TO RESOLVE. 1. Given the complexities of communicating, negotiating and finalizing a court order with approximately 30 attorneys, the Court should appoint Michael Goldberg, counsel to the RRA Creditors Committee, plus 2 or 3 other attorneys (collectively "Defense Lawyers") to work on behalf of all other parties and with counsel to the Trustee, in order to quickly and collaboratively finalize future deposition protocol related orders or resolve other Deposition related issues. 2. The Defense Lawyers should be required to formulate a universal set of Deposition questions that apply to every adversary case on the somewhat common defense issues including, but not limited to property of the estate, solvency and good faith. The Trustee shall have a similar obligation to prepare his own list of questions on issues common to all adversary cases. At the Deposition, one lawyer should either be selected by the Defense Lawyers or the Court to ask all such questions on behalf of all adversary defendants. Perhaps this part of the 1 EFTA01082221