Woman submits motion to quash former employer's deposition notice into wrongful termination lawsuit

GALVESTON - A Travis County woman who sued her employer for terminating her because she reported illegal workplace activities is fighting a notice of deposition and subpoena for production of evidence.

Regina Alderete alleged last June that when she was employed with A-MED Management Inc. she “witnessed several actions she believed to be contrary to company policy” and “outwardly” confronted and complained about these activities on numerous occasions.

According to her lawsuit, the defendant retaliated against her by creating “a hostile and unbearable work environment” prior to dismissing her as its community relations coordinator on Feb. 21, 2012.

A-MED formally countered the allegations as well as entered a motion for final summary judgment.

Alderete then amended her original petition to include Nurses to Go Inc.

The plaintiff non-suited A-MED before then-Galveston County 10th District Court Judge David Garner junked the litigation with a dismissal for want of prosecution on Nov. 21, 2012.

Judge Garner later reinstated the case, which has Nurses to Go as the sole respondent, toward the end of last year.

Alderete's motion shows Nurses to Go served its notice to appear on June 21 "without prior consultation" with her counsel.

It also says that the complainant "timely" filed the motion before the date of requested compliance, calling the request "vague, ambiguous, overly broad and unduly burdensome."

"In this matter, the requests are objectionable, because they seek 'any and all documents,' the three-page document argues.

An order is pending.

Case No. 12-CV-1420