February 2017, Los Angeles. Plaintiffs alleged their decedent was exposed to toxins by LBL’s client. During the pendency of the litigation, LBL Partner Guy W. Stilson filed a summary judgment motion. While the motion was pending, the client dissolved and terminated the employment of all its officers, directors, and personnel. Plaintiffs served a notice of the deposition of LBL’s client, and Stilson responded with a motion to quash the notice because the client no longer had any employees. Plaintiff opposed, arguing that the summary judgment motion was supported by a declaration from the client’s president. Stilson argued that the motion was filed before the president’s employment had been terminated but the deposition notice was not served until after the termination of the president’s employment. The court agreed that when the deposition notice was served the client was incapable of producing a responsive witness and quashed the deposition notice.