No proportionality, no deposition.

The Fifth Court granted a mandamus petition about a corporate-representative deposition, when “proportionality” was not shown, given the corporation’s other information disclosures: “Safeco supported its proportionality objection with evidence. Safeco provided the trial court with a business record affidavit and two hearing exhibits, one containing a chain of e-mails between counsel and the other containing its supplemental responses to Taiwo’s request for disclosure. Further, the declaration of Barbara Spearman, Senior Complex Resolution Specialist IV for Safeco, stated that Safeco had produced and disclosed ‘1,208 pages of responsive documents and things in this matter, including its entire, unprivileged claim file, which included Plaintiff’s Policy, correspondence between the parties, the police report stemming from the accident and witness statements regarding the Accident.’” In re Safeco, No. 05-21-00873-CV (May 10, 2022) (mem. op.).