With no explanation, chose the best option from "A", "B", "C" or "D". listing testimony topics, Aristocrat's subpoenas seek documentary evidence. The Bondholders correctly argue that Aristocrat may not seek document production after the discovery cut-off. See McKay v. Triborough Bridge and Tunnel Auth., No. 05 Civ. 8936, 2007 WL 3275918, at *2 (S.D.N.Y. Nov. 5, 2007) ("parties may not issue subpoenas ‘as a means to engage in discovery after the discovery deadline has passed.' ") (citing Dodson v. CBS Broadcasting, Inc., No. 02 Civ. 9270, 2005 WL 3177723 (S.D.N.Y. Nov.29, 2005)). Aristocrat's argument that these new documents would be used as trial exhibits is of no moment since Aristocrat's document requests are broad and, in many instances, call for "all documents” relating to several issues (Int. Defs.’ Mem. Ex. E.) See Dodson, 2005 WL 3177723, at *3 (<HOLDING>). 3 . The Bondholders move in limine to limit

A: holding that a request for admission is a tool of discovery subject to discovery cutoff dates
B: recognizing that rule 45 can be used to subpoena documents to be introduced at trial as trial exhibits but rejecting plaintiffs argument that documents sought after the discovery cutoff were for use as trial exhibits where the scope of the request is broad and clearly is designed for discovery not lastminute trial needs such as for originals of documents where copies were produced in discovery and there is a need for the original at trial
C: holding if a deposition is taken for discovery only  not for use at trial the deposition is not a stage of trial for which the defendant must be present
D: holding that where original documents were illegally seized those documents as well as all copies had to be returned
B.