Foreclosures—Former Mayor Bill de Blasio Must Appear for Deposition—Foreclosure Transfer Program—Plaintiffs Alleged That Municipal Defendants “Discriminated Against Minority Homeowners and Neglected To Provide Adequate Notice Prior To Seizing Their Property”—Parties Must Demonstrate “Exceptional Circumstances” Justifying the Deposition of a “High-Ranking Government Official”—Must Show That the Official Has “Unique First-Hand Knowledge Related to the Litigated Claims or That the Necessary Information Cannot Be Obtained Through Other, Less Burdensome or Intrusive Means”—Other Municipal Officials “Offered Vague Testimony as to Mr. de Blasio’s Motivations for Continuing” the Foreclosure Program—Pre-Motion Letters May Be Construed As “Motions, Provided All Parties Are Given Notice and Opportunity To Be Heard On the Substantive Issues”

The plaintiffs had commenced an action with respect to the city’s “operation of the Third-Party Transfer Program (TPTP), through which the city forecloses on tax-delinquent properties and transfers them to third-party real estate developers.” They alleged that the municipal defendants (defendants) “discriminated against minority homeowners and neglected to provide adequate notice to homeowners prior to seizing their property.”