Per a source with knowledge of the situation, the lawyers for Saints running back Reggie Bush plan to file in the near future a motion to force Lloyd Lake to submit to deposition questioning on February 22.

Lake’s deposition started on February 12, but the session quickly ended due to the presence of a private security guard in the office where the deposition was to be conducted.  Even after the security guard left the floor, Lake refused to proceed.

In support of their position that security is justified for the Lake deposition, Bush’s lawyers plan to allege that Lake told an unidentified witness the following:  “You are Reggie Bush’s boy, ain’t you?  You ain’t even supposed to be in San Diego.  Tell your boy when he comes back to San Diego, he is dead.”  (We’re told that the matter has been referred to law enforcement personnel, who have requested that the identity of the witness not be revealed.)

Bush’s lawyers also plan to allege that Lake made another threat against Bush during the same week in which Redskins safety Sean Taylor was killed by an intruder to his home, that Lake is a documented member of the “Emerald Hills Bloods” street gang, and that Lake once was found to be in possession of an Uzi sub-machine gun. 

Finally, Bush’s lawyers plan to attack the notion that Lake was intimidated by the security guard, based on part on an allegation that Lake appeared on a San Diego-area talk radio show on February 13 and said that he was “not afraid” of the security guard.

With all that said, we’re still not comfortable with the notion of a heat-packing private security guard showing up at a deposition in a law office without advance notice, even in the face of credible threats.  Bush’s lawyers should have made arrangements to conduct the deposition at the courthouse where the lawsuit is pending, and Bush’s lawyers should have made arrangements to have one of the courthouse bailiffs attend the session.