QUESTION(S)

Attorney Pascal Chastain has received a notice of trial in the case of Jensch v. Quenzer. The trial will be held in 90 days. Numerous depositions have been taken in the case, but one more is necessary for the trial. It is the deposition of the eyewitness in the matter and is the most important deposition. The bill for the previous depositions exceeds $1,000 and has not been paid. Pascal's client originally agreed to pay the bill but now says he is unable to do so. In addition, the client has not paid his legal fees to Pascal's firm in three months and says he cannot do so. The court reporting service will not provide any more services to the firm until its bill is paid. All discovery must be completed 30 days before trial. What should Pascal do?