Free Motion to Compel - District Court of Connecticut - Connecticut

Case 3:03-cv-00636-JBA

Document 23

Filed 02/25/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT EVELINE GOINS v. JBC & ASSOCIATES, P.C. ET AL. CASE NO. 3:03CV 636 (JBA)

February 25, 2004

PLAINTIFF' MOTION TO COMPEL S DEPOSITION AT THE COST OF DEFENDANTS Pursuant to Fed. R. Civ. P. 37(a), and 34(b), Plaintiff moves to compel defendant Boyajian to appear for a deposition in New Haven, and to pay all costs of the deposition, including plaintiff'attorney'fees. As the Court was informed on February 12, 2004, Mr. s s Boyajian'deposition had been noticed for February 26, 2004. As has repeatedly occurred in s the three Goins litigations, defense counsel announced the deponent was " unavailable." Discovery herein ends on March 1, and defendants have yet to provide significant information, particularly how the $10,000 figure was reached as the amount owing on a Wilson Suede & Leather account which had been substantially less just a year earlier. See discovery responses appended to Motion for Rule 37 Orders filed Feb. 2004. THE PLAINTIFF ORAL ARGUMENT IS NOT REQUESTED BY___/s/ Joanne S. Faulkner______ JOANNE S. FAULKNER ct04137 123 Avon Street New Haven, CT 065l1 (203) 772-0395 [email protected]

Case 3:03-cv-00636-JBA

Document 23

Filed 02/25/2004

Page 2 of 2

This is to certify that the foregoing and attached was mailed on February 24, 2004, postage prepaid, to: Jonathan D. Elliot Sabatino Fiano P. O. Box 763 Southport CT 06490

__/s/ Joanne S. Faulkner______ Joanne S. Faulkner