Free Motion to Compel - District Court of Connecticut - Connecticut

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ase 3:03-cv-01009-SRU Document 77 Filed O2/22/2005 Page1 of 2
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UNITED STATES ‘;_Z{`sE 1. L l
- T OF CONNECTICUT l
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JOSEPH ATTIAS & HAIM ATTIAS : CIVIL NO. 3:03 CV 01009 (SRU)
Plaintiffs 2

PATRONS MUTUAL INSURANCE :
COMPANY OF CONNECTICUT ; .
Defendant : February 18, 2005 . E
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MOTION TO COMPEL DISCLOSURE,
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Pursuant to Rule 37 (a) of the Federal Rules of Civil Procedure, the Plaintiffs hereby move the
Court for an order compelling the Defendant to produce unredacted copies of claims tiles on Fire loss
. claims for dates of loss of I2/4/03 and I0/8/03 which were received in discovery redacted from the l
defendant. It is the pIaintiI`fs’ contention that those files help establish the pattern ofconduct at issue in this
` case and accordingly the plaintiffs should be able to investigate those claims by contacting the insureds and
attorneys involved. Currently the files are redacted, hiding identifying information including reference to
the location of the properties, the names and contact information of the insureds and attomeys that
represented the insureds in those matters. The defendant has claimed an obligation to protect the privacy i
of their insureds in the past, however has not offered any legal support for that position. Undersigned
counsel for the plaintiffs contacted Attorney Heather Adams-Beman to determine whether the defendant _ 7
would be willing to produce unredacted copies of those files. As of the time of this filing no response has
be received from the defendant. _
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ase 3:03-cv-01009-SRU Document 77 Filed O2/22/2005 Page 2 of 2 _ .
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Wherefore the Plaintiffs moves the Court to order the defendant to produce unredacted copies of ·
the claims files for dates of loss 12/4/03 and 10/8/03 previously produced in compliance with discovery
requests in redacted form. I
THE PLAINTIFF,
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BY __+ _____ .
Ch ·. Hefferi i
Farver & Heff i
2842 Old Dixwell Avenue \
· Hamden, Connecticut 06518 I
Telephone: 203-288-8266
Facsimile: 203-288-4702 5
Fed Bar No.:CT 06473 .
QERTIFICATION T
I hereby certify that a copy ofthe ibregoing was sent by first class mail, postage prepaid this l8"`
day of February 2005, to:
Heather Adams—Be1nan, Esq.
Joel Rottner, Esq.
Skelley Rottner P.C.
PO Box 340890 .
i’iZ11`ff0I`€i,CT 06l34—0890
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Cheryl E. H an T ‘ t
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