Free Affidavit - District Court of Connecticut - Connecticut

Y ase 3:03-cv-01009;%RU Document 50 Filed 06/Z?2004 Page 1 of 3 .
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By .. _,_.;_;~;»;» _ UNITED STATES DISTRICT COURT {
. · msriucr or connacrrcnr N
tosapn ATTIAS a HMM Artrras ; crvn. No. ms cv 01009 (san) }
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Plaintiffs :
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PATRONS MUTUAL INSURANCE ;
COMPANY or CONNECTICUT ; N
Defendant : TUNE 21, 2004 W
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AFFIDAVIT or coUNsEL {
Pursuant to Local Rule 9 of the District of Connecticut the undersigned counsel i
for the plaintiffs hereby submits the following affidavit in support of the Plaintiff`s motion to I
compel disclosure dated June 21, 2004. _
STATE OF CONNECTICUT} 1
} at Hamden, June 21, 2004 I
COUNTY OF NEW HAVEN} i
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I, Cheryl E. Heffernan, having been sworn hereby depose and say:
1. I am over the age of eighteen and believe in the obligations of an oath;
2. The information contained herein is true to the best of my knowledge and I
basis on personal knowledge; `
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3. I am counsel for the plaintiffs Joseph and Hiam Attias the matter of Atttus
v. Patrons Mutual Insurance of Connecticut pending in the United State
District Court for the District of Connecticut; ,
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ase 3:03-cv-O100%Sj2U Document 50 Filed 06/22(2qO4 Page 2 of 3
4. By way of requests for discovery dated February 23, 2004 I, on behalf of i
the plaintiffs requested infomation and documents relative to tire loss T
claims on insurance policies issued by defendant during a particular period
of time.
5. Responses to these request were due on March 23, 2004.
6. No responses to the discovery requests were received in a timely fashion i
and no requests for additional time to file responses were received until
after the undersigned sent a fax on March 30, 2004 demanding
compliance. E
7. On April I3, 2004 as part of the defendant’s compliance the defendant j
objected to providing information or documentation as requested relative i
to other tire loss claims
8. On receipt of said "compliance" I wrote counsel for the defendant on April ,
13, 2004 requesting the compliance again. Compliance has not been l
received. I
9. Thereafter I had turther conversation with Attorney Rottner for the l j
defendant in regard to provide some compliance. _
10. By way of a pleading dated June 7, 2004, the defendant tile additionally
objections to the discovery requests. . j
l 1. Wherefore the undersigned submits that good faith efforts have been made j
to resolve the defendant’s objection to requested discovery . q
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Chery . l-Leffernan
Sworn to before me this 21** day of June, 2004.
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T omas E. . a<.e·= " T
Commis f the Superior Court j
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ase 3:03-cv-O1OOQ=Si¥U Document 50 Filed 06/22(2804 Page 3 of 3
CERTIFICATION I
I hereby certify that a copy of thc foregoing was sent by first class mail, postage prepaid
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this 21S` day of June 2004, to: i
Heather Adams-Beman, Esq. E
Joel Rottner, Esq. `
Skelley Rottner P.C. =
PO Box 340890 ·
Hartford, CT 06134-0890 . N
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