Free Motion for Protective Order - District Court of Connecticut - Connecticut

Case 3:03-cv-01009-SRU

Document 40

Filed 04/29/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOSEPH ATTIAS & HAIM ATTIAS VS. PATRONS MUTUAL INSURANCE COMPANY OF CONNECTICUT : : : : : : : : CIVIL ACTION NO. 3:03 CV 01009 (SRU) APRIL 28, 2004

MOTION FOR PROTECTIVE ORDER Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, the defendant in the above-referenced matter seeks a protective order allowing the deposition of Amy Pachiotti, an underwriter of the defendant, to occur at the same date and location as that of the continued deposition of Scott Michael Terra, the defendant's claims adjuster. The depositions of Ms. Pachiotti and Mr. Terra have been scheduled for Friday, April 30, 2004, at plaintiffs' counsel's office. The defendant has notified that Mr. Terra is unavailable on the scheduled date and has asked to reschedule both depositions. Defendant has filed a separate Motion for Protective Order regarding the nature and scope of the continued deposition of Mr. Terra. Counsel for the plaintiffs has agreed to reschedule Mr. Terra's deposition but not that of Ms. Pachiotti.

SR/220147/bsw

Case 3:03-cv-01009-SRU

Document 40

Filed 04/29/2004

Page 2 of 2

WHEREFORE, the defendant respectfully seeks an order allowing the defendant to present its representatives at the same date and location for the convenience of the parties. DEFENDANT, PATRONS MUTUAL INSURANCE COMPANY

By

\S\
Joel J. Rottner Skelley Rottner P.C. P.O. Box 34089 Hartford, Connecticut 06134-0890 (860) 561-7077 Fed. Bar ct05612

CERTIFICATION I hereby certify that a copy of the above was mailed via U.S. Mail, postage prepaid, on April 28, 2004, to the following counsel of record: Attorney Cheryl E. Heffernan Law Office of Cheryl E. Heffernan 2842 Old Dixwell Avenue Hamden, CT 06518

\S\
Joel J. Rottner

-2-