Free Motion to Compel - District Court of Connecticut - Connecticut

G ase 3:03-cv-01009-SRU Document 38-3 Filed O4/20/2004 Page 1 of 3 I
F IL E D I
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U.S. DISTRICT C —` I
UNITED STATES DISTRICTHEHDUWDRI. CSIIIIIN I
DISTRICT OF CONNECTICUT I I
JOSEPH ATTIAS & HAIM ATTIAS ; CIVIL NO. 3:03 CV 01009 (SRU) I
Plaintiffs : I
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PATRONS MUTUAL INSURANCE : I
COMPANY OF CONNECTICUT ; .
Defendant : APRIL 19, 2004
AFFIDAVIT OF COUNSEL I
Pursuant to Local Rule 9 of the District of Connecticut the undersigned counsel I
for the plaintiffs hereby submits the following affidavit in support ofthe Plaintiffs motion to I
compel disclosure dated April 19, 2004.
STATE OF CONNECTICUT}
} at Hamden, April 19, 2004
COUNTY OF NEW HAVEN} I
I, Cheryl E. Heffernan, having been sworn hereby depose and say: I
l. 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;
3. I am counsel for the plaintiffs Joseph and Hiam Attias the matter of Attias
v. Patrons Mutual Insurance cfC0nnecticut pending in the United State
District Court for the District of Connecticut;
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ase 3:03-cv—O1009-SRU Document 38-3 Filed O4/20/2004 Page 2 of 3 i
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4. By way of requests for discovery dated February 23, 2004 I, on behalf of
the plaintiffs requested information and documents relative to tire loss
claims on insurance policies issued by defendant during a particular period l
of time. l
5. Responses to these request were due on March 23, 2004.
6. No responses to the discovery requests were received in a timely fashion 3
and no requests for additional time to tile responses were received until i
after the undersigned sent a fax on March 30, 2004 demanding
compliance.
7. On April 13, 2004 as part of the defenda11t’s compliance the defendant
objected to providing information or documentation as requested relative
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
received.
9. Wherefore the undersigned submits that good faith efforts have been made
to resolve the defendant’s objection to requested discovery . j
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Sworn to before me this l9s° day of April, 2004. l
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Commissioner of the Superior Court
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ase 3:03-cv—O1009-SRU Document 38-3 Filed O4/20/2004 Page 3 of 3 N
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CERTIFICATION I
I hereby certify that a copy ofthe foregoing was sent by first class mail, postage prepaid
this l9"` day of April 2004, to:
Heather Adams—Beman, Esq. I
Joel Rottuer, Esq.
Skelley Rotmer P.C. I
PO Box 340890
Hartford, CT 06134-0890
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