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

Case 3:03-cv-00977-CFD

Document 24

Filed 06/29/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

WENDELL HARP and ARCHITECTS ENVIRONMENTAL COLLABORATIVE INTERNATIONAL, P.C. VS. JOHN DeSTEFANO, CITY OF NEW HAVEN and NEW HAVEN BOARD OF EDUCATION

: : : : : : : : :

NO. 3:03CV977(CFD)

JUNE 25, 2005

SECOND MOTION FOR PROTECTIVE ORDER

Plaintiffs respectfully move for a protective order imposing conditions of confidentiality upon the use of materials which the defendants are demanding that the plaintiff Harp produce at his continued deposition. This court previously denied summarily the plaintiffs' objection to the production of confidential personal tax and other financial records. In response to that denial, the defendants have dramatically expanded their demands to a five-page single-spaced typewritten list attached to their Renotice of Deposition. That document is attached hereto and incorporated herein by reference. Specifically, the plaintiffs seek an order directing that the materials demanded in Paragraphs 3, 4, 8(c), 8(f), 8(h), 9, 15, 16 and 29 be place under seal, not disclosed to any of the parties or any persons outside the office of Attorney Cone, and only to those persons within the office of Attorney Cone who have in her opinion a

1

Case 3:03-cv-00977-CFD

Document 24

Filed 06/29/2005

Page 2 of 2

genuine need for access to said materials in connection with the defense of this litigation. Plaintiffs further seek an order that there be no other disclosure of said materials without the order of this court, that no copies be made of said materials, and that upon the conclusion of this litigation the said materials be returned under seal to the plaintiffs. In support of this motion, the plaintiffs represent that the said materials are highly confidential personal or trade secret materials the unnecessary disclosure of which would inflict substantial injury upon the plaintiffs both personally and professionally.

THE PLAINTIFFS

BY:______________________________ JOHN R. WILLIAMS (ct00215) 51 Elm Street New Haven, CT 06510 203/562-9931 FAX: 203/776-9494 E-Mail: [email protected] Their Attorney

CERTIFICATION OF SERVICE On the date above stated, copies hereof were mailed to Attorney Rodger W. Lehr, Jr., Deputy Corporation Counsel, 165 Church Street, New Haven, CT 06510 [E-Mail: [email protected]]; and Attorney Carolyn W. Kone at Brenner, Saltzman & Wallman LLP, 271 Whitney Avenue, New Haven, CT 06511 [E-Mail: [email protected]].

__________________________________ JOHN R. WILLIAMS 2