Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00973-DJS
Exhibit 2 continued

Document 33-8

Filed 06/10/2004

Page 1 of 4

BY WAY OF PRODUCTION:

GENERAL RESPONSE As set forth in Fed.R.Civ.P. 34, the defendant will make available for inspection and copying in a reasonable time, place, and manner those documents requested below. Furthermore, although the defendant objects to any requests for production of documents that seeks information barred by the 4

Case 3:03-cv-00973-DJS

Document 33-8

Filed 06/10/2004

Page 2 of 4

statute of limitations, except where specifically objected to below, the defendant will provide such documents that are available and within its possession or control without waiving this objection. 1. Produce copies of any documents supporting the factual basis of your first affirmative defense.

2. Produce copies of any documents supporting the factual basis of your second affirmative defense.

3. Produce copies of any documents supporting the factual basis of your third affirmative defense.

4. Produce copies of any documents supporting the factual basis of your fourth affirmative defense.

5. Produce copies of any documents supporting the factual basis of your fifth affirmative defense.

6. Produce copies of any documents supporting the factual basis of your sixth affirmative defense.

7. Produce copies of any documents supporting the factual basis of your seventh affirmative defense.

5

Case 3:03-cv-00973-DJS

Document 33-8

Filed 06/10/2004

Page 3 of 4

State of Connecticut) ) ss. COUNTY OF )
The Undersigned, Margo S. Kilbon

, an authorized agent

the State of Connecticut Department of Transportation, being duly sworn, deposes and says: That I have read the preceding Request for Disclosure and Production, and state that said responses are true and accurate to the best of my ability, knowledge and study.

State of Connecticut Department of Transportation

1t%1;e~~
Its Authorized
,rf1/'Of rt:1P1 d Subscribed and sworn to before me on this 1-/ day o~August,. 2003.

pa

a P;rt11A1'i~ C!;;, ;:-10 f'.o

Case 3:03-cv-00973-DJS

Document 33-8

Filed 06/10/2004

Page 4 of 4

CERTIFICATION
This is to certify that a copy of the defendant's responses to plaintiffs second request for disclosure and production has been mailed this 22nd day of August, 2003, to the following parties: Kathleen Eldergill Beck & Eldergill, P.C. 447 Center Street Manchester, CT 06040