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

Case 3:03-cv-00973-DJS

Document 33-2

Filed 06/10/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ________________________________ LISA TILUM : CIVIL ACTION NO: 3:03 CV973 (DJS) Plaintiff : : VS. : : STATE OF CONNECTICUT, : DEPARTMENT OF TRANSPORTATION: Defendant : JUNE 9, 2004 ________________________________: AFFIDAVIT OF KATHLEEN ELDERGILL STATE OF CONNECTICUT ) ) ss. Manchester COUNTY OF HARTFORD ) I, Kathleen Eldergill, being duly sworn, hereby depose and say: 1. I am over the age of 18 and believe in the obligations of an oath. 2. I represent the Plaintiff Lisa Tilum. 3. Requests for disclosure and production have been served upon the Defendants. Defendants have not fully complied with Plaintiff=s requests, as more fully set forth in the Plaintiff's memorandum in support of motion to compel discovery. 4. I have tried to resolve this matter by sending counsel for the Defendant letters dated January 20, 2004, March 2, 2004 and April 14, 2004, copy of which are attached to Plaintiff=s memorandum in support of motion to compel discovery. 5. Despite these bona fide attempts to resolve discovery issues, we have been

Case 3:03-cv-00973-DJS

Document 33-2

Filed 06/10/2004

Page 2 of 2

unable to do so. 6. The foregoing is true and accurate to the best of my knowledge and belief.

Kathleen Eldergill Subscribed and sworn to before me this 9th day of June, 2004.

Joan M. Johnson Notary Public My Commission Expires: 7/31/06 CERTIFICATION I hereby certify that a copy of the foregoing has been mailed this 9th day of June, 2004, to the following parties: Margaret Q. Chapple Assistant Attorney General Attorney General=s Office 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 ______________________________ Kathleen Eldergill

Tilum\KEAff06-04.pld