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

Case 3:03-cv-00973-DJS

Document 33-10

Filed 06/10/2004

Page 1 of 1 Attorneys At Law

Beck (0 Elder8ilL P.c.
447 CENTER STREET, MANCHESTER, CONNECTICUT 06040 PHONE (860) 646-5606
COVENTRY (860) 742-0882 HARTFORD (860) 522-5606 FAX (860) 646-0054

March 2, 2004 ADVANCED VIA FACSIMILE ONLY: 808-5385 Margaret Q. Chapple Assistant Attorney General 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 RE: Lisa Tilum v. State of CT., Department of Transportation et al Docket No. 3:03 CV973 (DJS)

BRUCE S. BECK KATHLEEN ELDERGlLL MARC P. MERCIER FATIMA T. LOBO DAVID R. KRITZMAN MATTHEW R. POTTER DEREK V. OATIS MARIA MONICK-BARALL

Dear Peggy:

Enclosed is a copy of a letter I sent to Steve Courtney on January 20, 2004 outlining a meeting we held to resolve all discovery issues on January 13, 2004. The italicized comments represent our resolution of outstanding issues. As you can see, Steve Markwald had indicated that he would attempt to locate certain documents responsive to this request. To date I have not received these. In addition, at DOT's suggestion, I subpoenaed documents from the Department of Information Technology. I have since spoken to Tony Lazzaro of that office (418-6467) who has indicated that the documents I sought from that department are not, in fact, in its possession. He has promised to provide me with written documentation of this, which I will send to you once I have received it. As an aside, sometime after our meeting, I was informed that Cordula had been mistaken about the documents in question, and that they were, in fact, within DOT's custody and control.
Finally, Steve agreed to identify which documents produced in response to our second request for disclosure and production were responsive to our different requests.

Sincerely,

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Kathleen Eldergill KE:jmj cc: Lisa Tilum
Tilum\Cha030204.1tr

Exhibit 4