Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:03-cv-00943-AWT

Document 30

Filed 08/12/2005

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UNITED STATE DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT HARTFORD ************************************* GARY SESSION * PLAINTIFF * VS. * AUGUST 1, 2005

CIVIL ACTION NO. 303-CV-00943 (AWT)

CITY OF NEW HAVEN; STEPHEN * COPPOLA; AND EDWIN RODRIGUEZ * DEFENDANTS * *************************************

MOTION FOR PERMISSION TO NOTICE MORE THAN TEN DEPOSITIONS ON BEHALF OF THE PLAINTIFF GARY SESSION Pursuant to Fed. R. Civ. P. § 30, the plaintiff Gary Session hereby moves for permission to notice more than 10 depositions on his behalf. The plaintiff proposes to serve the Notices of Deposition attached as Exhibit A. In support of this motion the plaintiff states: 1. The plaintiff brought this action claiming multiple violations of the United States and Connecticut Constitutions, Federal Civil Rights Statutes and Connecticut tort law. 2. The deponents are all members of the New Haven police force who were involved in the investigation leading to the plaintiff's arrest. 3. The defendants Rodriguez and Coppola have identified each of these individuals as persons who have knowledge regarding the facts and circumstances of the case in their Rule 26 initial disclosure.

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Case 3:03-cv-00943-AWT

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4. The additional burden defending these depositions is minimal insofar as it will make the overall litigation of this matter less expensive for all parties involved. 5. The discovery sought is reasonable and just under all circumstances.

THE PLAINTIFF GARY SESSION

By________________________ David S. Feldman Philip Russell, LLC. 66 Field Point Rd. Greenwich, CT 06830 (203) 661-4200 FEDERAL JURIS No.: CT03556

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Case 3:03-cv-00943-AWT

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CERTIFICATION I herby certify that a copy of the above was mailed on August 1, 2005, to all counsel and pro se parties of record. Jonathan Beamon New Haven City Attorney's Office 165 Church Street New Haven, CT 06510 Stephanie S. Baier Susman, Duffy & Segaloff, P.C. P.O. Box 1684 New Haven, CT 06507-1684

______________________________ David S. Feldman

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