Free Response - District Court of Connecticut - Connecticut

, Case 3:03-cv-00943-AWT Document 203-4 Filed 08/05/2008 Page 1 of 3
SUSMAN , DUFFY (Sr S EGALOFF, P.C.
MK-IHAEL SUSMAN ATTORNEYS AT LAW
JAMES H. SEGALOFF
JOSEPH E. FAUGHNAN PLEASE REPLY TO:
LAURA M. SKLAVER ALLEN H. DUFFY
JAMES Ji PER!-I-O P.O. BOX IGB4 (IQSPISBG)
MATTHEW C. SUSMAN NEW HAVEN. CT OG50`7·IGB4 '*';‘“
THOMAS E. KATON OF COUNSEL
KAREN BALDWIN KRAVETZ (ECB) 624-9830 DAVID P, HAMBLETQN
PHILIP G. KENT '—-_-i
MEGHAN K_ GALLAGHER FACSIMILE (203) 552·B43O _
MICHAEL A. LEONE
ANIA M. WROBLEWSKA
writer’s e·maiI address: mvalla herqsusmandu .com
July 31, 2008
Via facsimile: 882-0354
John A. Pinheiro, Esq.
l67 Cherry Street, Suite 314
Milford, CT 06460
Re: Gary Session v. Edwin Rodriguez gDocket No. 3:03cv 00943 )
Dear Attorney Pinheiro:
This letter is in response to your recent accusations that I have made misrepresentations to
the Court, that I improperly seized documents and, subsequently withheld documents. As set forth
below, your accusations were made recklessly and are wholly without merit.
On July ll, 2008, during a telephonic status conference with the Court, you made numerous I
references to the withholding of documents by the Defendants. As you know, Edwin Rodriguez is
no lon er a member of the New Haven Police De artment and, thus, has counsel se arate from the
E _ _ P P
City of New Haven. Accordingly, during an exchange, whereby Attorney Katon asked you to clarify
your accusations against the City of New Haven from those against Edwin Rodriguez, a question
arose as to when Edwin Rodriguez gained possession of the internal affairs files. My representation
to the Court was to explain the circumstances surrounding my possession of the internal affairs
investigation information and the subsequent Motion for Protective Order. I explained to you and to
_ the Court that Edwin Rodriguez, through counsel, took possession of the tiles in December, 2007. I
did not represent to the Court that the Plaintiff s first request for internal affairs documents was
. made in December, 2007. I believe the court transcript of the status conference would reflect that I
have not made any misrepresentations to the Court.
A At the settlement conference, you also suggested to the Court, that I improperly seized
I documents from the City of New Haven and that I have withheld documents. Again, these attacks
I on my character as an officer of the Court are reckless and without merit. At the suggestion of
I corporation counsel and former counsel for Mr. Session, Attorney Roy Ward, I was given the files ‘
l regarding Mr. Rodriguez’s personnel information. Attorney Ward even drove the materials to my
office. At no time did I destroy or withhold documents. The documentation you received on July
l0, 2008, in response to the Court’s order, represents a complete set of all the personnel and internal
affairs information in the custody, control and possession of Mr. Rodriguez’s counsel.
\ EXHIBIT C

, Case 3:03-cv-00943-AWT Document 203-4 Filed 08/05/2008 Page 2 of 3
` I SUSMAN, DUFFY S4 SEGALOFF, lD.C.
Page 2.
In light of my response, it is clear that your accusations against me constitute
misrepresentations by you to the Court. As such rnisrepresentations are in violation of our code of
professional conduct, please refrain from making any similar accusations in the future.
Very truly yours,
aj il/~“
I Meghanl . G gh
MKG/gml
l:\Clicnt N—O\NHCITY\Session\Corrcpondencc\pinhciro 073 108.doc


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V ‘ Case 3:03-cv-00943-AWT Document 203-4 Filed 08/05/2008 Page 3 of 3 P- I
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