Free Response - District Court of Connecticut - Connecticut

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i Case 3:03-cv-00407-JCH Document 23 Filed 10/31/2003 Page 1 of 2 l _ ;
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FILED Q
i UNITED STATES DISTRICT couwi UU 3 l Q 3° 2*9
DISTRICT OF CONNECTICUT _ 4 _ ___ _ if
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4 ANGEL CABALLERO, JR ; PRISONER BRl{1i=i:..Ei·‘ iii -1 l B- E
i : NO. 3:03CV407 (J CH) (HBF)
a , VS. I
p JOHN J. ARMSTRONG ET AL. . OCTOBER 30, 2003 _
i i DEFENDANTS RESPONSE TO PLAINTIFF’S OBJECTION TO MOTION FOR
` . LEAVE TO DEPOSE PLAINTIFF
Defendants moved, pursuant to Rule 30(a) of the Federal Rules of Civil Procedure, to
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I depose the plaintiff a person confined to prison. Plaintiff objects, claiming that he has not yet 1
T - had an opportunity to complete his discovery yet. This is an action brought under 42 U.S.C. § I
. _ 1983 wherein plaintiff seeks to challenge the fact that he is recreating in handcuffs and leg irons l
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I at Northern. Plaintiff will merely be asked about his claims. There is no need for plaintiff to
l i have discovery from defendants first. There is no requirement that plaintiff complete his
` discovery, before defendants can engage in their discovery. Defendant merely seeks an
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opportunity to discover the nature and basis of plaintiffs claims. \
A WHEREFORE, defendant respectfully requests leave to depose Angel Caballero a person
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,»Ca§e”3:03-cv—00407@H Document 23 Filed 1 O/316%% Page 2 of 2 ·~- ·
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confined to prison on November 7, 2003. A
DEFENDANTS,
- l JOHN ARMSTRONG ET AL
A RICHARD BLUMENTHAL
ATTORNEY GENERAL {
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A Br: War. M aia · A
Ann . Lynch v '
Assistant Attorney Ge er I A
Federal Bar No: ct08326 A
110 Sherman Street 1
Hartford, CT 06105
Telephone No.: (860) 808-5450
. A Fax No. (860) 808-5591 ?
E-mail: [email protected]
CERTIFICATION
This is to certify that a copy ofthe foregoing was mailed in accordance with Rule 5(b),
A Fed. R. Civ. P., this 30th day of OCTOBER, 2003 to: _
Angel Caballero, Jr. Inmate No. 214362
Northern Correctional Institution {
E 287 Bilton Road, PO Box 665
A Somers, CT 06071
Bran Smi eponing Service 4,
44 Capit venue if
H a, or Q _,/’
Ann E. Lynch
, Assistant Attorney e ral