Free Affidavit - District Court of Connecticut - Connecticut

. Case 3:03-cv-00401-IVIRK Document 58 Filed 05/11/2004 Page 1 of 2 WI
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I UNITED STATES DISTRICT COURT , an ·;;· ;
DISTRICT OF CONNECTICUT I- {fi I
RHEA MILARDO ; I in IJ I
: CIVIL ACTION NO.: Eli
VS. ; S O3 CV 0401 MRI<
TOWN OF VVESTBROOK, ET. AL. Q MAY 10, 2004 I
AFFIDAVIT OF COUNSEL IN SUPPORT OF
MOTION FOR PROTECTIVE ORDER l
` I, Eric Brown, being duly sworn, depose and say under oath: I
1. The undersigned is over the age of 18 years and understands the
obligation of an oath. I
2. On May 3, 2004, the undersigned received a notice of deposition
from piaintiff’s counsel to take the deposition of the defendant _ I
Westbrook Police Union, Local 1257.
3. On May 6, 2004, the undersigned counsel spoke with the plaintiff's
counsel in an attempt to resolve the dispute related to the taking of I
the deposition. l
4. On May 7, 2004, the undersigned received a fax message from the
plaintiffs counsel outlining terms under which the plaintiff would
agree to postpone the deposition. (Exhibit 1 attached hereto).
5. Said terms are unacceptable to the defendant. I
6. The parties have made a good faith effort to resolve the differences
but are unable to reach a resolution at this time.
* Dated at Meriden, CT this 10*** day of May, 2004. I

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Case 3:03-cv-004CQ-MRK Document 58 Filed 05/1g/2»)OO4 Page 2 of 2
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Eric Brown
State of Connecticut :
SS: Meriden “
COL1i"|ty of New Haven Z y
Subscribed and sworn to me this 10*** day of I\/lay, 2004 J N

Har
Co e er of Superior Court `
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