Free Motion for Protective Order - District Court of Connecticut - Connecticut

Case 3:03-cv-OO4E)1.3MRK Document 56 Filed 05/1/1/2004 Page 1 of 4 __W
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UNITED STATES DISTRICT COURT , I
DISTRICT OF CONNECTICUT V #‘--
RHEA MILARDO : l I in-i
: CIVIL ACTION NO.: I
VS. 3 03 CV 0401 MRK i
TOWN OF WESTBROOK, ET. AL. MAY 10, 2004 \
MOTION FOR PROTECTIVE ORDER I
Pursuant t0 Fed. R. Civ.P. 26 and 32, and Local R. Civ. P. 37, the
defendants Westbrook Police Union Local 1257, and AFSCME Council 15 I
hereby move for a protective order from this court prohibiting the plaintiff from
proceeding with the deposition of the defendant Westbrook Police Union Local
1257 on May 12, 2004 at the law offices of Plaintiffs counsel.
The defendants so move for the following reasons: 1
1. Defendants’ counsel is unavailable to attend the deposition on said
date because he is required to attend a medical consultation with
his minor child; i
2. The plaintiff seeks through the deposition to obtain information
irrelevant to her claims against the defendants. Specifically, the
plaintiff seeks information from a person who:
a. "can identify the Assistant Attorney General who provided
information and/or guidance to President Joseph Pucillo
with respect to the application of the Mountain Bike Patrol
ORAL ARGUNIENT IS NOT REQUESTED
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( Case 3:03-cv-0O4@jlJ|RK Document 56 Filed 05/Er‘1f?0O4 Page 2 of 4
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Unit funds with respect to the settlement of this case. i
custody and control of the following described documents in j
{ the ordinary course of business."(sic); \
b. “has knowledge of all assistance and/or guidance obtained
by President Joseph Pucillo that formed the basis for his
representation to the local union members that it was i
appropriate to use a portion of the application ofthe l
Mountain Bike Patrol Unit funds with respect to the
settlement of this case. custody and control of the following l
described documents in the ordinary course of business."
(sic). I
Said information is irrelevant to the claims made by the plaintiff, and ,
instead is solely related to the settlement of the matter which the plaintiff now
contests, and of which the plaintiff opposes enforcement. N
The matter is scheduled for a conference before Magistrate Judge
Garfinkel on May 19, 2004, at which time the issue of the enforcement of
settlement is to be heard. Any discovery should be postponed until completion
of the settlement conference as settlement of the case in accord with the I
agreement already reached would render the need for discovery moot.
Wherefore, the defendants move that a protective order be issued staying
discovery until after completion of the settlement conference.
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. Case 3:03-cv—0O4Q-}/IRK Document 56 Filed 05/U/52004 Page 3 of 4 ,
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Ti-IE UNION DEFENDANTS
Eric R. Brown, CT13519 F
Staff Attorney 1
AFSCME Council 15 Legal Dept.
290 Pratt Street
Meriden, CT 06450 ,
203-237-2250 2
Fax: 203-237-2262
E—mai|: [email protected]
Juris No. 410629
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i Case 3[O3-CV-004- RK Document 56 Filed 05/{#004 Page 4 of 4 }
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CERTIFICATION
The undersigned certifies that the foregoing was mailed postage prepaid
to counsel for parties of record on the date set forth herein;
Susan Phillips
. Matthew Augur i
Eileen Duggan
Suisman, Shapiro, et. al. l
2 Union Plaza i
P.O. Box 191 l
New London, CT 06320 A
Michael J. Rose I
Alexandria Voccio =
Martha Ann Shaw
Howd 8 Ludorf {
65 Wethersfield Ave. l
Hartford, CT 06114-1190
John Bennett
Gould, Larson, et. al. l
35 Plains Road J
Essex, CT 06426 I
Charles I-loulihan, Jr.
1276 Hopmeadow Street
P.O. Box 582
Simsbury, CT 06070-0582 (CLU! `
Eric R. Brown I
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