Free Motion for Leave to File - District Court of Connecticut - Connecticut

Case 3:03-cv-00401-MRK

Document 49

Filed 03/22/2004

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UNITED STATES DISTRICT COURT for the DISTRICT OF CONNECTICUT RHEA MILARDO : : : : : : : : :

CIVIL ACTION NO. 303 CV 401 (MRK)

vs. TOWN OF WESTBROOK, WESTBROOK POLICE UNION, Local 1257, AFSCME Council 15, and DOUGLAS SENN

March 20, 2004

MOTION TO FILE DOCUMENT UNDER SEAL Rhea Milardo, Plaintiff herein, moves to file a document under seal and represents as follows: Procedural Context Defendants have filed a motion to compel enforcement of a settlement. Plaintiff contends that Defendants have failed to perform the agreement, and have retaliated against her for asserting her civil rights since the mediation session. Present Issue In connection with her opposition to the motion to compel settlement, Plaintiff has prepared an affidavit with associated exhibits relating to an action directed against her on March 18, 2004. Public disclosure of such action would lead to censure or termination. Further, even if the action by a non-party is appropriate, whether Defendants have caused such action to be taken raises grave issues of retaliation.
Motion to File Documents under Seal - Page 1

Case 3:03-cv-00401-MRK

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Public release of such information is prohibited, and Plaintiff may only file such material as a sealed document. Procedure Local Rule 5 allows a party to request permission in advance of the submission of the records to be sealed. Because the consequences of public disclosure are severe, Plaintiff f requests advance permission of the court to file such records under seal. RHEA MILARDO, PLAINTIFF

By: ____________________________________ Charles D. Houlihan, Jr. Federal Bar No. CT 11416 Post Office Box 582 Simsbury, CT 06070 Telephone: (860) 658-9668 E-Mail: [email protected] Telecopier: (860) 658-1339 ATTORNEY FOR PLAINTIFF

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Case 3:03-cv-00401-MRK

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Filed 03/22/2004

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CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the above and foregoing instrument has been mailed by first class United States Mail, postage prepaid, to: Alexandria L. Voccio, Esq Michael J. Rose, Esq. Martha A. Shaw, Esq. Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114 fax: 522-9549 Representing Douglas Senn Representing the Town of Westbrook Eric R. Brown, Esq. AFSCME Council 15 Legal Dept. 290 Pratt Street Meriden, CT 06450 fax: 203-237-2262 Representing Westbrook Police Union, Local 1257 and AFSCME Council 15 on this the ___ day of March 2004. _________________________ Charles D. Houlihan, Jr. Hinda K. Kimmel, Esq. Eileen C. Duggan, Esq. Susan M. Phillips, Esq. Matthew E. Auger, Esq. Suisman, Shapiro, Wool & Brennan Two Union Plaza, Suite 200 P.O. Box 1591 New London, CT 06320 fax: 860-442-0495

Motion to File Documents under Seal - Page 3