Free Motion to Compel - District Court of Connecticut - Connecticut

Case 3:01-cv-01977-EBB

Document 41

Filed 12/11/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PATRICIA ANN MEDVEY, Plaintiff, v. : OXFORD HEALTH PLANS, INC., and METROPOLITAN LIFE INSURANCE COMPANY, Defendants. : : DECEMBER 10, 2003 : : CIVIL NO. 301CV1977(WWE)

DEFENDANTS' AMENDED MOTION TO COMPEL Pursuant to Rules 33, 34 and 37 of the Federal Rules of Civil Procedure, the defendants Oxford Health Plans, Inc. and Metropolitan Life Insurance Company, hereby move to compel the plaintiff, Patricia Ann Medvey, to comply with defendants' discovery demands, dated May 29, 2003. Plaintiff served partial compliance with those demands on November 20, 2003, in response to defendants' October 21, 2003 Motion to Compel. However, plaintiff objected to many of the requests despite the fact that the time for such objections expired pursuant to Fed. R. Civ. P. 33 and 34 on June 28, 2003. Furthermore, plaintiff's responses to several other discovery requests were obviously incomplete. Indeed, plaintiff filed no response at all to several of the discovery requests. Defendants therefore file this Amended Motion to Compel complete

STAM1-747995-1

Case 3:01-cv-01977-EBB

Document 41

Filed 12/11/2003

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responses. In support of its motion, the defendants rely upon the accompanying affidavit of David J. Burke, Esq., and the accompanying Memorandum of Law. DEFENDANTS, OXFORD HEALTH PLANS, INC., METROPOLITAN LIFE INSURANCE COMPANY By: ________S/S______________ David A. Kulle (ct00333) [email protected] David J. Burke (ct04373) [email protected] Robinson & Cole LLP 280 Trumbull Street Hartford, CT 06103-3597 Tel No.: (860) 275-8200 Fax No.: (860) 275-8299

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Case 3:01-cv-01977-EBB

Document 41

Filed 12/11/2003

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing was sent via first class mail, postage prepaid, to Edmond Clark, Esq., 83 Scotland Avenue, Madison, Connecticut 06443-2501 on December 10, 2003.

_________S/S_________________ David J. Burke

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