Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

Case 3:01-cv-01927-WWE

Document 98

Filed 11/09/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

LISA A. CHARETTE VS. : NO. 3:01CV1927(WWE) NOVEMBER 8, 2006

DEPT. OF SOCIAL SERVICES, ET AL. :

PLAINTIFF'S MEMORANDUM IN OPPOSITION TO DEFENDANT'S MOTION FOR SANCTIONS

Plaintiff proposed September 12 and then October 17 as dates that she would be available for a deposition. She never agreed to more than approximately 1.5 hour sessions for her deposition, and she had requested that the deposition take place at the office of her therapist. The first session, on August 3, did take place there, with her therapist in attendance. Plaintiff has objected to attending any further sessions until the defendant produces records which were requested in February, 2006. Plaintiff's counsel received one of the requested documents, her personnel file, two days ago, on November 6. The parties are presently attempting to resolve their disagreement concerning the other requested documents without the necessity of filing motions with the Court. Plaintiff's counsel attaches Exhibit One, the affidavit of plaintiff, in response to defendant's Motion to Compel and for Sanctions.

Case 3:01-cv-01927-WWE

Document 98

Filed 11/09/2006

Page 2 of 2

THE PLAINTIFF

BY: KATRENA ENGSTROM (ct09444) John R. Williams and Associates, LLC 51 Elm Street New Haven, CT 06510 9203) 562-9931 Fax: (203)776-9494 E-Mail: [email protected]

CERTIFICATION OF SERVICE On the date above stated, a copy hereof was mailed to Joseph A. Jordano, Assistant Attorney General, P. O. Box 120, Hartford, CT 06141-0120. ___________________ KATRENA ENGSTROM