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

Case 3:01-cv-01927-WWE

Document 60

Filed 08/29/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

LISA A. CHARETTE VS. : NO. 3:01CV1927(WWE) AUGUST 28, 2005

DEPT. OF SOCIAL SERVICES, ET AL. :

BRIEF IN OPPOSITION TO MOTION TO COMPEL OR FOR SANCTIONS

The defendant is aware that the plaintiff suffers from many severely disabling physical infirmities which have significantly slowed the progress of this litigation. The defendant now seeks an order compelling the plaintiff to submit to a deposition at a location convenient to the plaintiff, or for sanctions. After medical consultation, the plaintiff is prepared to submit to a deposition at the office of her undersigned attorney on Friday, October 21, or Friday, November 4. Accordingly, the motion should be denied.

Case 3:01-cv-01927-WWE

Document 60

Filed 08/29/2005

Page 2 of 2

Respectfully submitted:

___________________________________ JOHN R. WILLIAMS (ct00215) 51 Elm Street New Haven, CT 06510 (203) 562-9931 FAX: (203) 776-9494 E-Mail: [email protected] Plaintiff's Attorney

CERTIFICATION OF SERVICE On the date above stated, a copy hereof was mailed to Attorney Tammy D. Geathers, Assistant Attorney General, P. O. Box 120, Hartford, CT 06141-0120.

_________________________________ JOHN R. WILLIAMS