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

Case 3:01-cv-01927-WWE

Document 106

Filed 01/09/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

LISA A. CHARETTE VS. : NO. 3:01CV1927(WWE) JANUARY 8, 2007

DEPT. OF SOCIAL SERVICES, ET AL. :

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

Plaintiff, LISA CHARETTE, respectfully submits this supplemental opposition to the proposed court order submitted by defendant's counsel. Defendant filed a motion for sanctions after plaintiff advised that she was unable to sit for a deposition of four (4) hours at 55 Elm St., Hartford, CT on January 8, 2007 due to her medical condition. Plaintiff's counsel offered another date, January 29, and indicated that the plaintiff required medical monitoring by her physician, Dr. Linda Siegel, in order to complete the deposition. Defendant's counsel has expressed his lay opinion in his motion and during the status conference of January 5, 2007, concerning the plaintiff's ability to tolerate a four hour deposition at the Attorney General's office, but he has no medical evidence which would contradict the letters from Dr. Siegel which have been submitted previously during the pendency of the case which describe the nature of plaintiff's physical limitations.

Case 3:01-cv-01927-WWE

Document 106

Filed 01/09/2007

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This medical condition is chronic and continuing. The plaintiff should not be sanctioned by fine and threat of dismissal under these circumstances, since she is attempting to cooperate with defendant's counsel.

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 sent by facsimile and mail, first class, to Joseph A. Jordano, Assistant Attorney General, P. O. Box 120, Hartford, CT 06141-0120. ___________________ KATRENA ENGSTROM

Case 3:01-cv-01927-WWE

Document 106

Filed 01/09/2007

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