Free Motion for Conference - District Court of Connecticut - Connecticut

Case 3:01-cv-01927-WWE

Document 102

Filed 12/15/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT LISA CHARETTE Plaintiff v. : : : : : CIVIL NO. 3:01CV1927(WWE)

STATE OF CONNECTICUT DEPARTMENT OF SOCIAL SERVICES, ET AL. Defendants :

December 15, 2006

MOTION FOR STATUS CONFERENCE COMES NOW the defendants, State of Connecticut Department of Social Services, Rudolph Jones, Ronald Georgetti, John Galiette, John Halliday and Brian Merbaum, through counsel and respectfully request a Status Conference be scheduled regarding the above-captioned matter. The plaintiff in the instant matter has adamantly refused to sit for a deposition and the defendants are prejudiced by her dilatory tactics. The defendant mailed to the plaintiff's counsel a re-notice of deposition on December 4, 2006, setting the continuation of the deposition for January 8, 2007. Plaintiff's counsel, Katrena Engstrom, Esq., informed the undersigned this date the following: (1) plaintiff cannot make the January 8, 2007 date because her mother is undergoing medical tests; (2) that the plaintiff will not allow herself to be videotaped; and (3) that she will only sit for the deposition for 1½ hours. This is the third time the plaintiff has unilaterally imposed conditions preventing her deposition. The plaintiff's refusal to sit for a deposition January 8, 2007 is further evidence in support of the defendants' Motion to Compel and Motion for Sanctions (Doc. # 97), which is pending. In light of the Court's order (Doc. # 101, November 3, 2006) regarding defendants'

Case 3:01-cv-01927-WWE

Document 102

Filed 12/15/2006

Page 2 of 3

motion to modify the scheduling order that states, "This is the final extension of time that shall be granted," the defendants, through counsel, respectfully request that a status conference be immediately scheduled. The undersigned represents as counsel for the defendants he cannot properly prepare dispositive papers without being able to depose the plaintiff to fully address all issues raised in the Complaint. WHEREFORE, the defendants respectfully request that the Court schedule a Status Conference regarding the instant matter.

DEFENDANTS

RICHARD BLUMENTHAL ATTORNEY GENERAL By: /s/ Joseph A. Jordano______________ Joseph A. Jordano Assistant Attorney General 55 Elm Street, P.O. Box 120 Hartford, CT 06141-0120 Tel: (860) 808-5340 Fax: (860) 808-5383 Email: [email protected] Federal Bar # ct21487

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Case 3:01-cv-01927-WWE

Document 102

Filed 12/15/2006

Page 3 of 3

CERTIFICATION I hereby certify that on December 15, 2006 a copy of the foregoing Motion for Status Conference was filed electronically. Notice of this filing was sent by e-mail to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. /s/_Joseph A. Jordano_____________ Joseph A. Jordano (# ct21487) Assistant Attorney General 55 Elm Street, P.O. Box 120 Hartford, CT 06141-0120 Tel.: (860) 808-5340 Fax: (860) 808-5383 E-mail: [email protected]

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