Free Motion to Compel - District Court of Connecticut - Connecticut

, Case 3:03-cv-00662-PCD Document 18 Filed 12/22/2003 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE
DISTRICT OF CONNECTICUT
)
CHRISTIE SUTHERLAND, )
Plaintiff ) Civil No. 3:03 CV 0662 (PCD)
)
v. )
)
OLIN CORP. d/b/a OLIN BRASS )
_ SOMERS THIN STRIP )
Defendant. ) December 22, 2003
)
DEF ENDANT’S MOTION TO COMPEL AND FOR SANCTIONS
Pursuant to Federal Rules of Civil Procedure 33, 34 and 37, and Local Rule 9(d),
defendant Olin Corporation d/b/a Olin Brass Somers Thin Strip ("Olin") moves to compel
plaintiff Christie Sutherland to make Initial Disclosures in accordance with Rule 26(a)("Initial
Disclosures"), and to provide complete answers and responses to Olin’s First Set of
Interrogatories and Requests for Production of Documents dated August 13, 2003 ("Discovery
Requests"). Despite the fact that plaintiffs Initial Disclosures were due within 14 days of the
parties’ June 3, 2003 Rule 26(f) conference, plaintiff has failed to make his Initial Disclosures.
Moreover, on October l0, 2003, and following a 30-day extension of time, plaintiff provided
responses to Olin’s Discovery Requests in which he failed to respond to many of Olin’s
Discovery Requests, provided evasive and incomplete responses to many other Discovery
Requests, and interposed improper and unsustainable objections. Accordingly, Olin respectfully
requests that the Court grant its motion to compel and for sanctions and order plaintiff to (1)
make Initial Disclosures; (2) respond to the Discovery Requests in their entirety; and (3) pay
Olin’s costs and attorneys’ fees incurred by the bringing of this motion and impose other
appropriate sanctions. Olin further requests that the Court order that the deadline for completion

i Case 3:03-cv-00662-PCD Document 18 Filed 12/22/2003 Page 2 of 3
of discovery be extended by an additional 30 days, up to and including February 9, 2004, in
order to pennit the Court to rule upon the instant motion, and to allow the parties to complete
necessary discovery.
Olin submits a memorandum and accompanying affidavit in support of this motion,
containing certifications in accordance with Local Rule 9(d)(2) that it has attempted to confer
with counsel for plaintiff in a good faith effort to resolve the issues raised by this motion without
Court intervention, but has been unsuccessful in reaching an agreement.
DEFENDANT
OLIN CORP. d/b/a OLIN BRASS
SOMERS IN STRIP,
By:
Stephe . Harris, ct13125
William J. Albinger, ct18861
Wiggin & Dana LLP
One Century Tower
P.O. Box 1832
New Haven, CT 06508-1832
(203) 498-4400
Its Attorneys
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Q Case 3:03-cv-00662-PCD Document 18 Filed 12/22/2003 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that on this 22nd day of December, 2003, a copy of the foregoing has
been mailed, postage prepaid, to the following:
Leonard A. McDermott, Esq.
Employee Advocates, LLC
35 Porter Avenue, 2B
P.O. Box 205
Naugatuck, CT 06770
Stephe . Harris
\9754\4o\441117.1
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