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Case 3:03-cv-00662-PCD Document 17 Filed 12/22/2003 Page 1 of 3
UNITED STATES DISTRICT COURT I
FOR THE
DISTRICT OF CONNECTICUT
CHRISTIE SUTHERLAND, )
Plaintiff ) Civil N0. 3:03 CV 0662 (PCD)
)
v. )
)
OLIN CORP. d/b/a OLIN BRASS )
SOMERS THIN STRIP )
Defendant. ) December 22, 2003
)
AFFIDAVIT
Stephen B. Harris, being duly sworn, deposes and states as follows:
l. I am over the age of eighteen years, understand the meaning and obligations of an
oath, and am competent to testify to the facts set forth in this affidavit.
2. I am an attomey with the law firm of Wiggin & Dana LLP, One Century Tower,
New Haven, Connecticut, counsel for the defendant Olin Corporation d/b/ a Olin Brass Somers
Thin Strip ("Olin") in the above captioned matter. I make this affidavit in support of Olin’s
Motion to Compel and for Sanctions dated December 22, 2003. I have personal knowledge of
the statements made herein.
3. On June 3, 2003, I spoke with plaintiffs counsel for the purpose of conducting a
conference in accordance with Rule 26(f). As a result of that conference, a Report of the Parties’
Planning Meeting was prepared, which was later approved and adopted, in part, by the Court. In
accordance with the Report, as approved by the Court, discovery is to be completed by January
9, 2004.
4. On August l3, 2003, Olin served its First Set of Interrogatories and Requests for
Production of Documents ("Discovery Requests") on plaintiff

Case 3:03-cv-00662-PCD Document 17 Filed 12/22/2003 Page 2 of 3
5. Plaintiff moved for an extension of time to respond to the Discovery Requests
until and including October 14, 2003. Olin consented to this extension and the Court granted
plaintiff s motion for extension of time.
6. On October 10, 2003, plaintiff served his responses and objections to Olin’s
Discovery Requests ("Discovery Responses"). Plaintiff, however, did not respond to many of
the Discovery Requests and instead promised to supplement the responses at a later date.
Plaintiff also did not provide complete responses to many of the Discovery Requests. Finally,
plaintiff interposed many objections to the Discovery Requests.
7. On November l 1, 2003, I wrote to plaintiffs counsel to advise him that plaintiff s
deposition scheduled for the following day would be postponed on account of the outstanding
discovery issues and requested that he contact me to resolve the outstanding issues. I received
no response to my letter.
8. On November 18, 2003, I sent plaintiffs counsel a 6-page letter which provides
an individual listing of each of the items of discovery in dispute, and reasons why discovery
should be allowed. In the letter, I requested that plaintiff provide complete Discovery Responses
as soon as possible, and reminded plaintiffs counsel of the January 9, 2004 discovery deadline.
I also requested that plaintiff make Initial Disclosures which were long past due. I concluded the
letter by stating that "[i]f for any reason plaintiff does not intend to comply with [Olin’s]
Discovery Requests, please let us know so that we may prepare a motion to compel the responses
and for appropriate sanctions." I received no response to my letter.
9. As of the date of this affidavit, plaintiff has not made Initial Disclosures in
accordance with Rule 26(a); nor has he provided complete responses to Olin’s Discovery
Requests.

Case 3:03-cv-00662-PCD Document 17 Filed 12/22/2003 Page 3 of 3
l0. The foregoing statements are true and co to the best of my knowledge and
belief. 3 i ;
phen B. Harris
Subscribed and sworn to before me
thiso}37""(day of December, 2003.
` E E-·»-! C M_
Notary Public
il My Commission Expires: MyCommissi0n Expires September30,2007.
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