Free Motion for Order - District Court of Connecticut - Connecticut

Case 3:03-cv-00316-JCH Document 57 Filed 10/3072003 Page 1 of 1 '
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UNITED STATES DISTRICT COURT F \ L E D 5
DISTRICT OF CONNECTICUT 2 3
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JOHN J. CHAPMAN
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EXPERIAN INFORMATION SERVICES, INC.
CHASE MANHATTAN BANK USA, N.A. October 28, 2003 I
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PLAINTIFF'S MOTION FOR DISCOVERY ORDERS: CHASE I
On August 19, 2003, this Court orally granted a confidentiality order and orally
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ordered defendant CHASE to comply with long outstanding discovery requests. To date, I
Chase has not provided documents responsive to Production Requests 9, ll (as to mixed
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SSN’s), 15, 16, 17, 25, 26, 27 as ordered. Nor has Chase provided a complete sworn {
response to Interrogatories 2-8, requesting it to "identity" individuals. Despite several
reminders and requests, defendant has not complied.
Pursuant to Fed. R. Civ. P. 37(b)(2) or (d), plaintiff moves for the entry of a default
against defendant CHASE, an order that the allegations of the complaint shall be taken
to be established against the defendant CHASE, and an order striking its affirmative
defenses.
THE PLAINTIFF
ORAL ARGUMENT NOT REQUESTED
JOANNE FAULKNER ct04137
123 Avon Street
New Haven, CT 06511
(203) 772-0395