Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

Case 3:00-cv—01026-SRU Document 77-4 Filed 04/06/2004 Pagel 0f4
D0cument5
April 6, 2004 9,50 AM

P Z Case 3:00-cv—01026-SRU Document 77-4 Filed 04/06/2004 Page 2 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
ANTHONY ANAIVIASI 1 CIVII; ACTION
NO. 3;00CV0102G(SRU)
V. 1
LANCE COUOI-ILIN and ·
TOWN OF EAST HAVEN : JUNE 10, 2003
AFFIDAVIT IN OPPOSITION TO MOTION FOR IN CAMERA REVIEW
R. David Stamm, being duly sworn, deposes and states as follows:
1. l am the Director ofthe Connecticut Bar Examining Committee. I am over
the age ot1B years and appreciate the signihcance of an oath.
2. This affidavit is submitted in opposition to plaintiff Anthony Anamisi's
Motion for In Camera Review dated May 22, 2003. The Motion requests the
Court to conduct an in camera review of documents in the possession of the
Connecticut Bar Examining Committee relating to defendant Lance Coughlirrs
application for admission to the Connecticut Bar. I
3. The Connecticut Bar Examining Committee is a Committee of the
Connecticut Superior Court. The Bar Examining Committee has the duty to
provide for the examination ot candidates for admission to the bar, to determine
whether such candidates are qualitied as to pre-law education, legal education,
I morals and fitness, and to recommend qualitied candidates to the Court for
admission. -
t.,,.,w.,. IHMGW §2£‘;;.§?3t3i°a§§”
westp0n,Cf ossso & SAGELLP 1uti$i~r¤.41219s

._ Case 3:00-cv—01026-SRU Document 77-4 Filed 04/06/2004 Page 3 of 4
4. ln discharging its duty to determine whether bar applicants are qualified as
I to pre-law education, legal education, morals and fitness, the Bar Examining
Committee routinely solicits pertinent background information from the applicants
themselves and from third party sources. Applicants for admission to practice as
an attorney are required to complete a standard application form and are also
required to execute a Release of information form. The Release of lnfomriation
form allows the Bar Examining Committee to obtain a wide variety of information
from third party sources. information gathered by the Committee includes
information regarding a candidates personal background, educational
experience, military service, credit history, employment history and medical and `
mental health history (tothe extent that the latter information relates to the ability
of the applicant to function as an attorney).
5. The records ofthe Bar Examining_Committee are confidential under Rule
2-50 of the Rules ofthe Superior Court. ln addition, the Release of information V
form and the forms used to solicit information from third parties provide an
assurance of conhdentiality to the applicants and to the third party sources of A
information. A copy of the Bar Application/Release of information form utilized
for the July 1997 bar application is attached to this affidavit as Exhibit 1. A copy
of theform employer reference letter utilized for the July 1997 bar examination is
annexed to this affidavit as Exhibit 2. The policy of confidentiality stated in Rule
2-50 and the Committee practice of assuring confidentiality to applicants and to
third party sources of information facilitates the work of the Committee by
mma., Hel-OW ‘é¥;i";§0‘§,°§%3it§§“
Wcstpmt,CT umn ll. SAGEl.l.P .lurisN¤, ¤.i2i9s

N l _ Case 3:00-cv—01026-SRU Document 77-4 Filed 04/06/2004 Page 4 of 4
encouraging candor in the application process.
6. l have reviewed the records ofthe Bar Examining Committee to determine
the relevant chronology of Lance Coughlin's application for admission to the bar.
Mr. Coughlin was a July 1997 applicant. l-le sat for and passed the bar
examination administered in July 1997. Subsequently, in November 1997, Mr.
Coughlin was admitted as a Connecticut attorney. As a July 1997 applicant, Mr. A
Coughlin's bar application would have been submitted no later than May 31,
1997 (the cut off date for the July 1.997 examination).
7. For the reasons stated in this afndavit and in the accompanying
Memorandum of Law, the Bar Examining Committee requests that the plaintifts
Motion For ln Camera Review be denied .
\_ .
. i d .
- l -, N. tv /i/l_
_ R. avid Stamm . i
f _ Otn
- SUBSCRIBED AND SWORN to before me this] day c June, 200 I
\— \;__J ,*..4 J l MWQQ -
‘. mmi sioner ofthe
Superior Court
a333T3.1(l-l5FPi
mm: - $$55
as Wm HMOMN E; a‘§i°§%$i2§2
w¤s¤p¤n,cT 06880 & SAGEM.? · JurisN¤»·’·l2l95