Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:00-cv-00261-TPS

Document 112

Filed 04/18/2006

Page 1 of 4

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

MICHAEL BRAHAM Plaintiff, v. JOHN ARMSTRONG, et al., Defendants.

) ) ) ) ) ) ) ) )

3:00-cv-00261-TPS

April 18, 2006

MOTION FOR IN CAMERA REVIEW The plaintiff, Michael Braham, respectfully moves for judicial in camera review of documents provided to plaintiff in redacted form. Plaintiff requests unredacted versions of these documents in order to prepare for trial in this case. Opposing counsel objects to turning over unredacted versions of these documents, but does not object to the court reviewing these documents in camera (see attached affidavit). The documents provided in redacted form are: 1. Incident Report Package. This includes redacted copies of: a. Critical Incident Summary (includes hand-written notation "Revised") b. Shift Supervisor Summary c. Incident Report (Pages 1, 3, 4, & unnumbered [4 pages total]) d. Incident Report Supplement (Pages 2-8) e. Informational Log (2 Pages) f. Photocopies of photos of Mr. Braham (2 Pages) g. Use of Force Reports (8 pages) 2. Plaintiff's Medical File

Case 3:00-cv-00261-TPS

Document 112

Filed 04/18/2006

Page 2 of 4

3. Unit Log Book 4. Staff Log Book

Opposing counsel identified all of these documents as trial exhibits in the Joint Trial Memorandum filed in this case on August 15, 2002, (Doc. # 69). The exhibit numbers listed in the Joint Trial Memorandum are Exhibits, 101, 103, 115, and 116 respectively. Plaintiff respectfully requests that this motion for in camera review be granted. Respectfully submitted,

/s/ Brett Dignam ct00283 Jerome N. Frank Legal Services Organization Yale Law School P.O. Box 209090 New Haven, CT 06520-9090 203-432-4800 [email protected] Counsel for the Plaintiff

Case 3:00-cv-00261-TPS

Document 112

Filed 04/18/2006

Page 3 of 4

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

MICHAEL BRAHAM Plaintiff, v. JOHN ARMSTRONG, et al., Defendants.

) ) ) ) ) ) ) ) )

3:00-cv-00261-TPS

April 18, 2006

AFFIDAVIT OF COMPLIANCE WITH LOC. R. CIV. P. 37(a)(2)

Plaintiffs counsel has conferred with opposing counsel in an effort in good faith to resolve by agreement the issues raised by this Motion for In Camera Review without the intervention of the Court, and has been unable to reach such an agreement.

Respectfully Submitted,

/s/ Brett Dignam
ct00283

Jerome N. Frank Legal Services Organization Yale Law School P.O. Box 209090 New Haven, CT 06520-9090 203-432-4800 [email protected] Counsel for the Plaintiff

Case 3:00-cv-00261-TPS

Document 112

Filed 04/18/2006

Page 4 of 4

CERTIFICATE OF SERVICE This is to certify that on April 18, 2006, a copy of the foregoing Motion For In Camera Review was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by email to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing though the Court's CM/ECF system. /s/ Brett Dignam