Free Motion for Order - District Court of Connecticut - Connecticut

Case 2:91-cv-00180-RNC

Document 566-5

Filed 07/15/2008

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E X H I B I T B2

Case 2:91-cv-00180-RNC

Document 566-5

Filed 07/15/2008

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT P.J., et al., Plaintiffs, v. STATE OF CONNECTICUT, et al. Defendants. : : : : : : CIVIL NO. 291CV00180 (RNC)

JUNE 12, 2008

NOTICE OF DEPOSITION Please take notice that the plaintiffs will take the oral deposition of BRIAN CUNNANE, pursuant to Rule 30(a) and (b) of the Federal Rules of Civil Procedure, on JULY 8, 2008, at 10:00 a.m. at the Law Offices of David C. Shaw, LLC, 34 Jerome Avenue, Suite 210, Bloomfield, Connecticut. Pursuant to Fed. R. Civ. P. 30 and 34, deponent is requested to bring the following documents1 to the deposition: 1. Documents necessary to help you answer questions about the status of the implementation of the Settlement Agreement in this matter. The deposition will be taken upon oral examination, pursuant to Federal Rules of Civil Procedures, before Post Reporting Service. The deposition will continue from day to day until completed, subject to such adjournment as may be agreed upon by counsel. Opposing counsel is invited to attend and cross-examine the witness. The testimony will be used for discovery

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The word "document" as used herein includes all writings, drawings, graphs, charts, photographs, phonorecords, computer data bases, CD Roms, and other data compilations from which information can be obtained and translated, if necessary, into a reasonably usable form. These documents include any material stored in any other electronic manner as well.
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Case 2:91-cv-00180-RNC

Document 566-5

Filed 07/15/2008

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purposes and may be introduced at trial.

PLAINTIFFS By /s/ David C. Shaw David C. Shaw, Esq. Fed. Bar No. ct05239 Law Offices of David C. Shaw LLC 34 Jerome Ave., Suite 210 Bloomfield, CT 06002 Tel. (860) 242-1238 Fax. (860) 242-1507 Email [email protected]

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Case 2:91-cv-00180-RNC

Document 566-5

Filed 07/15/2008

Page 4 of 4

CERTIFICATION This is to certify that a copy of the foregoing was sent first class, postage prepaid mail to counsel of record on June 12, 2008: Darren P. Cunningham Assistant Attorney General State of Connecticut P.O. Box 120 Hartford, CT 06141

/s/ David C. Shaw David C. Shaw, Esq.

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