Free Reply to Response to Motion - District Court of Connecticut - Connecticut

Case 2:91 —cv-OO1 80-RNC Document 545 Filed O1/O9/2008 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
P.J., et al., : CIVIL NO. 2:9lcv00l80 (RNC)
Plaintwfs ;
v.
STATE OF CONNECTICUT, et al
Defendants 1 JANUARY 8, 2008
NOTICE OF FILING OF DEFENDANTS’ SUPPLEMENTAL
RESPONSE TO PLAINTIFF’S MOTION TO COMPEL
By Order of the Court, Martinez, J, Defendants’ Motion Seeking Leave To File
Supplemental Response To The Plaintiffs’ "Motion To Compel" was granted on December 21,
2007. (Doc. #544). Therefore, the defendants in the above action respectfully amend their
supplemental response to plaintiffs’ March 30, 3007 "Motion for Disclosure and Production" to
include the attached "Defendant’s Supplemental Response to Plaintiff s Motion for Disclosure
and Production dated March 30, 2007."
Defendants’ contend that the disclosure of this response will seriously narrow or possibly
moot plaintiffs pending "Motion to Compel" and that the court would benefit greatly from
reviewing its contents before considering plaintiffs’ pending motion. In addition, the
defendants’ recent disclosure is consistent with the spirit of Local Rule of Civil Procedure 37(b)
which requires that in the event of a discovery dispute each side shall provide the court with "a
specific verbatim listing of each of the items of discovery sought or opposed, and immediately
l

Case 2:91-cv-00180-RNC Document 545 Filed O1/O9/2008 Page 2 of 3
following each specification shall set forth the reason why the item should be allowed or
disallowed."
Defendants continue to assert and their previous responses to Plaintiffs’ Motion to
Compel demonstrate, that they have made every reasonable effort to provide plaintiffs with the
information and data requested consistent with the parties’ Settlement Agreement, directives of
the United States Department of Education ("USDOE"), and fair resource allocation.
DEFENDANTS
STATE OF CONNECTICUT, ET AL
RICHARD BLUMENTHAL
ATTORNEY GENERAL
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BY: /S/ §»=4,·/x I . if I- ~/.,t,,»,` £;7'i'é`~· mt
Darren P. Cunningham ; ,
Assistant Attorney General
Federal Bar No. ct253 80
55 Elm Street, P.O. Box 120
Hartford, CT 06141-0120
Tel: (860) 808-5210
Fax: (860) 808-5385
darrcn.cunninghamgqilpo.statc.ct.us

Case 2:91-cv-00180-RNC Document 545 Filed O1/O9/2008 Page 3 of 3
CERTIFICATION
I hereby certify that a copy ofthe foregoing was mailed in accordance with Rule 5(b) of
the Federal Rules of Civil Procedure on this 8th day ofJanuary, 2008, first class postage prepaid
to:
The Honorable Donna Martinez
United States Magistrate Judge
450 Main Street
Hartford, CT 06103
David C. Shaw, Esq.
34 Jerome Avenue, Suite 210
Bloomfield, CT 06002
Frank Laski, Esq.
Mental Health Legal Advisors Committee
294 Washington St., Suite 320
Boston, MA 02108
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Darren P. Cunningham .
Assistant Attomey General V Y