Free Notice (Other) - District Court of Connecticut - Connecticut

Case 3:03-cv-00943-AWT Document 181 Filed 06/12/2008 Page 1 of 2
UNITED STATES DISTRICT COURT
FOR THE
DISTRICT OF CONNECTICUT
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GARY SESSION * CIVIL ACTION NO.
PLAINTIFF * 3:03—CV—00943 (AWT)
=¤=
VS. *
CITY OF NEW HAVEN; STEPHEN * JUNE 12, 2008
COPPOLA; AND EDWIN RODRIGUEZ *
*
DEFENDAN TS *
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NOTICE OF FILING OF PROPOSED ORDER REGARDING DISCLOSURE OF
DOCUMENTS PURSUANT TO FED. R. CIV. PRO. 26§C [ (1) {QQ
The Defendant, Edwin Rodriguez, hereby submits a Proposed Order, attached as Exhibit A,
in response to the Cou1t’s June 4, 2008 Order regarding the Defendant’s Motion for Protective
Order (#139) and the Plaintiffs Cross-Motion to Compel (#141). The Defendant is ordered to
produce those portions of his personnel file and internal affairs tile that have not been produced.
The Defendant submits the proposed order as a result of his concems raised in his Motion for
Protective Order regarding the potentially prejudicial and confidential nature of the items being
produced.
The undersigned attempted to contact the Plaintiff via telephone and via e—mail to discuss
the proposed order but was unable to make contact. Accordingly, the parties have not yet reached a
consensus regarding the proposed order. Because the parties have not reached an agreement as to
the proposed order, the Defendant submits, herewith, a memorandum of law in support of his

Case 3:03-cv-00943-AWT Document 181 Filed 06/12/2008 Page 2 of 2
proposed order.
Respectfully submitted,
DEFENDAN TS,
/s/ Meghan K. Gallagher
Meghan K. Gallagher
Federal Bar No. ct26914
Susman, Duffy & Segaloft, P.C.
55 Whitney Avenue
New Haven, Cormecticut 06510
Phone: (203) 624-9830
Fax: (203) 562-8430
E-mail: mgallagher@[email protected]
CERTIFICATION
I hereby certify that on June 12, 2008 a copy of the foregoing Notice of Proposed Order was
tiled electronically and served by mail on anyone unable to accept electronic tiling. Notice of this
tiling will be sent by e-mail to all parties by operation of the court’s electronic tiling system or by
mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing.
Parties may access this filing through the court’s CM/ECF System.
/s/ Meghan K. Gallagher
Meghan K. Gallagher
Federal Bar No. ct 26914
Susman, Duffy & Segalofh P.C.
55 Whitney Ave.
New Haven, CT 06510
tel.: 203-624-9830
fax: 203-562-8430
[email protected]