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

Case 3:03-cv-00452-CFD Document 67-2 Filed 11/15/2007 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRECT OF CONNECTICUT
DAVID RURAN )
Plaintiff, g CIVIL ACTiON
) NO,
VS. )
BETH EL TEMPLE OF WEST HARTFORD, g
INC g NOVEMBER t5, 2007
Defendant )
AFFTDAVIT OF JOSEPH ANDRIOLA
The undersigned, being duly sworn, hereby deposes and says:
1, l am over eighteen (18) years of age and understand the obligations of an
oath,
2, i am counsel for Beth EI Temple of West-Hartford, Inc., the defendant in
the above—captioned matter,
3, On or about October 30, 2007, counsel for the defendant first received
F’|aintiff’s Responses to i3efendant's First Set of interrogatories, which were dated
February 26, 2007.
4, Plaintiff objected to and did not provide a response to interrogatories
numbers 9, 10, 11 and 13,
5, Defendants counsel in a letter to plaintiffs counsel, dated November 2,
2007, responded to plaintiffs objections and offered to accept answers to specific
requests in that letter as satisfactory compliance with discovery, Said letter was sent
via e-mail and regular rnaii,
OM G°°*l"’l“ $°l¤i*'° Primm {860) 522-6103
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Case 3:03-cv-00452-CFD Document 67-2 Filed 11/15/2007 Page 2 of 3
0. On November B, 2007, defendants counsel, Michael Macllonaid, had a
telephone conference with plaintiffs counsel, William Madsen, in an attempt to resolve
the parties’ differences concerning the plaintiffs objections to discovery. \/Viiliarn
Madsen informed Michael MacDonald that he had not reviewed the letter dated
November 2, 2007,
7. Michael MacDonald directly thereafter, on November 8, 2007, faxed
another copy ofthe letter, dated November 2, 2007, to piaintiffs counsel.
B. On November 12, 2007, defendants counsel, Michael MacDonald, again
called piaintiffs counsel, William Madsen, to attempt to resolve discovery disputes.
\/Viliiam Madsen was unavailable and a voice-—mai| was left for him.
9. On November 13, 2007, defendants counsel, Michael MacDonald, again
called piaintiffs counsel, William Madsen, to attempt to resoive discovery disputes.
V\/iiliam Madsen was unavailable and a voice—rnaii was left for him.
10. To date, plaintiffs counsei has not responded to defendants counsel good
faith efforts to resolve these discovery disputes, even though plaintiffs counsel has had
ample opportunity to respond. For example, plaintiffs counsel was performing
depositions on this case on November 9 and 12, 2007, and did not provide defendants
counsel with a response to his November 2, 2007 letter.
11. Despite good faith efforts, the parties have been unable to reach an
accord concerning their differences over plaintiffs obiections to interrogatories numbers
9,10,11 and 13.
G G d ` S -2-
“° OO wm qumc i’l1or1c {860) 522-6103
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Case 3:03-cv—00452-CFD Document 67-2 Filed 11/15/2007 Page 3 of 3
Josephg ndrioia
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Subscribed and sworn to before me on this§_*5_ day of November, 2007.
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