Free Motion for Protective Order - District Court of Connecticut - Connecticut

Case 3:03-cv-00169-AVC Document 84-2 Filed 06/OQ/2004 Page 1 of 2 il
p IN THE UNITED STATES DISTRICT COURT ` i
" FOR THE DISTRICT OF CONNECTICUT
C AHLSTROM VVINDSOR LOCKS LLC, : n
l I Plaintiff _ CASE NO. 3 :03 -CV-01 69-AVC
SCHOELLER & HOESCH, NA, INC.,
P. H. GLATFELTER COMPANY S
an Defendants TUNE 8, 2004
_ AFFIDAVIT OF DINA S. FISHER., ES! Q.
· _ I, Dina S. Fisher, Esq., being duly sworn, do hereby depose and say, to the best of my
personal knowledge, information and belief] as of the below signed date: ‘ Z
U __ U l. I am over the age of IS years and understand the obligations of an oath.
I 2. I am a member in good standing of the bar ofthe state of Connecticut.
3. I am a partner at the law firm of Robinson & Cole LLP, and represent the Defendants U
in this matter.
4. This Affidavit is submitted in support of the Motion For Protective Order filed by
l Defendants, with respect to a Notice of Deposition served by the Plaintiff, Ahlstrom Windsor Locks ‘
. LLC ("Plaintiff") on May 5, 2004, pursuant to Ru1e.30(b)(6) of the Federal Rules of Civil Procedure
U ("Plaintiff’ s 30(b)(6) Notice"). U _
U ‘ 5. I conferred with counsel for the Plaintiff, Sidney R. Bresnick, on two occasions
U in with respect to his May 5, 2004 Notice of Deposition. I explained that Defendants believe the

Case 3:03-cv-00169-AVC Document 84-2 Filed 06/08/2004 Page 2 of 2
Notice is duplicative of already completed discovery, and that it is premature given the pendency
p of Plaintiff s motion to compel.
6. I also explained to Attorney Bresnick that the people he would have to depose as
- . to the subjects identified in the notice would be either Gerhard Slawik or Guenter Grauer, both of
if U whom the Plaintiff has already deposed for well over the permitted time. it
‘ 7. We were unable to resolve the present controversy with respect to the Notice of l
Deposition without court intervention. l Q_
Dina S. Fisher _ e
Subscribed and sworn to before me i _
this Sth day of June, 2004
n 8- l 12 l