Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv—001 18—lV|FlK Document 98-3 Filed 05/24/2004 Page 1 of 2 1
. 05/21/2004 FRI 14:57 mx °°2’°°·
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9 ` "`A ‘ Y:
RICHARD DLUl\<[El\”'.I.'HAL S g ss sim sn-ear
AJ.T01<.N15‘r GEMERAJ. *2*, mill] Qi 1:0. Box 120 ,
s o, cé§',v,¢ ttm-tram. . ` ' Tcl: (860) 808-52/0
Offlcc 0f"l`hc Attorney General] Farr: (860) NOU·5385
State of Comtecticut i
p May 21, 2004 l
Greg Bass, Esq. A
Maria Morelli-Wolfe, Esq.
Greater Hartford Legal Aid, 3'° Flr.
999 Asylum Avenue
Hartford, CT 06105-2465
RE: Raymond v. Rowland
Dear Attorneys Bass and Morelli—Wolfe: A
I am in receipt of your letter dated May 19, 2004 demanding that the parties resolve all .
discovery disputes related to Plaintiffs’ Second Request for Production of Documents by A
Monday, May 24, 2004, or a Motion to Compel will be filed. I am writing to indicate that we are
following up on discovery issues and expect to be able to substantially narrow the number of
items in dispute. We are requesting that you hold off on filing a Motion to Compel at least until
the end of next week (May 28) to allow that process to be completed. l
Specifically, I met with J an Miller this morning on a number of items in dispute that I
relate to her area of expertise. I
First, you have asked for copies of Post Authorization Supervisor Reviews. I believe
that you were previously provided a representative copy of this report, at the statewide level. I
arn forwarding a copy ofthe current statewide report for May, 2004. These reports are also
prepared at the supervisor and worker levels. We previously objected to the production of these I
reports on confidentiality grounds based upon our mistaken understanding that client identifiers
were disclosed. r I reviewed the supervisor level and worker-level reports this morning. I did not
see any client identiliers, so the report is available to you. The supervisor and worker level l
reports are extremely voluminous-a stack of paper about 8" thick, double sided for the month of y
A May, 2004, alone. Notwithstanding their volume, I saw essentially no useful infomation. I’ll
nevertheless forward thc stack for May, 2004 to your attention. Apparently, no one in DSS
keeps the reports from prior months. I don’t know whether or not they can be reproduced for t
prior months; however, in light ofthe volume of material and their lack of any probative value, Z
we trust that you will agree that any further production of these reports for any other month is not
warranted.
Second, you verbally narrowed Request No. 3 to items falling within b. iv, i.e. former
TFA recipients who claimed an exemption based upon incapacity, whose claim was denied or
found undetermined by MRT. We are looking into this request and believe that it may he
possible to identify each such individual — not through EMS, but though a separate system
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P Case 3:03-cv-00118-IVIRK Document 98-3 Filed 05/24/2004 Page 2 of 2 l
. 05/21/2004 FRI 14:57 FAX @003/°° 4
Greg Bass, Esq. 4
Marla Morelli-Wolfe, Esq.
Re: Raymond v. Rowland _
May 21, 2004 ‘ 4
Page 2 ` ‘ q
C utilized by the MRT. We should be in 21 position to know whether we can identify these 4
individuals by early next week. Confidentiality issues, however, may preclude disclosure
because these individuals do not appear to be classmembers as evidenced by the denial of a claim
for an exemption by MRT, i.e. they do not appear to be "disabled.”
3. I am also following up on what infomation can be retrieved (and in what time name)
from the "ADDR screen." Again, I should be in a position to report back next week; however, it i
is possible that the ADDR screens could be of assistance in more readily identifying and
individuals who have been granted ADA accommodations. 4
Peter Brown is following up on a number of other requests, including on items where we
_’ indicated that we would produce whatever responsive documents could be located in our
possession or control in response to particular requests, but have not yet produced same. We’ll
follow up on all other issues raised in your letter as soon as we can. _
To the extent that you are asking for information on individuals who are non-
classmembers, we continue to believe that confidentiality requirements preclude disclosure. We
expect, however, to be in at position to substantially narrow the scope of any discovery dispute
shortly, and ask your indulgence at least until May 28m .
Very t ly yours
l . . . _.
Hugh B ber
Assistant Attorney General
HB:dh A i
_ cc: Peter L. Brown, AAG
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