Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut


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Date: December 31, 1969
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State: Connecticut
Category: District Court of Connecticut
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Case 3:02-cv-02101-AVC Document 49-2 Filed 10/11/2005 Page 1 of 1
LATV oameas
iLEV§I‘ 557 PRi>t5PEC'E` ATEDILTE ° HARTFORD, CONNECTICUT O610§-2922
TELEPHONE: (S60) 233-982.1. ° FAX {S60) 232-7213
DA.l‘~.l§EL E. LIVIN43S'1`ON ~ _ TU {-§O\%`AR|i S‘1'REE'&`
GREZGG D. Ai}LE§§' L.OI{DON, CG·2\lN`t·ZC'i'lC!LT1` (:635321)
RUTH L. P·`L•'LD.—t (850) '1'H()1NL—\.5 HZ BIEHCLFLYOHN
MARY KELLY r·1,.k;L¤.ta m;1=u· any H.mT£=J1m ormcm
PETER GOSELEN
DEBORAH L. MCEQENNA
HEBTRI E
_ "_‘ warraws orizracr DIAL: ‘
- gasp) 5704638
I _;__ "pdgoselin@Epm.or
· November 4, 2004
M.J. l\/lcCarthy
Assistant Attorney General
Office of the Attorney General ,
55 Elm Street
P.O. Box 120
Hartford, CT 06141
RE: Welfare v. O'Meara i
Dear l\/l.J.,- A _
Thank you for your letter of October 27, 2004, supplementing the defendant’s
discovery responses. We look forward to receiving your privilege log. We agree
that we will provide a verification of the.plaintiff‘s interrogatory responses.
The scheduling problem amounts to this. Officially, discovery is closed. Yet the
plaintiff does not yet know which documents the defendant will claim are
privileged — including both documents that were previously produced and that g
would otherwise presumably be part ofthe recent supplementing. l can foresee
a danger here that there will be a dispute about the defendant’s claims of
privilege, and plainly that would have to be resolved before a motion for summary
judgment. »
Once we know what it is that you claim you do not have to provide, we can
certainlyjoin in a proposal to the Court regarding the scheduling of dispositive
motions. `
Sincerely, ~ °
,4* ,2 .
‘,] z"__/
Peter Goselin T