Free Affidavit - District Court of Connecticut - Connecticut

I _ . Case 3:02-cv-01718-RNC Document 71 Filed O3/05/2004 Page 1 of 3 {
l
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
JOSEPH A. SCHIAVONE : CIVIL ACTION NO. I
CORPORATION, ; 3:02 CV-1718 (RNC)
MICHAEL SCHIAVONE ; —
Plaintiffs, : ,
. · l
PHILIP KASDEN, ; March 5,2004 };;;yt2; =¤ M"
NORTHEAST UTILITIES SERVICE ; L}-, lim
COMPANY, ; gig, U
THE CONNECTICUT LIGHT AND ; j;__ C-, @
POWER COMPANY : '**‘
Defendants, : Z`;
AFFIDAVIT OF CHARLES J. NICOL IN SUPPORT OF
THE CONNECTICUT LIGHT AND POWER COMPANY’S OBJECTION TO
PLAlNTIFFS’ MOTION FOR ORDER COMPELLING DISCOVERY FROM CL&P
Personally appeared Charles J. Nicol,. who, being duly sworn, hereby deposes and says:
1. I am over eighteen (18) years of age and believe in the meaning and the obligation
of an oath.
2. The Statements contained in this Affidavit are based upon my own personal
knowledge.
3. I am a member of the bar and admitted to practice law in the State of Connecticut
and before this Court.
4. I represent The Connecticut Light and Power Company ("CL&P") in the above-
captioned matter. l
l
‘ l
v—v"*_‘ ’ T**—*—————v; ` 3; __ __ V if __
%%`”l "T"”%*`—- v V -- -- L

l
‘ ” P J Case 3:02-cv-01718-RNC Document 71 Filed O3/05/2004 Page 2 of 3 [
5. This Affidavit is in support of The Connecticut Light and Power Company ’s p
Objection to Plaintwfs ' Motion for Order Compelling Discovetjyjrom CL&P, dated March 5,
2004. j
6. Plaintmff First Set of interrogatories and Production Requests Addressed to
Connecticut Light & Power Company ("Discovery Requests") is dated December 2, 2003, and |
consists of 7 interrogatories and 5 document production requests. i
7. CL&P responded to Plaintiffs’ First of Interrogatories on December 30, 2003.
8. CL&P’s response contained objections to each of the interrogatories and 4 of the 5
requests for production; notwithstanding its objections, CL&P provided partial answers to
those portions of the interrogatories and requests that it found unobj ectionable.
9. I had a conference call with Counsel for Plaintiffs, Nicholas J. Harding, on January
23, 2004. Also participating in said conference call was Angela L. Ruggiero, also Counsel for -
CL&P, and Mary McQueeney, Counsel for Plaintiffs. During said conference call, we
explained further the basis for each of CL&P’s objections, providing further specific
information as to why Plaintiffs’ Discovery Requests were overly broad, unduly burdensome,
overly vague, and sought irrelevant information. We offered to withdraw CL&P’s objections
and respond accordingly if Plaintiffs would limit their Discovery Requests appropriately. .
10. CL&P agreed to withdraw its objections to Interrogatory No. 2, Interrogatory No. K
J
7, and Request for Production No. 3.
11. CL&P also agreed to provide revised responses, substituting language suggested
by Plaintiffs’ Counsel. CL&P also· agreed to provide further responses to certain of the j
Discovery Requests.
l 2
_____________ ____,_,________,_;;...__..._....__,__ ..... - 1

` I I , Case 3:02-cv-01718-RNC Document 71 Filed O3/05/2004 Page 3 of 3 {
12. CL&P agreed to provide revised responses by January 30, 2004 and did, in fact, 0
provide the record responses by that date.
Dated at Berlin, Connecticut this Sth day of Mar · . H
1 7/ I F ]
_ A
. es J. ol
Subscribed and sworn to before me on this 5th day of March, 2004.

Angel . Ruggiero
Commissioner of the Superior Court


!
i
i
i
i
1
\
3 i
_ rrrr i