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Case 3:02-cv-00860-AVC

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

JOSEPH BURGESON VS. CITY OF NEW HAVEN, ET AL

PRISONER CASE NO. 3:02-cv-860 (AVC) (TPS)

SEPTEMBER 2, 2004

NOTICE OF COMPLIANCE Defendants hereby notify the court, pursuant to its order dated August 6, 2004, that they believe that they have complied with the discovery requests that are the subject of the court's order, and that such compliance was mailed to the plaintiff on either April 5, 2004 or April 6, 2004. On either of those dates, the following items, some with attachments, were mailed to the plaintiff: 1. Answers of Defendant Warren Palmer to Plaintiff's Resubmitted These resubmitted interrogatories corrected problems contained in

Interrogatories.

earlier interrogatories served by the plaintiff, that resulted in objections being interposed by this defendant, and this defendant answered the resubmitted interrogatories. 2. Defendant Warrant Palmer's Response to Plaintiff's Clarified and

Amended Interrogatories Contained in Plaintiff's Response to Defendants' Objections to His Interrogatories. As the title suggests these clarified and amended interrogatories were filed in response to defendants objections' to earlier interrogatories served by the plaintiff, and this defendant answered these clarified and amended interrogatories.

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3.

Defendant Warren Palmer's Response to Plaintiff's First Set of

Interrogatories. This defendant answered certain of these interrogatories to which no objections had been interposed, and provided answers to other interrogatories where there had been objection without waiving said objections. As to the other interrogatories where objections had been interposed, the plaintiff subsequently served, as noted above, "Resubmitted Interrogatories" and "Clarified and Amended Interrogatories" that were answered by this defendant. 4. Defendant Warren Palmer's Response to Plaintiff's Request for

Documents and Things.

A majority of requests, most of them in the nature of

interrogatories were answered or complied with, as each individual request dictated. Objections were made to certain requests, which happened to be in the nature of interrogatories. Plaintiff's "Resubmitted Interrogatories," his "Amended and Clarified

Interrogatories," and portions of his "Second Request for Production of Documents," served by the plaintiff in response to these objections, were answered by this defendant. 5. Answers of Defendant J.D. Smith to Plaintiff's Resubmitted

Interrogatories.

These resubmitted interrogatories corrected problems contained in

earlier interrogatories served by the plaintiff, that resulted in objections being interposed by this defendant, and this defendant answered the resubmitted interrogatories. 6. Defendant, J.D. Smith's (erroneously giving the name of Warren Palmer in

the caption) Response to Plaintiff's Clarified and Amended Interrogatories Contained in

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Plaintiff's Response to Defendants' Objection to His Interrogatories.

As the title

suggests, these clarified and amended interrogatories were filed in response to defendants' objections to earlier interrogatories served by the plaintiff, and this defendant answered these clarified and amended interrogatories. 7. Defendant J.D. Smith's Responses to Plaintiff's First Set of

Interrogatories. This defendant answered certain of these interrogatories to which no objections had been interposed, and provided answers to other interrogatories were there had been objection without waiving said objections. As to the other interrogatories where objections had been interposed, the plaintiff subsequently served, as noted above, "Resubmitted Interrogatories" and "Clarified and Amended Interrogatories" that were answered by this defendant. 8. Defendant J.D. Smith's Response to Plaintiff's Request for Documents

and Things. A majority of the requests, most of them in the nature of interrogatories were answered or complied with, as each individual request dictated. Objections were made to certain requests, which happened to be in the nature of interrogatories. Plaintiff's "Resubmitted Interrogatories," his "Amended and Clarified Interrogatories," and portions of his "Second Request for Production of Documents," served by him in response to those objections, were answered by this defendant. 9. Response to Plaintiff's Second Request for Production of Documents. Responses, with no objections, were provided to these production requests and documents were provided.

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THE DEFENDANTS,

/s/:_________________________________ Michael A. Wolak, III Assistant Corporation Counsel City of New Haven Office of Corporation Counsel 165 Church Street, 4th Floor New Haven, CT 06510 Tel. No.: (203) 946-7970 Fax No.: (203) 946-7942 E-mail: [email protected] Fed. Bar #ct12681 Their Attorney

CERTIFICATION OF SERVICE This is to certify that the original of the foregoing was mailed, postage prepaid, on September 2, 2004 to the following pro se party: Joseph Burgeson #14101 MacDougall Corrections Institute 1153 East Street ­ South Suffield, CT 06080

/s/:__________________________________ Michael A. Wolak, III

J:\CYCOM32\WPDOCS\D023\P002\00004794.DOC

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