Free Motion to Compel - District Court of Connecticut - Connecticut

Case 3:02-cv-00616-AHN

Document 42

Filed 05/28/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MICHELE CLOUTIER, Plaintiff, v. GORDON R. ENGLAND, SECRETARY OF THE NAVY, Defendant. : : : : : MAY 26, 2004 CIV. NO. 3:02CV616(AHN)

DEFENDANT'S MOTION TO COMPEL ANSWERS TO WRITTEN DISCOVERY AND ATTENDANCE AT DEPOSITION AND MEDICAL EXAMINATION Pursuant to Fed. R. Civ. P. 37(a) and D. Conn. L. Civ. R. 37(a), the defendant Secretary of the Navy moves for an order compelling the plaintiff to serve answers to interrogatories and requests for production, appear for a medical examination, and appear for deposition. The undersigned counsel certifies that

counsel have conferred in good faith over an extended period of time regarding these discovery failures and are at impasse. In

support of this Motion, the defendant submits the accompanying memorandum of law with two exhibits. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

CAROLYN A. IKARI ASSISTANT UNITED STATES ATTORNEY 450 Main Street, Room 328 Hartford, Connecticut 06103 (860) 947-1101 Federal Bar No. ct13437 ORAL ARGUMENT IS NOT REQUESTED

Case 3:02-cv-00616-AHN

Document 42

Filed 05/28/2004

Page 2 of 2

CERTIFICATION OF SERVICE I hereby certify that a copy of the within and foregoing has been sent via facsimile and mailed, postage prepaid, this 26th day of June, 2004, to: Edward Formisano Sinapi, Formisano & Company, Ltd. 100 Midway Place Suite 1 Cranston, RI 02920-5707 and mailed, postage prepaid, to: Raymond T. Trebisacci 398 Liberty Street Pawcatuck, CT 06739 AUSA William Brown Office of the U.S. Attorney 157 Church Street, 23rd Floor New Haven, Connecticut 06510 Honorable Holly B. Fitzsimmons United States Magistrate Judge United States District Court 915 Lafayette Boulevard Bridgeport, Connecticut 06604

CAROLYN A. IKARI ASSISTANT UNITED STATES ATTORNEY

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