Free Motion for Conference - District Court of Connecticut - Connecticut

Case 3:02-cv-00223-CFD

Document 124

Filed 03/20/2008

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

: : : v. : : STATE OF CONNECTICUT, COMMISSION ON : HUMAN RIGHTS AND OPPORTUNITIES, : NICHOLAS CIOFFI, Chairperson; RICHARD : ROBINSON, Commissioner and Chairperson; : CYNTHIA WATTS ELDER, Executive Director; : and LEANNE APPLETON, Business Manager : Defendants. :

JEWEL E. BROWN, Plaintiff,

CASE NO. 3:02CV223(CFD)

March 19, 2008

DEFENDANTS' MOTION FOR STATUS CONFERENCE

COMES NOW defendants Cynthia Watts Elder, Vivian Blackford and Leanne Appleton requesting a status conference be held in the above-captioned matter. In support of the motion the defendants, through counsel, show the court as follows: 1. On March 10, 2008 (Doc. # 123) the court granted defendants' Motion for

Partial Summary Judgment. The Court outright dismissed state agencies Connecticut Commission on Human Rights, Department of Administrative Services and the Office of Policy and Management. The Court further dismissed Barbara Waters, Marc Ryan, Nicholas Cioffi and Richard Robinson as defendants in their individual capacities. 2. The lone remaining counts pursuant to 42 U.S.C. § 1981 and 1983 are

against substitute defendants in their official capacities for the purposes of prospective injunctive relief and against defendants Watts Elder, Appleton and Blackford in their official and personal capacities.

Case 3:02-cv-00223-CFD

Document 124

Filed 03/20/2008

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3.

The plaintiff's Second Substituted Complaint is a lengthy rambling set of

allegations that the court in its summary judgment ruling noted that the "current version of the complaint presents a series of factual allegations in thirteen counts, but does not specify to which defendants or which laws each allegation pertains." 4. In order for the defendants to depose Mr. Brown, and avoid generalized

answers lacking any specificity or Mr. Brown testifying that everything will all come out in discovery, the defendants request this conference so as to clarify the exact allegations and causes of action against each of the remaining individual defendants. 5. Alternatively, the defendants ask that the court order that the plaintiff be

prepared at his deposition to testify to: (1) to specify those allegations that apply to each defendant and (2) the facts that support any claim against the three remaining individual defendants. 6. Defendants intend to file for summary judgment and desire to complete

Mr. Brown's deposition expeditiously. 1 7. The undersigned has contacted the plaintiff, who is appearing pro se,

regarding the filing of this motion. WHEREFORE, the defendants respectfully request that the Court order a status conference to clarify the remaining issues in the instant matter.

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The Court has previously granted permission to notice the deposition of Mr. Brown to address the remaining issues following the Court's ruling on the Motion for Partial Summary Judgment.

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Case 3:02-cv-00223-CFD

Document 124

Filed 03/20/2008

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DEFENDANTS, RICHARD BLUMENTHAL ATTORNEY GENERAL

By:

______________________________ Joseph A. Jordano Assistant Attorney General 55 Elm Street, P.O. Box 120 Hartford, CT 06141-1020 Tel: (860) 808-5340 Fax: (860) 808-5383 E-mail address: [email protected] Federal Bar # ct21487

CERTIFICATE OF SERVICE The undersigned hereby certifies that on this 19th day of March, 2008 a copy of the aforementioned Defendants' Motion for Status Conference was sent by First Class United States mail, postage prepaid to: Jewel E. Brown, Pro Se 21 Brewster Road South Windsor, CT 06074

_____________________________ Joseph A. Jordano Assistant Attorney General

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