Free Motion for Miscellaneous Relief - District Court of Connecticut - Connecticut

Case 3:02-cv-00223-CFD

Document 101

Filed 08/01/2005

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

JEWEL E. BROWN, Plaintiff,

: : : 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. :

CASE NO. 3:02CV0223(CFD)

July 29, 2005

MOTION FOR LEAVE TO TAKE PLAINTIFF'S DEPOSITION

COMES NOW, defendants State of Connecticut, Commission on Human Rights and Opportunities, Nicholas Cioffi, Richard Robinson, Cynthia Watts Elder, and Leanne Appleton and requests leave of the court to reopen discovery for the limited purpose of taking the deposition of the plaintiff, Jewel Brown. In support of their motion, the defendants, through counsel, represent as follows: 1. The discovery deadline in this instant matter was June 30, 2005 (Doc. #

71, dated November 17, 2004). 2. The defendants filed a motion for partial summary judgment and

accompanying papers on or about March 24, 2005 (Doc. #s 84, 85, 86, 87 and 88). 3. 4. The defendants motion is pending. The defendants, through counsel, request permission to notice the

deposition of the plaintiff for the limited purpose of addressing new issues raised by the

Case 3:02-cv-00223-CFD

Document 101

Filed 08/01/2005

Page 2 of 2

plaintiff in the Second Substituted Complaint filed with the Court on February 10, 2005 (Doc. # 80). WHEREFORE, the defendants request leave of the Court to reopen discovery in the above-captioned matter for the limited purpose as stated above.

DEFENDANTS, COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES, ET AL, RICHARD BLUMENTHAL ATTORNEY GENERAL

By:

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

CERTIFICATION The undersigned hereby certifies that on this 29th day of July, 2005 a copy of the aforementioned Motion for Leave to take Plaintiff's Deposition 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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