HEARING PANEL OF THE DISCIPLINARY BOARD OF THE EPISCOPAL CHURCH IN CONNECTICUT ____________________________________ THE EPISCOPAL CHURCH IN CONNECTICUT } } v. } } THE REVEREND AMJAD SAMUEL } RESPONDENT }
____________________________________} ECCT Title IV Matter 2021-1 ______________________________________________________________________________
RESPONDENT’S SUPPLEMENTAL MEMORANDUM IN SUPPORT OF RESPONDENT’S MOTION TO DISMISS et al ___________________________________________________________________ The Respondent, The Reverend Amjad J. Samuel, through his counsel, Michael F. Rehill, submits this Supplemental Memorandum to his Motion to Dismiss et al, as permitted by the Hearing Panel in response to the Church Attorney, Bishop Ian Douglas and the Episcopal Church in Connecticut withholding documents and information from Respondent and Respondent’s Counsel. In violation of Canon IV.13.5., on December 13, 2022, eight months after Mandatory Disclosures were due from the Church Attorney to Respondent’s Counsel, Donald J. Allison provided via email 475 pages of documentation and correspondence of Bishop Ian Douglas to Respondent’s Counsel. The Church Attorney stated that he had received this information approximately 4 weeks prior to sharing it with Respondent’s Counsel. Accordingly, all the dates set forth in the Proposed Discovery Plan and Scheduling Order in Respondent’s Motion to Dismiss et al must be revised. Respondent’s Counsel is unable to provide proposed new dates at this time as the Church Attorney still has more Mandatory Disclosures to provide and there are two motions currently pending. Respondent’s Counsel will send an email to the Church Attorney with a list of the remaining outstanding Mandatory Disclosures based upon information discovered in the 475 pages of documents and prior
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