A former agent may be entitled to discovery on the topic of interns, if that helps a factfinder decide whether intern agents who remained at the defendant qualified as "employees," as opposed to independent contractors. In January 2009, the defendant, State Farm Mutual Automobile Insurance Co., allegedly hired the plaintiff, Ashraf Uddin, as an intern agent. In August 2009, Uddin signed a one-year, independent contractor agreement. At the end of the year, State Farm allegedly informed the plaintiff that he had not met goals, which required that approximately 80 percent of policies he wrote be for LAM, or "long annual mileage." Allegedly, Uddin repeatedly protested State Farm's policies. In part, Uddin wanted to tailor individual policies to individual customers, and many of his customers did not qualify for the "long annual mileage" policies, because they were elderly or disabled and did not drive long distances. Also, the plaintiff allegedly was unhappy that State Farm allegedly investigated minority clients and ruled that they did not meet State Farm's criteria. Uddin sued State Farm and alleged wrongful and retaliatory discharge, in violation of C.G.S. §31-51q, because he allegedly protested policy classifications and racial profiling. Uddin sought to depose his former supervisor, Melissa Valentin and filed a motion to compel, pursuant to Practice Book §13-14. State Farm maintained its treatment of interns was not relevant, because the plaintiff was no longer an intern. State Farm protested that the scope of topics was overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. "State Farm's treatment of [its] interns," wrote the court, "is relevant on the issue of whether such treatment was the same or carried over into the period of time State Farms claims Uddin was an independent contractor." In connection with his claim he was discharged because he complained about alleged racial profiling, the plaintiff may obtain information about prior complaints. The court restricted the time period of the plaintiff's inquiry to three years prior to the start of the plaintiff's internship. The court granted in part the plaintiff's motion to compel. 

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