Free Motion in Limine - District Court of Connecticut - Connecticut

t 1 Case 3:00-cv—00973-AHN Document 99-2 Filed 02/16/2005 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
C.A. NO.: 3:00 CV 0973 (AHN) (HBF)
TIMOTHY HAYES, )
)
Plaintiff )
)
v. )
)
COMPASS GROUP USA, INC., )
d/b/a EUREST DINING SERVICES)
and CARY ORLANDI, )
)
Defendants. )
)
AFFIDAVIT OF COUNSEL IN SUPPORT OF DEFENDANTS’ MOTION IN LIMINE
TO EXCLUDE AN ECDOTAL EVIDENCE ABOUT THE TERMINATIONS OR
DEMOTIONS OF OTHER FORMER EMPLOYEES
I, Margaret H. Paget on my oath swear and depose:
l. I am an attorney duly admitted to practice in the Commonwealth of Massachusetts. I
am admitted pro hac vice in this action to represent defendants Compass Group USA, Inc. and
Cary Orlandi.
2. Attached as Exhibit A is a true and accurate copy of excerpts from the Deposition of
Timothy Hayes, Volume II, dated July 5, 2001.
3. Attached as Exhibit B is a true and accurate copy of excerpts from the Deposition of
Timothy Hayes, Volume I, dated March 8, 2001.
4. Attached as Exhibit C is a true and accurate copy of excerpts from the Deposition of
Joseph Wawrzynski in Carming v. Compass Group USA, Inc., dated April 20, 2003.
5. Attached as Exhibit D is a true and accurate copy of a Letter from Saverino Correalle
to Cary Orlandi, dated May 29, 1997.
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· { Case 3:00-cv—00973-AHN Document 99-2 Filed 02/16/2005 Page 2 of 2
6. Attached as Exhibit E is a true and accurate copy of excerpts from the Deposition of`
Wayne Patick in Patick v. Compass Group USA, Inc., dated January 27, 2000.
7. Attached as Exhibit F is a true and accurate copy of excerpts of the Deposition of
Cary Orlandi in this action, dated March 9, 2001.
8. Attached as Exhibit G is a tmc and accurate copy of a Settlement and Confidentiality
Agreement between Wayne Patick and Compass Group USA, Inc., dated May 3, 2000.
9. Attached as Exhibit H is a true and accurate copy of the Notice of Dismissal With
Prejudice in Patick v. Compass Group USA, Inc., dated May 4, 2000.
10. Attached as Exhibit I is a tmc and accurate copy of` excerpts from the Deposition of`
Cary Orlandi in Camiing v. Compass Group USA, Inc., dated January 12, 2001.
11. Attached as Exhibit J is a true and accurate copy of` Entry of Judgment on Counts I,
II, and IV in Canning v. Compass Group USA, Inc., dated June 9, 2003.
12. Attached as Exhibit K is a true and accurate copy of an Email from Ed Sanchez to
Cary Orlandi, dated June 12, 2000.
13. Attached as Exhibit L is a true and accurate copy of a Compass Stop Automatic Pay
Form for Anthony Manganello.
Signed under the penalties of perjury this @5% of` February, 2005.
W
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