Free Response - District Court of Connecticut - Connecticut

. Case 3:00-cv-00973-AHN Document 97 Filed O2/15/2005 Pa%eH of 4 i
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Unrrsn srxrss nrsrmcr COURT
DISTRICT on connscrrcur t
rriviornv Hnvss ; civrr. Action no; 3:00 cv 0073 (Answer) i
Plaintiff : ,
vs. i $3
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COMPASS GROUP UsA, inc., ; ,3;;,; .. gs: j
d/b/a EUREST mums SERVICES ; ggyg ¤¤ Egg j l l
and CARY ORLANDI ; FEBRUARY 14, 2005 tp;-, as j
Defendants : 79 lm.? l
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Rrxrnrrinvs omscrrons ro 0m:N0Asrrs· j
PROPOSED usr or sxnrsrrs j
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Pursuant to Paragraph 3 of this Court’s Pre—trial Order, objections on the grounds of j
relevance are reserved for a later date. Otherwise, the Plaintiff objects as follows:
Exhibit # 4 -- Letter from third party (Lane Press) describing results of Lane Press survey of its
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employees and providing notice of termination of services. j
Objection: Hearsay and does not qualify for Rule 803(6) adrnissibility.
Exhibit #8 —— Results of survey conducted by outside company OCM allegedly completed by j
unidentified individual.
Objection: Hearsay and does not qualify for admission under Rule 803(6).
Exhibit # 17 -— Memorandum of defendant employees referencing hearsay statements of non-
employees. j
Objection: Hearsay and does not qualify for admission under Rule 803(6). g
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’ r Case 3:00-cv-00973-AHN Document 97 Filed O2/15/2005 Page 2 of 4
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Exhibit #21 —- Unsigned customer suwey.
Objection: I-iearsay and does not qualify for admission under Rule 803(6). Not authenticated by U l
author Rule 90l(a).
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Exhibit #22 —— Letter from Defendant to a customer containing hearsay and self-serving i
statements.
Objection: Hearsay and does not qualify for admission for Rule 803(6) exception. Also
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inadmissible under Rule 403.
Exhibit #23 -- Anonymous letter alleging Plaintiff had an affair.
Objection: Hearsay and does not qualify for admission for Rule 803(6) exception. Also 1
excludable under Rule 403 and Rule 90l as unauthenticated and unsigned. i
Exhibit #35 -— Declaration of Robert Berg attached to the Defendants’ Motion for Summary
Judgment. {
Objection: Hearsay.
Exhibit #16 ·- Memo 10/ I6/97, Hayes to Orlandi, includes a note from Orlandi which appears i
not to be part ofthis exhibit.
Objection: May be irrelevant to the actual exhibit.
Exhibit #20 -— Two copies of memorandum of l/l2/98 from Orlandi to Hayes.
Objection: No objection to clean copy. Handwriting on second copy not legible, possibly
irrelevant and hearsay. R
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· ' Case 3:00-cv-00973-AHN Document 97 Filed O2/15/2005 Page3of4 I

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Exhibit #’s 37 & 38 -- Documents containing data.
Objection: Possible authentication objection under Rule 901. Plaintiffs council will first make I I
effort to authenticate. I
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RESPECT U SU ITTED I
By:
Stephen F. Mc leney
Federal Bar ct04073
McE1eney& Grail, LLC
363 Main St t
Hartford, Connecticut 06106
His Attorneys
[email protected]
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· ' Case 3:00-cv-00973-AHN Document 97 Filed 02/15/2005 Page 4 of 4 i
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CERTIFICATION
I hereby certify that a copy of the foregoing was mailed, first class postage prepaid, on i i
this l4‘*‘ day of February, 2005, to the following counsel of record: l
Christopher Kenney, Esq. i t
Margaret Paget, Esq.
Sherin and Lodgen LLP l
l0l Federal Street
Boston, MA 02110 E
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Lawrence Peikes, Esq. l
Wiggin and Dana LLP T
400 Atlantic Street t
Stamford, CT 06901 I
Fred Frangie, Esq. · . I
Robert Fortgang & Associates ,/ __ »
573 Hopmeadow Street /{ `
Simsbury, CT 06070 l
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Stephen FX __ c
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