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

Case 3:OO—cv-00973-AHN Document 78 Filed O1/27/2005 Paget of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
TIMOTHY HAYES,
Case N0.: 3:00CV0973 (AHN) (HBF)
Plaintiff,
-versus-
i COMPASS GROUP USA, INC., d/b/a EUREST
_,,, , DINING SERVICES and CARY ORLANDI,
Defendants. JANUARY 26, 2005
Y PPLICATION OF LOCALCOUNSEL. T9 BE EXCUSED

Pursuant to Conn. L. Civ. R. 83.l(d)1, undersigned local counsel of record for
1 defendants Compass Group USA, Inc. ("Compass Group") and Cary Orlandi (collectively
"defendants") hereby applies for permission to be excused from attendance in court in
connection with the above-captioned suit. In support of said application, counsel states as
follows:
Jury selection in this employment discrimination case is scheduled to be conducted on
Friday, February 18, 2005, and trial is set to begin on the following Monday, February 21, 2005.
Throughout the course of this litigation, defendants’ visiting counsel, currently Christopher
Kenney, Esq. and Margaret Paget, Esq. of Sherin and Lodgen LLP, have maintained primary
up g g responsibility for defending this action. By Order dated July 22, 2003, Attorneys Kenney and
J T Paget were admitted to practice before this Court for purposes of representing defendants in this
particular case. Shortly thereafter, both visiting lawyers entered their appearances on behalf of
defendants.
ORAL ARGUMENT NOT REQUESTED

l , Case 3:OO—cv-00973-AHN Document 78 Filed O1/27/2005 Page 2 of 3
j Attorneys Kenney and Paget, and their Firm, have a longstanding relationship with
l
Compass Group, and have represented Compass Group in other lawsuits alleging similar claims
A e of employment discrimination. While local counsel has carefully monitored the proceedings,
Attorneys Kenney and Paget have maintained primary responsibility for the representation of
I . defendants’ in this case and, per defendants’ wishes, will serve as lead counsel for defendants at
i A trial. Accordingly, defendants respectfully submit that the presence of local counsel at the trial
i and related proceedings is not necessary to the defense of this action, and would serve to impose
an undue expense on defendants.
l
For these reasons, undersigned counsel respectfully requests that this application to be
excused from appearing in Court be granted.
l Respectfully submitted,
THE DEFENDANTS,
T COMPASS GROUP USA, and CARY
i *`· ORLANDI
Lawrence Peikes (ct 07913)
P Wiggin and Dana LLP
Their Attomeys
400 Atlantic Street
Stamford, CT 06901-3234
(203) 363-7600 »
(203) 363-7676 (fax)
-and-
Christopher A. Kenney (ct25O l 7)
Margaret H. Paget (ct25016)
, _ Sherin and Lodgen LLP
if 101 Federal Street
A Boston, MA 02110
(617) 646-2000
2

_ I it Case 3:OO—cv-00973-AHN Document 78 Filed O1/27/2005 Page 3 of 3
- CERTIFICATE OF SERVICE
A This is to certify that on the 26th day of January, 2005, a true and correct copy of the
foregoing APPLICATION OF LOCAL COUNSEL TO BE EXCUSED FROM ATTENDANCE
IN COURT was served via first—c1ass U.S., postage pre—paid, on the following:
Stephen McEleney, Esq,
McEleney & McGrai1
A 363 Main Street
p p_ Hartford, Connecticut 06106
Lawrence Peikes
x14926x1x97422.1 C
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