Free Affidavit - District Court of Connecticut - Connecticut

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1 { Case 3:00-cv-00973-AHN Document 48 Filed 1 1/O3/2003 Page 1 of 3 `
. UNITED STATES DISTRICT COURT F I I- E D
iii E DISTRICT OF CONNECTICUT
- 21110 NOV - 3 13 lv 30
I OTHY HAYES, ) , A _ ,_ M. 1
) US iJ1STE§E"t,r_t4 Lu_0;·t1 I
" Plaintiff, ) 175 R1 1] G1: :2 Fil 1 1
) C.A. NO.: 3:00 CV 0973 (AHN) (HBF) ·
v. ) 1
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COMPASS GROUP USA, INC., ) .
d/b/a EUREST DINING SERVICES ) 1
and CARY ORLANDI, ) _
)
Defendants. )
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AFFIDAVIT OF CHRISTOPHER A. KENNEY l
IN SUPPORT OF DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT ON ALL COUNTS OF PLAINTIFF’S COMPLAINT
I, Christopher A. Kenney, depose:
l. I am an attorney duly admitted to practice before the United States District
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Court for the District of Massachusetts. I represent defendant Compass Group USA, Inc.
in this case. ·
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2. Attached as Tab A is a true and accurate copy of excerpts from the 1
deposition of Cary Orlandi taken on March 9, 2001, 1
3. Attached as Tab B is a true and accurate copy of excerpts from the
deposition of Timothy Hayes taken on March 8, 2001. i
4. Attached as Tab C is a true and accurate copy of a Profile and Change
Form for Timothy Hayes dated December 1996.
5. Attached as Tab D is a true and accurate copy of a Memorandum from
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Cary Orlandi to Timothy Hayes dated August 5, 1997.
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6. Attached as Tab E is a true and accurate copy of a Memorandum from
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il i Case 3:00-cv-00973-AHN Document 48 Filed 1 1/O3/2003 Page 2 of 3
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Cary Orlandi to Timothy Hayes dated August 13, 1997. 1
7. Attached as Tab F is a true and accurate copy of a Memorandum from i
Cary Orlandi to Timothy Hayes dated September 24, 1997.
8. Attached as Tab G is a true and accurate copy of a Memorandum from
Cary Orlandi to Timothy Hayes dated September 30, 1997.
9. Attached as Tab H is a true and accurate copy of a Memorandum from
1 Cary Orlandi to Timothy Hayes dated October 9, 1997. i
10. Attached as Tab I is a true and accurate copy of a Memorandum from
Timothy Hayes to Cary Orlandi dated October 13, 1997. R
p I 1. Attached as Tab J is a true and accurate copy of a Letter from Timothy
i Hayes to Cary Orlandi and Bob Kelley dated October 14, 1997. a
12. Attached as Tab K is a true and accurate copy of a Performance
Evaluation for Timothy Hayes dated December 15, 1997.
13. Attached as Tab L is a true and accurate copy of a Memorandum from 1
Cary Orlandi dated December 16, 1997.
14. Attached as Tab M is a true and accurate copy of a Memorandum from I
Cary Orlandi to Timothy Hayes dated January 12, 1998.
15. Attached as Tab N is a true and accurate copy of a Letter from James
Carothers and Cary Orlandi to Robert K. Berg dated March 19, 1998.
16. Attached as Tab O is a true and accurate copy of a Memorandum from
Timothy Hayes to Cary Orlandi dated March 25, 1998. U - 1
17. Attached as Tab P is a true and accurate copy of the Declaration of Robert i
K. Berg dated September 5, 2003.
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18. Attached as Tab Q is a true and accurate copy of a Memorandum from
l - Cary Orlandi to Timothy Hayes dated April 13, 1998.
19. Attached as Tab R is a true and accurate copy of a Letter from Connecticut
Schools Food Service Directors to Canteen dated May 27, 1998.
20. Attached as Tab S is a true and accurate copy of a Letter from Cary
K Orlandi to Timothy Hayes dated June l, 1998.
21. Attached as Tab T is a true and accurate copy of excerpts from the
l deposition of Timothy Hayes taken on September 16, 2003.
i 22. Attached as Tab U is a true and accurate copy of excerpts from the
deposition of Timothy Hayes taken on July 5, 2001 .
23. Attached as Tab V is a true and accurate copy of Compass employee
demographic information.
24. Attached as Tab W is a true and accurate copy of Plaintiffs Responses to
Defendants’ Second Set of Interrogatories, No. 7.
25. Attached as Tab X is a true and accurate copy of Defendants’ Second Set
of interrogatories, No. 9.
26. Attached as Tab Y is a true and accurate copy ofthe Complaint in this
action, dated May 25, 2000.
i 27. Attached as Tab Z is a true and accurate copy of the Compass Group l
Employee Data Sheet of Cary Orlandi, dated January 2, 2003.
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Signed under the pains and penalties of per y of y · er,) 2003. $
Christopher A. ‘ 'enney
2 nanny cents that n Inst copy ¤r me asm gamma i
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