Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

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_ Case 3:00-cv-00656-SRU Document 92 Filed O4/05/2004 Page 1 of 3 1"”OO° (‘·°)G"$'_¢/ff)
l UNITED STATES DISTRICT COURT L E D l
l DISTRICT OF CONNECTICU _ 1
mt APH 5 p 2, 2 7
UP. ms
MARSHALL CHAMBERS, ) BRIDGE E Off T l
Plaintiff} ) CIVIL No. 3:00CV00656(SRUQ ‘
v. )
) a
ANTHONY PRINCIPI, Secretary, ) l
U.S. Department of Veterans Affairs, ) DATE: April 1, 2004 l
Defendant. ) {
PLAINTIFF’S OPPOSITION 1
TO DEFENDANT’S MOTION IN LIMINE
Plaintiff hereby objects to Defendant's Motion in limine, on the grounds
set forth in the attached Memorandum of Law.
THE PLAINTIFF l
MA HALL CH S
i i
By: {T/créwmx/7 »- 34,.. l
E13 M. PILGRIM, Esq.
Law Offices of Caleb M. Pilgrim, LLC w
1404 Whalley Avenue — 2**** Floor
New Haven, CT 06510
Tel; 203-387-2524
Federal Bar No. ct 14857
l
CERTIFICATION <
This is to certify that a copy of the foregoing was mailed, postage prepaid, this 15*
day of April 2004 to Attorney Lauren , , AUSA, US DO] 157 Church Street,
New Haven, cr 06510. Q I
/ ` rc., `
B M. PILGRI , Esq. `
l
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I ' __ ‘ Case 3:00-cv-00656-SRU Document 92 Filed O4/05/2004 Page 2 of 3
UNITED STATES DISTRICT COU ‘
I DISTRICT OF CONNECTICUT$ E L E D I
ZIIIIII APR -5 P 2= 2'I
MARSHALL CHAMBERS, ) I
Plaintiff] ) 0.5. DISTRICT COURT I
I CIVIL N@BIf)@1f>El\Vd0@£]tiIIIsRU) I
V. ] I
) .
ANTHONY PRINCIPI, Secretary, ) DATE: April 1, 2004 I
U.S. Department of Veterans Affairs, ) I
Defendant. ) I
PLAINTIFF’S MEMORANDUM IN SUPPORT OF I
OPPOSITION TO DEFENDANT’S MOTION IN LIMINE I
Plaintiff hereby submits the instant Memorandum of Law in support of his I
I
opposition to Defendant’s Motion in limine. Defendant's motion seeks to
preclude the Plaintiff from introducing sundry exhibits, and certain testimony on
the ground that the Plaintiff had failed to produce the information requested by I
the Defendant. Plaintiff has supplied a list of all relevant exhibits, and copies of
said exhibits to the Defendant. The Defendant's motion is moot and should
therefore be denied.
I
On or about March 25, 2004, Plaintiff submitted his initial List of ·Witnesses and
Exhibits. On March 31, 2004, Plaintiff submitted to Defendants counsel an I
amended List of Exhibits with asterisk (*) denoting all those exhibits, which
Plaintiff would seek to introduce at trial. In addition, Plaintiff had faxed to I
Defendant's counsel a list of those witnesses Plaintiff expected to call at the
commencement of trial on April 5, 2004. On or about April 1, 2004, Plaintiff also I
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“ _ * Case 3:00-cv-00656-SRU Document 92 Filed O4/05/2004 Page 3 of 3
faxed to the Defendant a letter in which he advised Defendant's counsel that he
intended to introduce admissions by the Defendant concerning the issues of
employment discrimination at the defendant VA at the time the Plaintiff was I
l
employed with the Defendant.
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Based on the foregoing, it is crystal clear that Plaintiff has complied with his duty
to disclose witnesses and exhibits to be offered at trial. Defendants motion is [I
1
thus moot, and should be denied.
WHEREFORE, Plaintiff objects to Defendants Motion in limine on the grounds
that Defendant's motion is without merit, and should be denied.
i>LA1Nt11¤1= l
MA _ ALL CI·IAg§ N
By; <::.·:·u¤er&r¤»iB{L/ __ -Qn,,
CALEB M. PILGRI , Esq.
‘ Law Offices of Caleb M. Pilgrim, LLC !
1404 Whalley Avenue - 2nd Floor
New Haven, CT 06510 I
Tel: 203-387-2524 ‘
Federal Bar No. ct 14857 )
CERTIFICATION
This is to certify that a copy of the foregoing was mailed, postage prepaid, this 15* `
day of April 2004 to Attorney Lauren MQ Nash, AUSA, US DO] 157 Church I
Str t, N H , CT 06510. ` l
ee ew aven Q !
eee/ers-AMK ·-A M .
EB M. PILGRI , Esq. l
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