Free Response - District Court of Connecticut - Connecticut

Case 3:00-cv-00380-DJS

Document 170

Filed 11/16/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

MARTA M. PABON V. CASE NO. 3:OOCV380 (DJS) (TPS)

JOSEPH RECKO STATE CREDIT ADJUSTMENT BUREAU, INC.

November 13, 2004

PLAINTIFF'S SUPPLEMENTAL INFORMATION RE COSTS The Clerk denied costs for the depositions of Ferranti and Vecchitto subject to plaintiff'showing how these were used in the preparation of the case. First, the depositions s were submitted in support of summary judgment, Doc. No. 76 at Ex. 9, 10. They were used in support of plaintiff'Local Rule 9(c)1 Statement at ¶¶ 12, 46, 47, 49, 50, 51, 52, 53, 54, 56, s 57, 58, 61, 62. Since plaintiff was successful in her motion for summary judgment, the cost of those depositions should be allowed. D. Conn. Local Rule 54(c) 2(ii) allows the costs where the depositions are " in support of a successful motion for summary judgment." used Second, the undersigned affirms that they were necessarily obtained for the preparation of the case. Depositions of defendants and of a third party witness are recognized as essential to gather facts in preparation of the case. Third, aside from the summary judgment ruling, Defendants conceded liability in the maximum amount of damages. The award of costs should recognize that success. Fourth, Defendants conceded that the costs for deposition of Vecchitto were proper, but merely claimed that defendants' share of the costs should be $234.82. Since no judgment entered against co-defendant Ferranti, it is proper to tax the entire amount to these defendants.

Case 3:00-cv-00380-DJS

Document 170

Filed 11/16/2004

Page 2 of 2

THE PLAINTIFF

BY____/s/ Joanne S. Faulkner___ JOANNE S. FAULKNER ct04137 123 Avon Street New Haven, CT 06511-2422 (203) 772-0395
[email protected]

This is to certify that the foregoing was mailed on November 13, 2004, postage prepaid, to: Laurence Nadel 261 Bradley Street New Haven CT 06511

___/s/ Joanne S. Faulkner__ Joanne S. Faulkner

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