Free Affidavit - District Court of Connecticut - Connecticut


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Pages: 2
Date: December 17, 2004
File Format: PDF
State: Connecticut
Category: District Court of Connecticut
Author: unknown
Word Count: 371 Words, 2,350 Characters
Page Size: 612.72 x 1008 pts
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https://www.findforms.com/pdf_files/ctd/23001/86.pdf

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Case 3:03-cv—0O630—DJS Document 86 Filed 12/16/2004 Page 1 of 2 5
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
MARIO RICHARDS : CIVIL ACTION NO.
PLAINTIFF : 3:03 cv00630 (DJS)
COMPUTER SCIENCES CORPORATION DECEMBER I5, 2004 I
DEF ENDANT
SETIFICATION
The undersigned being duly sworn deposes and says:
I. I, Michael J. Melly, represent the plaintiff, Mario Richards, in this case. E
2. I have spoken to counsel for the defendant on November 5, 2004 and November,
9, 2004 in an attempt to resolve outstanding discovery disputes.
3. The parties were able to resolve some of the disputes, however, plaintiff has yet
to receive anything [accept for copies of two letters to/from USDOL] pursuant to the
agreement. Counsel for the defendant promised that information and items would be I
produced by December 9, 2004. Counsel for the defendant has not communicated back
to counsel for the plaintiff regarding whether or not other items would be forthcoming.
4. On October 26, 2004 I spoke with defendant’s counsel, Tasos Paindiris, who agreed
that the defendant would provide the names and addresses of current CSA’s on or before E
November 5, 2004 and the names and addresses of former CSA”s on or before November
16, 2004, which dates were modified to November I2, 2004 and November 19, 2004





I Case 3:03-cv—0O630—DJS Document 86 Filed 12/16/2004 Page 2 of 2 1
respectively. _
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5. Defendant reneged on this agreement and to date has not provided any names and 1
addresses as promised. Defendant’s reasoning was that plaintiff refused to agree and make
concessions regarding notice issues.
6. At this point, one year and seven months after discovery was served, the plaintiff 1
is yet not aware of whether or not certain relevant infomation and items will be J
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forthcoming. Further, the plaintiffdoes not know when promised items will be
forthcoming. 1
7. I spoke with Tasos Paindiris on December 10, 2004, wherein he was informed of
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plaintiffs intent to file a motion to compel regarding outstanding discovery. 1
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Miami . M ly 1
Subscribed and swom to before me this Ig day of December 2004. 1
@0;/as J. Mullins I
omm. of the Sup. Court