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

Case 3:03-cv-006365DJS Document 40-2 Filed 106%/2003 Page 1 of 4 i
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UNITED STATES DISTRICT COURT it if li":
for the Izll li *5* 0-..4. . ..1. .
DISTRICT OF CONNECTICUT _ ,, t
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MARIO RICHARDS, : CIVIL NO. 303CV00630 {DJ S)
Plaintiff} ; T
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COMPUTER SCIENCES CORPORATION. OCTOBER &_, 2003 i
Defendant. : E
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AFFIDAVIT OF TASOS C. PAINDIRIS K
Tasos C. Paindiris, of Hartford, Connecticut, being first duly sworn, deposes and says: ,
l. I am an attorney with the law firm of Jackson Lewis LLP in Hartford, i
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Connecticut, who are counsel in this civil action for Defendant Computer Sciences Corporation,
("Defendant"). This Affidavit is submitted in support of Defendant’s Memorandum of Law in {
H Opposition to Plaintiff s Motion for Class Certification and Permission to Serve Notice. i
1 2. Defendant’s Memorandum of Law in Opposition to Plaintiff s Motion for Class
Certification and Permission to Serve Notice is premised, in part, on the testimony adduced at
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I Plaintiff s deposition. I affirm that true and correct copies of relevant pages from the deposition
of Plaintiff, Mario Richards, dated September 30, 2003, cited in the Memorandum of Law in
Opposition to Plaintiffs Motion for Class Certification and Permission to Serve Notice, are
E attached hereto as Exhibit "l." Plaintiff has not waived reading and signing of the deposition
transcript and his time period for doing so has not yet expired.
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Case 3:03-cv-OO63P=I5)JS Document 40-2 Filed 10?§2003 Page 2 of 4
3. I affirm that a true and correct copy of the April 9, 2002 notice of suspension, i
marked at Plaintiffs deposition dated September 30, 2003 as Defenda.n1:’s Exhibit 6, is attached
hereto as Exhibit "2".
4. I affirm that a true and correct copy of the March 19, 2002 final written warning, K
marked at Plaintiffs deposition dated September 30, 2003 as Defendant’s Exhibit 7, is attached
hereto as Exhibit "3”.
5. I affirm that a true and correct copy of the Mem. of Decision and Order, L/@1, I
Safeco Ins. Co. of America, No 3:02CV2239 (DJ S) (D. Conn. July 15, 2003) as obtained from I
the case file Mike v. Safeco Ins. Co. of America, No 3:02CV2239 (DJS), is attached hereto as
Exhibit "4". {
6. I affirm that a true and correct copy of the case as obtained from the LEXIS K
database in the matter Freeman v. Wal-mart Stores Inc., No. 02-5161, 2003 U.S. Dist. LEXIS
6664 (W.D. Ark. Apr. 15, 2003) is attached hereto as Exhibit "5". i
7. I affirm that a true and correct copy of the case as obtained from the LEXIS
database in the matter Baum v. Shone ’s Inc., No. 98-423-CV-ORL 19-B, 1998 U.S. Dist.
LEXIS 21484 (M.D. Fla. Orl. Div. Dec. 3, 1998), is attached hereto as Exhibit "6”,
8. I affirm that a true and con·ect copy of the case as obtained from the LEXIS
database in the matter Dean v. Pricelinecom, Inc., No. 3:00CV1273(DJS), 2001 U.S. Dist.
LEXIS 24982 (D. Conn. June 5, 2001), is attached hereto as Exhibit "7".
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Case 3:03-cv-006 - JS Document 40-2 Filed 10/ 2003 Page 3 of 4
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Tasos C. Paindiris
Sworn and subscribed to before me
this 14th day of October, 2003
Notary Public _ (
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DEFENDANT, —
COMPUTER SCIENCES CORPORATION
By:
William]. Anthony (c (1 65) \"~
Tasos C. Paindiris (ct 1 3 )
Iackson Lewis LLP
55 Farmington Avenue, Suite 1200
Hartford, CT 06105
Tel: (860) 522-0404 l
Fax: (860) 247-1330
E-mail: [email protected]
E-mail: gaindi1rt@]'acksordewis.com
Lisa A. Schreter (ct17647) z
Jackson Lewis LLP i
245 Peachtree Center Avenue, N.E. ‘
1900 Marquis One Tower
Atlanta, GA 30303-1226 (
Tel. (404) 525-8200 i
Fax. (404) 525-1173
E-mail: schretel@]'acksoi1lewis.com
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l Case 3:03-cv-00630=B)JS Document 40-2 Filed 10/JASZOO3 Page 4 of 4
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Q CERTIFICATION OF SERVICE
l . . . . . i
y ThlS 1S to C€I'll1fy that a copy ofthe foregomg was sent by tirst class mail, postage
A prepaid, on this 14*}* day of October, 2003, tothe following:
Michael ]. Melly
143 Oneco Avenue l
New London, CT 06320
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Tasos C. Paindiris i
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