Free Notice (Other) - District Court of Connecticut - Connecticut


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Date: June 2, 2004
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State: Connecticut
Category: District Court of Connecticut
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https://www.findforms.com/pdf_files/ctd/22994/25.pdf

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4 Case 3: 3-cv-00623-CED Document 25 Filed 05/21/2004 Page 1 of 2
a . ». " ( O
UNITED STATES DISTRICT COURT J
Drsrmcr on coiwncrrcur F Q L §
Plaintiff
: cw. Action N0.
v. : MAY 21, 2004 cg/l"""
US INVE TIGATIONS I
SERVIC S, INC., :
Defendant 8 ¥
PLAINT FFS’ ACCEPTANCE OF DEFENDANT’S RULE 68 AND CONN. GEN. i
STAT. § 52-193 OIFFER ()F JUDGMENT
Pla ntiff Karen Harter hereby accepts the Defendants Offer of Judgment, dated
April 22, 1 04, pursuant to Fed.R.Civ.P. Rule 68 and Conn. Gen. Stat. § 52-193.
On May 19, 2004, counsel for the Plaintiff contacted the Defendant’s counsel
requesting consent stipulation to extend the Offer of Judgment until May 21, 2004,
giving Plai tiff an opportunity to accept the offer. The undersigned informed Defendant’s
counsel th he was unable to consider the April 22, 2004 Offer of Judgment due to his
involveme t in two other unrelated eases where he filed motions for summary judgment
during the `nitial l0 day period of acceptance of the Rule 68 Offer. The original
acceptance deadline was May 5, 2004.
The Defendant’s Rule 68 Offer of Judgment stated precisely as follows,
The Defendant, US Investigation Services, Inc., pursuant to Rule 68 of the
Fed ral Rules of Civil Procedure and Conn. Gen. Stat. § 52-193, hereby offers to
setting Plaintiff s claims and to stipulate that judgment in the amount of Twenty
Thol sand Dollars ($20,000.00) be entered on Plaintiff’ s behalf.

}


J Case 3: 3-cv-00623-(EPD Document 25 Filed 05/21/2% Page 2 of 2
l Th Defendants April 22, 2004 Offer of Judgment did not include plain language .
that precl ded Plaintiff from recovering a1;torneys’ fees associated with the action.
Plaintiff al o moves on this date for a Motion for Attorneys’ Fees pursuant to Title VII,
ADA, AD A and FLSA.
Dated: So thport, CT PLAINTIF F,
May 21, 2 04- KAR_ N ARTER
By:
Ma P. C ey (ctl7828)
Carey Associates, P.C.
Attorneys At Law
71 Old Post Road, Suite One
Southport, CT 06490
(203) 255-4150 tel.
(203) 255-0380 fax.
[email protected]
Attorney for Plaintiff
I CERTIFICATE OF SERVICE
TH S IS TO CERTIFY, that the foregoing was delivered via facsimile and UPS
Second Day Service, fee prepaid, this the 21t day of May, 2004 to:
Richard Voigt
McCa.rter English LLP
City Place
185 Asylu Street
Hartford, C 06103
ark P. Car
2