Free Motion for Attorney Fees - District Court of Connecticut - Connecticut

Case 3:03-cv-00623-CFD Document 24-2 Filed 05/21/2004 Page 1 of 2
UNITED STATES DTSTRICT COURT
DISTRICT OF CONNECTICUT
KAREN HARTER, :
Plaintiff
: Civ. Action No. 3:03CV623(CFD)
v. : MAY 21, 2004
US TNVESTIGATIONS
SERVICES, INC., 2 _
Defendant
PLAlNTlFFS’ ACCEPTANCE OF DEFENDANT’S RULE 68 AND CONN. GEN;
STAT. § 52-193 OFFER OF JUDGMENT
Plaintiff Karen Harter hereby accepts the Defendants Offer of Judgment, dated
April 22, 2004, pursuant to Fed.R.Civ.P. Rule 68 and Conn. Gen. Stat. § 52-l93.
On May l9, 2004, counsel for the Plaintiff contacted the Defendanfs counsel
requesting a consent stipulation to extend the Offer of Judgment until l\/lay 2l, 2004,
giving Plaintiff an opportunity to accept the offer. The undersigned informed Defendants r
counsel that he was unable to consider the April 22, 2004 Offer ofludgment due to his
involvement in two other unrelated cases where he filed motions for summary judgment
during the initial l0 day period of acceptance ofthe Rule 68 Offer. The original
acceptance deadline was l\/lay 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 ‘
Federal Rules of Civil Procedure and Conn. Gen. Stat. Qi 52-l93, hereby offers to t
settle Plaintiff s claims and to stipulate that judgment in the amount of Twenty
Thousand Dollars ($20,000.00) be entered on Plaintiff’s behalf. l
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R/ Case 3:03-cv-00623-CHD Document 24-2 Filed 05/21/20/O4 Page 2 of 2 l
l /’ The Defendants April 22, 2004 Offer of Judgment did not include plain language
i that precluded Plaintiff from recovering attorneys’ fees associated with the action.
Plaintiff also moves on this date for a Motion for Attorneys Fees pursuant to Title Vll,
ADA, ADEA and FLSA. i
Dated: Southport, CT PLAINTIPF,
May 2i, 2004 I /4 ,
By:7Zw___
Ma V P. C ey (ctl7828)
Car®&”Ai;sociates, P.C.
Attorneys At Law
7l Old Post Road, Suite One
Southport, CT 06490
(203) 255-4150 tel.
(203) 255-0380 fax.
[email protected]
Attorney for Plaintiff
CERTIFICATE O}? SERVICE
THIS IS TO CERTIFY, that the foregoing was delivered via facsimile and UPS
Second Day Service, fee prepaid, this the 2lm day of May, 2004 to:
Richard Voigt
McCarter & English LLP
City Place l
l85 Asylum Street
Hartford, CT 06l03
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