Free Motion in Limine - District Court of Connecticut - Connecticut

Case 3:03-cv-00973-DJS

Document 24

Filed 02/24/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ________________________________ LISA TILUM : CIVIL ACTION NO: 3:03 CV973 (DJS) Plaintiff : : VS. : : STATE OF CONNECTICUT, : DEPARTMENT OF TRANSPORTATION: Defendant : FEBRUARY 23, 2004 ________________________________: PLAINTIFF=S MOTION IN LIMINE The Plaintiff, Lisa Tilum, hereby moves this Court to enter an order, in light of Raymond v. United States, 355 F.3d 107 (2d Cir. 2004), permitting her to introduce evidence post-trial, including testimony by Plaintiff=s expert, Sheldon Wishnick, on the negative tax consequences of any award of attorney=s fees to the Plaintiff, in the event Plaintiff is a prevailing party entitled to recover fees under state or federal law. In support of this motion, Plaintiff states that such evidence should be presented to this Court for its consideration in order to fulfill the objectives of Title VII of the Civil Rights Act of 1964, 42 U.S.C. ' 2000e, et seq., and the Connecticut Fair Employment Practices Act, Conn. Gen. Stat. '46a-60 et seq., which are intended to afford victims of discriminatory employment practices make-whole relief. In further support of this motion, Plaintiff submits the Memorandum of Law filed herewith.

Case 3:03-cv-00973-DJS

Document 24

Filed 02/24/2004

Page 2 of 2

PLAINTIFF

By: Kathleen Eldergill Beck & Eldergill, P.C. 447 Center Street Manchester, CT 06040 (860) 646-5606 Fed Bar No: ct00024 CERTIFICATION I hereby certify that a copy of the foregoing has been mailed this 23rd day of February, 2004, to the following parties: Stephen J. Courtney Assistant Attorney General Attorney General=s Office 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 ______________________________ Kathleen Eldergill

Tilum\MoLim02-04.pld