Free Motion for Protective Order - District Court of Connecticut - Connecticut

.77.7+.77. .. ,... ..........,.........._......; ,,___,__________i______ ___,__ _____[ __] _____
11 `(L"‘ "“m·*—mrrr1
. . . Case 3:03-cv-00444-AWT Document 33-2 Filed 1 /15/20_ 3 P e 1 of 2 `
1 1
1
1 1
i 1
UNITED STATES DISTRICT CO 1
DISTRICT OF CONNECTICUT
. 1
ROSEMOUNT AEROSPACE INC., : g
Plaintiff : Civil Action . 303C\10444
vs. : `
WEED INSTRUMENT COMPANY, INC., :
and HARCO LABORATORIES, INC., :
Defendants. : DECEMBER 2, 2003
AFFIDAVIT IN SUPPORT OF MOTION FOR A P TE 1 TIIYE O ER 1
STATE OF CONNECTICUT) 1
) ss:
COUNTY OF NEW HAVEN) ?
RICHARD HOYT, being duly sworn, deposes and says: p
1. I am employed by Defendant I-Iarco Laboratories, IT. ("Harc1o") as siness Unit
Manager — Sensors, and I make this affidavit in support of Harco’s motion fpr a Prot ctive Order
with respect to the Request to Permit Entry for Inspection se ed by 1P1aintif Rosemount
Aerospace, Inc. 1
2. The Request to Permit Entry for Inspection is sough1* to dbseive the a sembly and
1
brazing of total air temperature ("TAT") sensors. My resp0nsibi`ities inc1lude su ervising the
1
srzvssivn f
1
. --. 1+ 1 1 . 11111111111
*_ _ ___1 1 1 _¥_n__¥___’_(‘1__ 1111111111

I' I U I N-——;F`I
” ' ` Case 3:03-cv-00444-AWT Document 33-2 Filed 1 /15/2003 P e 2 of 2
I
I I
manufacturing ofthe TAT sensors. Harco is not assembling or b zing TAT senso s and has no I
contracts to do so now. Requiring Harco to conduct a mock ass mbly anil brazin of the TAT I
sensor would require us to disrupt the current manufact ing scliIedule t reschedule
manufacturing of other products that we now have deadlines to p oduce. additi n, we do not I
have the personnel available to conduct such a mock assembly, an , therefcisre, we ould have to I
shift personnel from present production and/or require them to ork oveiitime. Al o, any TAT _·
sensor that we then made would sit in inventory, resulting in carr ing Icostis. The p-ocess would
be highly disruptive, burdensome and expensive. It would cost I-lar o approiiimately $5,000. _ I
I I
3. Everything that Rosemount would learn from such an inspsiction is described in
the 1nanufacturer’s instructions, drawings and other documents th t alreadyi have b en produced
to Rosemount. Therefore, such an inspection is unnecessary. M reover, tIhat man facturing is .
I
done in a room where Rosemount would be able to observe confide1I1tial an proprietary
information relating to the manufacturing of other products that ha e nothin? to do ith this case I
that would be in plain sight, presenting the danger of trade ecrets rind con dential and
proprietary information being revealed. .
"
RICHARDH YT
Sworn to before me this
I? _r _,Deceni r, 03_
Notary Public . I
I I I
‘ I
S'l`:2735lvl 2 I
_ I
‘"?‘-*“·;‘-·*·_* l `II— i