Free Response - District Court of Connecticut - Connecticut

· Case 3:02-cv-02237—lV|RK Document 62 Filed 12/03/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
TRILEGIANT CORPORATION, )
)
Plaintiff, )
) .
v. ) CIV. NO: 3:02 CV2237 (MRK)
l
BP PRODUCTS NORTH AMERICA, )
INC. )
)
Defendant. ) December 3, 2004
PLAINTIFF’S OBJECTION T0 VERIFIED BILL OF COSTS
The Plaintiff, Trilegiant Corporation (“Trilegiant”), by and through its attorneys,
Cummings & Lockwood, LLC, respectfully submits this objection to Defendant BP
Products North America, Ir1c.’s ("BP") Verified Bill of Costs. Set forth below are those
costs Trilegiant considers nonrecoverable and solely the responsibility of BP. -
I. Jennifer Montague - Air Fare $1,743.50
Trilegiant objects to this cost on the basis that Ms. Montague’s return trip to
London was via business class. Pursuant to L.Civ.R. 54(c)(4)(iii), fees of common carriers
are only taxable at coach fare rates.
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- Case 3:02-cv-02237—IV|FlK Document 62 Filed 12/03/2004 Page 2 of 3
II. Ellen Best - Omni Hotels $545.58
Trilegiant objects to this cost on the basis of excessiveness. Pursuant to L.Civ.R.
54(c)(7)(viii), subsistence fees for witnesses in attendance at trial or deposition will not be
recoverable beyond the time of testimony by the witness. Ms. Best’s testimony lasted one
day. The only receipt documenting Ms. Best’s hotel costs is her own credit card statement
in the amount of $545.58. Upon information and belief, the average room rate at the Omni
Hotels is approximately $l70.00—$l90.00 per night. Accordingly, without an itemized bill
from the Omni detailing why Ms. Best’s costs totaled $545.58, Trilegiant objects.
THE PLAINTIFF ·
TRILEGIANT CORPORATION
By gv ’ él
R an P. wt? 4278)
Kevin P. S. :_ el (CT 25838)
Cmnmings i· Lockwood LLC
Four Stamford Plaza
107 Elm Street
Stamford, CT 06902
Tel. (203) 327—l700
Fax (203) 351-4534
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· Case 3:02-cv-02237—IV|FlK Document 62 Filed 12/03/2004 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that on this E day of December, 2004, a copy ofthe foregoing
P1aintiff's Objection to Verified Bill of Costs was served via facsimile and first-class U.S.
Mail, postage prepaid, 011:
Steven M. Greenspan, Esq.
Brian D. Porch, Jr., Esq.
Day, Berry & Howard LLP
CityPlace I
Hartford, CT 06103
kevin éghel
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