Free Motion to Compel - District Court of Connecticut - Connecticut

Case 3:00-cv-01124-WIG Document 175 Filed 05/21/2007 Page 1 of 3
UNITED STATES DISTRICT°COURT
DISTRICT OF CONNECTICUT
DENISE EVARTS, : CIVIL ACTION NO.
: 3 :00CVl 124 (WIG)
Plaintiff, :
THE SOUTHERN NEW ENGLAND
TELEPHONE COMPANY, :
Defendant. MAY 21, 2007
DEFENDANT’S MOTION FOR ORDER
AND FOR EXPEDITED CONSIDERATION
In the sole remaining claim in this action, plaintiff Denise Evarts alleges that
defendant Southem New England Telephone Company ("SNET"), violated Title VII of
the Civil Rights Act by subjecting her to a hostile work environment based upon her
gender. She claims that she was constructively discharged as a result of this hostile
environment and she seeks, among other remedies, back pay, lost benefits, and damages
for alleged emotional distress. Trial in this matter is scheduled to commence on June 6th.
Defense counsel has on several occasions in the past months requested updated discovery
responses conceming plaintiffs attendance at law school, employment, and attempts to
seek employment, but plaintiff has failed to provide such updates since 2001. On May
9th, plaintiffs counsel confirmed that she would not be providing supplements to
plaintiffs outdated responses to SNET’s discovery requests regarding plaintiffs
employment and efforts to obtain employment.
ORAL ARGUMENT NOT REQUESTED

Case 3:00-cv-01124-WIG Document 175 Filed 05/21/2007 Page 2 of 3
Because SNET has made a good faith effort to resolve this matter with opposing
counsel but has been unable to do so, and given that trial is imminent, pursuant to Fed. R.
Civ. P. 37 and D. Conn. L. Civ. R. 37, SNET moves to compel plaintiff to supplement
her undisputedly outdated responses to SNET’s discovery requests and to attend a
deposition limited to the issue of her law school attendance, employment, and attempts to
obtain employment since her September 14, 2001 deposition. Further, because trial is
scheduled to begin on June 6, 2007, SNET respectfully requests that this Court expedite
consideration of this motion.
With this motion, SNET submits a supporting memorandum of law and the
affidavit of Theresa Waugh.
Dated at North Haven, Connecticut this 21 st day of May, 2007.
THE DEFENDANT, ‘
THE SOUTHERN NEW ENGLAND
TEL ONE COMPANY
By *5-
Lori B. Alexander
Federal Bar No. CT 08970
Theresa M. Waugh
Federal Bar No. CT23559
LITTLER MENDELSON, P.C.
110 Washington Avenue, 3rd Floor
North Haven, Connecticut 06473
Telephone: (203) 234-6344
Facsimile: (203) 234-6345
E-Mail: [email protected]
E-Mail: [email protected]
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Case 3:00-cv-01124-WIG Document 175 Filed 05/21/2007 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing was mailed by first-class mail,
postage prepaid to all counsel and pro se parties of record on this 21st day of May, 2007,
as follows: Karen Torre, Esquire, Law Offices of Karen Lee Torre, 51 Elm Street, Suite
307, New Haven, Connecticut 06510.
·‘· W t
Theresa M. Waugh
Federal Bar No. CT23559
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