Free Motion in Limine - District Court of Connecticut - Connecticut

Case 3:00-cv-01124-WIG Document 174 Filed 05/15/2007 Page 1 of 4
FUI? '.E’ {5 in H, G7
UNITED STATES DISTRICT COURT I if if I I
DISTRICT OF CONNECTICUT
DENISE EVARTS :
Plaintiff
I : Civil No. 3:00CVl 124 (WIG)
V. :
THE SOUTHERN NEW 2
ENGLAND TELEPHONE COMPANY, : May 10, 2007
Defendant
PLAINTIFF’S MOTION IN LIMINE
Plaintiff respectfully moves this court to preclude SNET, its counsel, officials and witnesses
from introducing any evidence, offering any testimonial statements or otherwise eliciting testimony
on the following subjects:
1) The lay opinions of any other female employee of SNET regarding the character of
plaintiff s supervisor Matthew Cordner and manager Edward Dillman.
2) Any and all opinions of one Wanda Lewis, an ex-supervisor of the plaintiff or any
introduction of hearsay statements or notes authored by Lewis which defendant claims
to have been placed in plaintiffs personnel tile.
3) Plaintiff s academic records, including college and law school transcripts, grades, test
performance and like matters relating to her schooling.
4) Evarts’ career as a lawyer, her bar admission, job-seeking and employment as a
lawyer.

Case 3:00-cv-01124-WIG Document 174 Filed 05/15/2007 Page 2 of 4
The plaintiff submits that the issue before the juror in this case is whether plaintiff was
subjected to a hostile and offensive working environment on account of her gender; in particular,
whether such environment was created by supervisor Matthew Cordner and manager Edward
Dillman. Also before the jurors is the question whether plaintiff reasonably left the work
environment then and there existing and was thus constructively discharged. In anticipation that
defendant may seek to distract the jury from its task, plaintiff seeks an order precluding SNET from
inquiring into the above matters or offering documents or soliciting testimony from witnesses on
these matters as they are irrelevant under Fed. R. Evid. 401 and thus inadmissible under Fed.R.Evid.
402.
Plaintiff anticipates that SNET may introduce testimony from former SNET supervisor Wanda
Lewis regarding her opinion of Evarts or introduce a hand-written note allegedly authored by Lewis
and allegedly found in SNET’s files regarding Evarts which contains her opinion of Evarts. Plaintiff
will object to the introduction of such note which appears on defendant’s list of exhibits on two
grounds: 1) the note has never been authenticated; and 2) it is irrelevant to the issues before the jury.
Whether a prior supervisor saw reason to pen a note containing a negative criticism of Denise Evarts
is irrelevant to whether her successor, Matthew Cordner, created a hostile and office working
enviromnent for Evarts on account of her gender and/or whether Edward Dillman contributed to that
enviromnent by his own conduct toward the plaintiff.
For all of the above reasons, the plaintiff respectfully requests that this motion be granted.
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Case 3:00-cv-01124-WIG Document 174 Filed 05/15/2007 Page 3 cf 4
THE PLAINTIFF
BY: é
KA N LEE TORRE
Federal Bar N0. ct01707
Law Offices 0f Karen Lee Torre
51 Elm Street, Suite 307
New Haven, CT 06510
(203) 865-5541
Her Attomey
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Case 3:00-cv-01124-WIG Document 174 Filed 05/15/2007 Page 4 of 4
CERTIFICATION
I hereby certify that a copy of the foregoing was mailed, First Class, postage paid, on May
10, 2007, to:
Lori B. Alexander, Esq.
Theresa M. Waugh, Esq.
Deborah DeHart Cannavino, Esq.
Littler Mendelson, P.C.
110 Washington Avenue
North Haven, CT 06473
David Vegilante, Esq.
Southern New England Telephone C0
310 Orange St., 8th Fl.
New Haven, CT 06510
x ‘ *1
S; lb Q
Karen Le orre
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