Free Motion in Limine - District Court of Connecticut - Connecticut

Case 3:00-cv-01124-WIG Document 166 Filed 05/11/2007 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
DENISE EVARTS, : CIVIL ACTION NO.
: 3:00CVl 124 (WIG)
Plaintyf :
THE SOUTHERN NEW ENGLAND
TELEPHONE COMPANY, :
Dekndant. MAY 10, 2007
DEFENDANT’S MOTION IN LIMINE RE LOST WAGES AND BENEFITS
Because plaintiff Denise Evarts unequivocally failed to make reasonable efforts to mitigate
her damages, she is barred from recovering lost wages or benefits in this action. Defendant Southern
New England Telephone Company ("SNET") therefore respectf11lly moves in limine to preclude the
offer and introduction of evidence or comments of counsel relating to Ms. Evarts’s claim for lost
wages and benefits arising after she left SNET. Alternatively, SNET moves that this Court enter an
order precluding the offer and introduction of evidence or comments of counsel relating to Ms.
Evarts’s claim for lost wages and benefits arising after she began law school in August 1998. In
support of this motion, SNET today files a memorandum of law.
ORAL ARGUMEN T REQUEST ED

Case 3:00-cv-01124-WIG Document 166 Filed 05/11/2007 Page 2 of 4
Dated at North Haven, Connecticut this 10th day of May, 2007.
THE DEFENDANT,
THE SOUTHERN NEW ENGLAND TELEPHONE
COMPANY
Lori B. Alexander
Federal Bar No. CT 08970
Theresa M. Waugh
Federal Bar N0. CT23559
LITTLER MENDELSON, P.C.
110 Washington Avenue
North Haven, Connecticut 06473
Tel. (203) 234-6344
Fax (203) 234-6345
E-Mail: [email protected]
E-Mail: [email protected]
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Case 3:00-cv-01124-WIG Document 166 Filed 05/11/2007 Page 3 of 4
CERTIFICATE OF SERVICE
This is to certify that a copy ofthe foregoing was mailed by first—class mail, postage prepaid
to all counsel and pro se parties of record on this 10th day of May, 2007, as follows: Karen Torre,
Esquire, Law Offices of Karen Lee Torre, 51 Elm Street, Suite 307, New Haven, Connecticut 06510.
gg,/g’. Q gf QL
Lori B. Alexander
Federal Bar No. CT08970
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