Free Motion for Order - District Court of Connecticut - Connecticut

Case 3:03-cv-00630-DJS Document 83 Filed 11/19/2004 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
MARIO RICHARDS 2 CIVIL ACTION NO.
PLAINTIFF : 3:03 CV00630 (DIS)
V.
COMPUTER SCIENCES CORPORATION
DEFENDANT 1
1 NOVEMBER Lgm, 2004
JOINT MOTION FOR
APPROVAL OF NOTICE AND CONSENT FORMS
The parties jointly move that the court approve the attached notice and consent
forms in this matter, The parties agree to the content of the forms except for the opt·in
period for potentiai opt—in plaintiffs. Specifically, the parties seek the foliowingz
1) Plaintiff requests that the opt»in period expire at the end ofdiscovery.
2) Defendant requests that the potential opt~in Plaintiffs shall have sixty
(60) days after the date the Notice is mailed to file their consents with the Court.
RESPECTPULLY SUBMITTED,
DEFENDANT PLAINTIFF
COMPUTER SCIENCES CORPORATION MARIO RICHARDS
/`!
By: g Z By
Tasos C. Pain iris, ctl6'/39 Michael I. elly, 7841
Jackson Lewis LLP Bartinik, Gianac los, Bartinik,
Suite 1200 Ba1"tinil< & Grat r, P.C.
55 Farmington Avenue 100 Fort Hili Rd.
Hartford, CT 06105 Groton, CT 06340
Te}: (860) 522»0404 Tei: (860) 445 8521
Fax: (860) 24721330 Fax: (Fax) 445-5873

Case 3:03-cv-00630-DJS Document 83 Filed 11/19/2004 Page 2 of 4
NOTICE OF CLASS ACTION
TO: COMZPUTER SCIENCES CORPORATION
CUSTOMER SUPPORT ANALYSTS LEVEL I AND LEVEL H (PRESENT AND PAST)
Re: Mario Richards v. Computer Sciences Corporation, a class action
United States District Court, Civ. Case No. 3:03 cv063(}(DJS)
Dear Employees of CSC:
Introduction:
The purpose of this notice is to inform you of the existence of a class action in which your rights may be
affected and to instruct you on the procedure for participating in this suit.
Description ofthe Class Action:
This case has been brought as a class action on behalf of present and former Customer Support
Analysts (CSA) Level I and Level II, of Computer Sciences Corporation (CSC}. The class action is brought
under the FAIR LABOR STANDARDS ACT, 29 U.S.C. 207 et al against Computer Sciences Corporation in
the United States District Court for the District ofConnecticut, civil case no. 3:03 cv 0630 (DIS)
The Plaintiff s Attorney is Michael J. Melly, Bartinik, Gianacoplos, Bartinik, Bartinik & Crrater, 100
Fort Hill Road, Groton, Connecticut 06340, Tel: 860 445-8521, Email: [email protected]. Defendant
CSC is represented by Tasos C. Paindiris, Jackson Lewis LLi’, 55 Farmington Avenue, Suite 1200, Hartford,
Connecticut 06105, Tel: 860—522—0-404, E-mail: [email protected]
In this class action the plaintiffs/employees seek to recover regular and overtime wages for hours
worked over 40 hours per week. Plaintiffs/employees also seek and additional equal amount by way of
liquidated damages and prejudgment interest, attorneys fees and costs. Anyone who worked as a customer
support analyst Level I andfor level 11 at any time since September 23, 2001 may be eligible to join in this action
and make a claim for regular or overtime wages. CSC denies that any wages are due and contends that these
positions were properly classified as exempt from the overtime provisions ofthe FLSA.
To date the Court has not ruled on the claims made in the lawsuit. The court will determine the wages
and liquidated damages, if any, due each customer support analyst (CSA) for overtime hours worked. The court
will also determine the attorney’s fees and costs, if any, to be assessed the defendant, Computer Sciences
Corporation.
Effect of Joining This Suit
If you choose tojoin this suit you will be bound by the judgment. During the course of litigation you
may be asked or required to provide information, give a deposition, and/or to attend trial. You are not required
to join this suit. Federal law prevents Computer Sciences Corporation from retaliating against you because you
have exercised your rights under the Fair Labor Standards Act.
Your Right to Participate in this Suit
If you are a present or past customer support analyst (CSA) level I or level II of Computer Sciences
Corporation and wish to make a claim for overtime wages against Computer Sciences Corporation, you may
join in this class action. If you have any further questions you may contact Plaintiff’ s Attorney Michael J. Molly,
Bartinik, Gianacoplos, Bartinik, Bartinik & Grater, 100 Fort Hill Road, Groton, Connecticut 06340, Tel: 860
445-8521, Email: mmeliy(Zr)grotonlarv.cog.
If you wish tojoin this ciass action, you must sign the enclosed "CONSENT TO JOIN CLASS ACTiON" The
Consent to Join Class Action must be filed with the Court by .
Please mail the original consent form for filing with the court to:
Michael J . Molly, Esq.,
Bartinik, Gianacoplos, Bartinik, Bartinik & Grater
100 Fort Hill Road
Groton Connecticut 06340

Case 3:03-cv-00630-DJS Document 83 Filed 11/19/2004 Page 3 of 4
CONSENT TO JOIN CLASS ACTION
(§air Labor Standards Act, 29 USC Sec. 207 et al
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
Mario Richards, on behalf ofhirnself, Nor 3:03CV00630 (DJ S)r
and others similarly situated,
Plaintiffs,
v:
Computer Sciences Corporation,
Defendant,
To The United States District Court, and To Each Party, and To Counsel of Record: —
I, , (name) (address)
(Apt) (State) (zip code);
Tl. cell (if applicable)
emaii (if applicable)
hereby state:
Iam a present or former Customer Support Analyst level I or Levei II at Computer Sciences Corporation and
do hereby consent to become a party to the above-captioned class action and to be bound bythe decision ofthe
Court in connection herewith, I authorize plaintift`s counsel to represent my interests in this niatterr
Signature Date

Case 3:03-cv-00630-DJS Document 83 Filed 11/19/2004 Page 4 of 4
CERTIHCATION OF SE§_\/ICE
This is to certify that a copy of the foregoing was sent by first class mail,
postage prepaid, on this 19th day of November, 2004, to the following:
Michael J. Melly, Esql
Bartinlk, Gianacoplos, Bartinik, Bartinik & Grater, PCC,.
100 Fort Hill Rdl.
Groton, CT 06340
Tasos C. Paindiris