Free Motion for Leave to File - District Court of Connecticut - Connecticut

Case 3:03-cv—OO630-DJS Document 127 Filed 12/O4/2006 Page 1 of 3
UNITED STATES DISTRICT COURT ` ` "
DISTRICT OF CONNECTICUT
MARIO RICHARDS, : I ` as · - i ’
on behalf of himself and : CIVIL ACTION NO.
all others similarly situated : 3:03 CV00630 (DJS)
PLAINTIFFS, :
COMPUTER SCIENCES
CORPORATION _ : November 29, 2006
DEFENDANT.
PLAINTIFF’S MOTION FOR PERMISSION TO ALLOW

Plaintiff, Mario Richards, on behalf of the class, requests that the court grant
permission to the following parties to opt-into the class. In support thereof, the plaintiff
states:
Procedural Baclgground
This action was brought pursuant to the Fair Labor Standards Act, 29 U.S.C. 201
et seq. (FLSA), claiming wages for overtime hours worked in excess of forty hours per
week. The court (Squatrito, J.) granted class certification to all employees of Computer
Sciences Corporation holding the position of CSA (Customer Support Analyst) Level I &
Il.
Parties Seeking To Opt-In
William Campbell, Mark Caputo and Gwen Zarkos are CSA’s (custmer support
analyst) working out of the Norwich, CT facility who claim to have worked over-time
hours without pay during the relevant time period. Counsel for the plaintiff has
communicated with these persons and believes it appropriate that they be allowed to opt-

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Case 3:O3—cv—OO630-DJS Document 127 Flléd
in. Although the deadline has passed to opt—in, these three persons have good reason why
they have not previously opted in. They did not receive a notice of their right to opt-in to
this case, as their names were not provided to plaintiff by Computer Sciences
Corporation. These proposed opt-in parties have already provided the necessary
infomation to plaintiff s counsel. Adding theses persons as members of the class would
not unduly prejudice to the defendant or cause any delay in the proceeding/settlement of
this case.
Opposing Counsel
Counsel for the plaintiff has spoken to opposing counsel in this matter.
Defendant’s position is yet undetermined regarding the present request.
Plaintiff
Mario Richards.
on behalf of the class
By A! 1/
Michael J. Mel
Fed. Bar No ct1784l
143 Onec Avenue Suite 4
P.O. Box 771
New London, CT 06320
Tel: (860) 447-1990
Fax: (860) 961-8602
[email protected]

‘ 2006 Pa e 3 of 3
Case 3:03—cv—00630-DJS Document 127 Fnled 12/04/ 9
CERTIFICATION {
I hereby certify that a copy ofthe foregoing was mailed on ./{ Z} ip
To: ·’
Tasos C. Paindiris, Esq.
William Anthony, Esq.
Jackson Lewis
90 State House Sq. 8m Fl. .
Hartford, Ct 06103 /
Mac aa J. Me