Free Motion to Compel - District Court of Connecticut - Connecticut

Case 3:03-cv-00630-DJS Document 110 Filed 05/12/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
for the
DISTRICT OF CONNECTICUT
MARIO RICHARDS, CIVIL NO. 3:03 CV00630 (DIS)
Plaintiff, :
COMPUTER SCIENCES CORPORATION
Defendant. : MAY 12, 2006
DEFENDANTS MOTION TO COMPEL DISCOVERY RESPONSES
Pursuant to Rule 37 of the Federal Rules of Civil Procedure and the Local Rules of this
Court, Defendant, Computer Sciences Corporation ("Defendant"), respectfully moves this Court
for an order compelling PIaintiffs’ responses to Defendanfs First Set of Interrogatories and
Defendant’s First Request for Production dated December 8, 2005; December 22, 2005; and
January ll, 2006. Defendant also requests that Plaintiff be compelled to produce the Notice
form sent to the potential opt ins along with the date the form was sent in accordance with this
Court’s previous Order. Further, in accordance with Fed. R. Civ. P. 37(a)(4) and D. Conn.
L.Civ. R. 9(d)(4), Defendant requests that it be awarded its reasonable fees and expenses
incurred in making this Motion.
In support of its Motion, Defendant has also tiled an accompanying Memorandum of
Law. Attached as Exhibit A to Defendant’s Memorandum is the Affidavit of Tasos C. Paindiris,
certifying that good faith efforts have been made to fully resolve the parties’ outstanding

Case 3:03-cv-00630-DJS Document 110 Filed 05/12/2006 Page 2 of 3
discovery issues, in accordance with Rule 37(a)(2)(B) of the Federal Rules of Civil Procedure
and Local Rule 9(d)(2).
DEFENDANT,
COMPUTER SCIENCES CORPORATION
By: /s/ T (ISGS C. Pczindiris
Tasos C. Paindiris (ct 16739)
William J . Anthony (ct 17865)
Jackson Lewis LLP
90 State House Square, S"' Floor
Hartford, CT 06103
Tel: (860) 522-0404
Fax: (860) 247-·1.33O
E—mail: painc1i1·t@jaeksonlewiscom
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Case 3:03-cv-00630-DJS Document 110 Filed 05/12/2006 Page 3 of 3
CERTIFICATION OF SERVICE
I hereby certify that on May 12, 2006, a copy of the foregoing Defendanfs
Motion to Contpel Discovery Responses was filed electronically and served by mail on anyone
unable to accept electronic tiling. Notice of this tiling will be sent by e-1"Jaail to all patties by
operation of the Court’s electronic tiling system and by mail to anyone unable to accept
electronic filing as indicated on the Notice of Electronic Filing, Parties may access this tiling
through the Court’s CM/ECI: Systemc

Tasos C. ?aindiris
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