Free Response - District Court of Connecticut - Connecticut

Case 3:03-cv-01011-AWT

Document 65

Filed 05/20/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT NICHOLAS CAGGIANIELLO, NEIL CIVIL ACTION NO. 3:03CV1011(AWT) HOWARD and THOMAS FALCO, on behalf of themselves and all other similarly situated employees of FSG Privatair, Inc. Plaintiffs, vs. FSG PRIVATAIR, INC., and in their individual and official capacities DAVID C. HURLEY, HUGH F. REGAN, THOMAS H. MILLER and THOMAS L. CONNELLY Defendants. OBJECTION TO DEFENDANTS' MOTION FOR PROTECTIVE ORDER AND SANCTIONS The plaintiffs hereby object to the defendant's motion for protective order and sanctions on the basis that Plaintiffs and their counsel have not sought a motion to compel defendants to produce the individual flight trip sheets or taken any other affirmative action with the court to produce them and, furthermore, agree that defendants are not required to produce them. The motion is therefore premature and moot. A memorandum of law in support of this objection is attached hereto. Respectfully submitted, THE PLAINTIFFS BY: ______________________________ James T. Baldwin, Esq. (ct08535) COLES, BALDWIN & CRAFT, LLC. 1261 Post Road, P.O. Box 577 Fairfield, CT 06824 Tel. (203) 319-0800 Fax (203) 319-1210 May 20, 2005

Case 3:03-cv-01011-AWT

Document 65

Filed 05/20/2005

Page 2 of 2

CERTIFICATION This is to certify that a copy of this Objection to Defendants' Motion to Exempt from Answering Complaint was sent by first class mail on February 27, 2004 to the following counsel of record: Joseph C. Maya, Esq. Maya & Associates, P.C 183 Sherman Street Fairfield, CT 06824 Russell J. Sweeting, Esq. Maya & Associates, P.C. 183 Sherman Street Richard J. Diviney, Esq. 65 Jesup Road PO Box 390 Westport, CT 06881-0390

______________________________ James T. Baldwin, Esq. Fairfield, CT 06824

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