Free Motion in Limine - District Court of Connecticut - Connecticut

Case 3:03-cv—00986-JCH Document 88-5 Filed 06/21/2005 Page1 0f4
EXHIBIT 2

if Case 3:03-cv—OO986-JCI-l Document 88-5 Filed 06/251 /2005 Page 2 of 4
. l UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
SUSAN E. WOOD, CIVIL ACTION NO.
3:03—C\/-986 (JCH)
Plaintiff,
l V.
SEMPRA ENERGY TRADING
CORPORATION, October 2, 2003
Defendant.
PLAINTIFF'S RESPONSES TO DEF ENDANT’S FIRST SET OF INTERROGATORIES
To: Mary C. Dollarhide, Esq.
Peter M. Schultz, Esq. ·
PAUL, HASTINGS, I AN OFSKY & WALKER LLP
I 1055 Washington Boulevard
Stamford, CT 06901-2217
Pursuant to the Federal Rules of Civil Procedure, Plaintiff Susan E. Wood ("Wood" or "Plaintiff")
hereby responds to Defendant Sempra Energy Trading Corporation's ("Sempra" or "Defendant") First Set
of Interrogatories ("Interrogatories") as follows:
GENERAL OBJECTIONS
1. Plaintiff objects to Sempra’s Interrogatories insofar as their instructions and definitions
I exceed, enlarge or modify the requirements of the Federal Rules of Civil Procedure.
2. Plaintiff objects to Sempra’s Interrogatories to the extent that they call information that is
protected from disclosure by the attorney—client privilege.
3. Plaintiff objects to Sempra’s Interrogatoiies to the extent that they call for infomation that

I Case 3:03-cv—00986-JCH I Document 88-5 Filed 06/21/2005 Page 3 of 4
_ time he met my partner and found out I was gay, after which his treatment of me changed, making
me feel less welcome and included; t
- Brian Cumming informing me at the end of 2001 to watch out and be careful because some of the
managers at Sempra were not comfortable with me.
INTERROGATORY NO. 14: ‘ I
With respect to paragraphs 37 and 61 of your Complaint, describe with specificity each and every "sexual
innuendo []," "inapprop1iate boast[]," and/or "strange and intrusive conversation[]" allegedly initiated or
_ _ made by Sarathi Roy. Include in your answer the date, time and location of each and every alleged
if innuendo, boast and/or conversation.
OBJECTION: · ‘ _
Unduly burdensome. Subject to this objection and the generalnobjections set forth about, Plaintiff
l responds as follows:
RESPONSE: » I
A — Upon arriving on the Oil Marketing Desk, Sarathi repeatedly asked me about my relationship with
Lynda. How we met, if we lived together, where we lived, what we did for fun, etc. His interest in
my personal life was excessive and it made me-uncomfortable; _
- Repeatedly initiating inappropriate conversations on instant messenger. Specifically using the
"falling hearts" environment and choosing the "big kiss" action while chatting with me;
- Repeatedly changing the environment back to "falling hearts" after I would change it to something
different. Saying that he "liked that better"; · 8
i - If I would disagree with him on an issue he would say how his wife would not do that to him
because he is the "man of the house"; p ,
- Boasting how he was the boss of his house, just like it should be. How the man should always be in
charge and that he expects his wife to cook and clean for him. Saying that’s the way it should be
because he married her and brought her over here and is giving her a good life. That she should be
grateful to him for that;
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_ - Along those same lines, asking me “who wore the pants in our family", referring to me and my
lesbian partner;
- Boasting how he refused to let his wife visit him on the trading floor (he got her a job there soon
after he moved her from India after they got married) because it would make him look bad to have a
woman hanging around him like that;
I - Upon returning from my trip to Southern France with my partner in Sept. 2001, he asked if we I
wore any clothes on the beach because he heard women did not wear tops in Southern France;
I - Boasting about his sexual conquests and how he was once dating two women from the Sempra
office at the same time. Following that up by saying that the women at Sempra were "easy";
- Boasting about spending time down at the Boxing Cat Grille and being the resident “stud". Telling
tales of how he would go down there to pick up old and lonely women and take them home to please
them for the night-; F
l I - Continuous boasting about "Miss Kim" his "special masseuse" who is "a lady who really knows
’ how to treat a man". This masseuse works for a local massage parlor, which parlors were referred
to at Sempra as rub-and-tugs. He would often say he was going for a massage with Miss Kim after
work. p V
INTERROGATORY NO. 15: I
Identify the "former work colleague" referenced in paragraph 51 of the Complaint and describe with
specificity each and every statement allegedly made by the "former work colleague" conceming Sarathi
Roy’s alleged comfort-level with Plaintiff. Include in your answer the date, time and location at which the
I “former work colIeague" made each and every alleged statement.
RESPONSE:
I Billy Lasher in the IT Department
- Spring 2001 - When I told him I was gay he said he knew and was ok with it but to be careful
because not many of the employees were comfortable with my lesbian status;
- Late Spring 2001 — I mentioned how I thought Cliff (in the back office) was very helpful when I ran
I clients through his office. Billy warned me that was because he thought I was cute and he didn’t
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