Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:02-cv-01302-JCH

Document 449

Filed 08/15/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

SHAWN POULIOT, Plaintiff v.

PAUL ARPIN VAN LINES, INC. et al. Defendants

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CIVIL ACTION NO. 3:02 CV 1302 (JCH) JUDGE JANET C. HALL

August 12, 2005

DEFENDANTS' MOTION FOR AMENDMENT OF PRE-TRIAL COMPLIANCE TO ALLOW SUPPLEMENTAL OBJECTION TO PLAINTIFF'S EXHIBITS WITH INCORPORATED MEMORANDUM OF LAW NOW COME the Defendants, Paul Arpin Van Lines, Inc. and Arpin Logistics, Inc. and request that the attached Objections to Plaintiff's Exhibits be substituted for that filed with this Court on August 1, 2005. In support of this motion, the Defendants state as follows: 1. The parties' Joint Pretrial Memorandum with attachments was duly filed with the Court on August 1, 2005. 2. Defendants' Objections to Plaintiff's Exhibits were formatted into chart form and when that occurred, apparently Plaintiff's Exhibit No. 14 was inadvertently cut off of the top of one of the chart pages. 3. Defendants' stated objection to that particular Exhibit is "foundation." No other supplement is made. 4. The Defendants do note that no listing is made in their Objections for Plaintiff's Exhibit No. 9d, nor is any objection stated. The Defendants have not seen any Exhibit 9d and it has been indicated by the Plaintiff that there is no Exhibit 9d.

Case 3:02-cv-01302-JCH

Document 449

Filed 08/15/2005

Page 2 of 3

As such, no objection is stated even though that particular Exhibit appears on Plaintiff's list. 5. Plaintiff did add a late Exhibit between July 26 and August 1, namely, number 33, a videotape, to which the Defendants duly objected. WHEREFORE, the Defendants respectfully request that they be allowed to amend the pre-trial compliance to substitute the attached Defendants' Supplemental Objections to Plaintiff's Exhibit List attached to the final pre-trial materials.

Respectfully submitted,

/s/Karen Frink Wolf Harold J. Friedman, Esq. CT 23785 Karen Frink Wolf, Esq. CT 26494 FRIEDMAN GAYTHWAITE WOLF & LEAVITT Six City Center, P.O. Box 4726 Portland, ME 04112-4726 (207) 761-0900 (207) 761-0186 (Fax) [email protected] [email protected]

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Case 3:02-cv-01302-JCH

Document 449

Filed 08/15/2005

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing was mailed via U.S. First Class Mail this ___ day of August, 2005 to the following: Michael A. Stratton, Esq. Stratton Faxon 59 Elm Street New Haven, CT 06510 Thomas J. Grady, Esq. Lenihan Grady & Steele 6 Canal Street PO Box 541 Westerly, RI 02891-0541 /s/ Karen Frink Wolf Karen Frink Wolf, Esq. CT 26494

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