Case 3:09-cv-01145-TPS Document 157-1 Filed 11/29/13 Page 1 of 2
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
JAME...
Case 3:09-cv-01145-TPS Document 157-1 Filed 11/29/13 Page 2 of 2
Upcoming SlideShare
Loading in …5
×

Castelluccio v. IBM, IBM's Memo in Opposition to Motion to Preclude

1,164 views

Published on

IBM opposed plaintiff's motion to preclude introduction of the internal investigation conducted by HR. IBM argued that the investigation was directly relevant to IBM's motive in deciding to terminate plaintiff and that the investigation report was admissible as a business record. IBM also argued that it needed the investigation report to defend itself against plaintiff's claim of "willfulness."

Published in: Business
0 Comments
0 Likes
Statistics
Notes
  • Be the first to comment

  • Be the first to like this

No Downloads
Views
Total views
1,164
On SlideShare
0
From Embeds
0
Number of Embeds
11
Actions
Shares
0
Downloads
1
Comments
0
Likes
0
Embeds 0
No embeds

No notes for slide

Castelluccio v. IBM, IBM's Memo in Opposition to Motion to Preclude

  1. 1. Case 3:09-cv-01145-TPS Document 157-1 Filed 11/29/13 Page 1 of 2 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JAMES CASTELLUCCIO, Plaintiff, CIVIL ACTION NO. 3:09 CV 1145 (TPS) – against – INTERNATIONAL BUSINESS MACHINES CORPORATION, November 29, 2013 Defendant. AFFIRMATION OF ZACHARY D. FASMAN Zachary D. Fasman, a member of the firm of Paul Hastings LLP, counsel for Defendant, affirms and says: 1. During a conversation with Plaintiff’s counsel, Mark Carta, I represented to Mr. Carta that IBM would oppose any motion in limine filed outside of the permissible time period that this Court had established for the raising of anticipated evidentiary issues. I further stated that, if he did file such a motion, IBM preserved all rights to challenge the timeliness of that motion in any subsequent response. 2. Attached as Exhibit A is a true and correct copy of a June 30, 2008 e-mail from Russell Mandel to Keith Holmes. 3. Attached as Exhibit B is a true and correct copy of Plaintiff’s November 14, 2013 letter to the Court requesting permission to file the instant motion. 4. Attached as Exhibit C is a true and correct copy of excerpts from the April 21, 2010 Deposition of Patricia O’Malley.
  2. 2. Case 3:09-cv-01145-TPS Document 157-1 Filed 11/29/13 Page 2 of 2

×