Fracasse v. People's United Bank
A court can grant production requests for credit card statements, vacation and travel itineraries that are reasonably calculated to lead to the discovery of admissible evidence. The plaintiff, Tracy Fracasse, sued People’s United Bank, and alleged it misclassified her as an exempt employee and failed to pay overtime, when she worked more than 40 hours per week, in violation of the Fair Labor Standards Act and the Connecticut Minimum Wage Act. Fracasse estimated that she worked six hours or more each weekend. The defendant filed discovery requests for production and asked Fracasse to provide credit card statements, vacation information and travel itineraries. Fracasse objected that the requests for production were overly broad and unduly burdensome. "A court can limit discovery if it determines . . . that the discovery is: 1.) unreasonably cumulative or duplicative; 2.) obtainable from another source that is more convenient, less burdensome, or less expensive; or 3.) the burden or expense of the proposed discovery outweighs its likely benefit," pursuant to In Re: Priceline.com Inc. Securities Litigation, a 2005 decision of the U.S. District Court for the District of Connecticut. The District Court overruled Fracasse’s objections to the defendant’s production requests, which were reasonably calculated to lead to the discovery of admissible evidence. The court ordered the plaintiff to make good-faith efforts to locate personal calendars, vacation and travel itineraries in her possession and to contact her credit card company.