Free Motion in Limine - District Court of Connecticut - Connecticut

Case 3:00-cv-00835-CFD Document 336 Filed O3/O4/2004 Page 1 of 3 {
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UNITED STATES DISTRICT COLET` L. E D
I DISTRICT OF CONNECTICUT
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INDYNIAc BANK, I=.s.s.
Plaintiff cIvII. ACTION No.
s:00cvsss (CFD)
v. Z
NIoSTAI=A REYAD AND WAFA REYAD
Defendants
DATE: IIIIARcI-I 3, 2004
DEFENDANT IIIIoSTAI=A REYAD’S TI-IIRD MOTION IN I.IIvIINE
Defendant Mostafa Reyad moves this Court to add the attached three documents
to the list of Defendants exhibits. The said documents obtained after the filing of
the pre-trial memorandum on November 18, 2003. The documents are materials
to Defendants claims. The three documents:
1. A copy of the Ruling of United States Court of Appeals dated February 17,
2004 (2 pages).
2. A copy ofthe surrender of policy No. 048230202; face value was one
million dollar insuring Mostafa Reyad dated February 23, 2004.
3. A copy of two notices of Lapse for two insurance policies; face amount
was one million dollar combined, was insuring I\/Iostafa Reyad, both dated
January 5, 2004.
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_ _ Case 3:00-cv-00835-CFD Document 336 Filed O3/O4/2004 Page 2 of 3 f
The first document shows that, the Third Circuit dismissed the Appeal, because it
merely postpones the resolution of the case pending proceedings in another
federal court. Defendant claims damages caused by the New Jersey action, gag,
Defendants’ first claim p. 28, exhibit "B" of the pre-trial memorandum. Plaintiff
responded at p.3, exhibit "A” of the memorandum; Plaintiff claims that this Court
has no jurisdiction to review such Orders. Q
The second and the third documents are to adjust the actual damages suffered
_ by Defendants caused by this action by the amount of two million dollar lost by
Defendant Mostafa Reyad. As the dates of these documents show, it was not
available to be claimed, and now it should be accepted as admissible evidence at
the trial of this action.
CONCLUSION
The Honorable Court should accept these documents as part of Defendants!
exhibits at the Trial.
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The Defendant l
Mostafa Reyad
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2077 CenterA - # 22D
Fort Lee, NJ 07024
Day Phone 203-325-4100
Home Phone 201-585-0562
CERTIFICATION
The Undersigned certifies that he mailed a true and correct copy of this Motion to
Attorney David Schaefer 271 Whitney Avenue, New Haven, CT 06511 and Wafa
Reyad at 2077 Center Avenue # 22D, Fort Lee, NJ 07024.
Mostafa geéé Q
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