Free Response - District Court of Connecticut - Connecticut

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I Case 3:03-cv-00617- K Document 58 Filed 02/14/2006 Page 1 of 2
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I UNITED STATES DISTRICT COURT ‘ I
I ` DISTRICT OF CONNECTICUT I
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DARIUSZ GRZEGORCZYK : Case N0.: 3:03cv00617,(MRK) (WIG) I
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: FEBRUARY 14, 2006 I
M & M GETTY SERVICE INC., etal. : I
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RESPONSE TO ORDER TO SHOW CAUSE I
DATED JANUARY 25, 2006 I
The Plaintiff, DARIUSZ GRZEGORCZYK, through counsel hereby respectfully requests
that dismissal with prejudice not be entered with regard to the above captioned matter. While
good cause does not exist, Plaintiffs failure to attend the hearing in damages was not willful nor
meant as an insult to the Court. Plaintiffs counsel was on trial presenting PIaintiff's case before I
a jury on the matter known as Hock v. Kalimian, and bearing docket number CV-03-0476331-
S, before the Honorable Judge Blue in New Haven Superior Court. While the client was notified
prior to the hearing not to attend, leave was inadvertently and mistakenly not obtained by this I
Honorable Court even though undersigned counsel thought it had been. Undersigned counsel .
offers this not as an excuse but as an explanation. I
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More importantly, Plaintiffs counsel will accept any sanction imposed by this Court as
being proper and just because of counseI's past experience. It is hoped that PIaintiff's I
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counseI's negligence will not be perceived as disrespect to this Court. I
RESPECTFULLY SUBMITTED I
THE PL/-\|NT|FF I
DARIUSZ GRZEGORCZYK I
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By:
MICHAEL S. HILLIS
DOIVIBROSKI, KNAPSACK & HILLIS LLC
129 Whitney Avenue
New Haven, Connecticut 06511 _
(203) 624-9096 I
Federal Bar No.: ct11867 I
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[ . Case 3:03-cv-00617-W Document 58 Filed O2/14/29456 Page 2 of 2
CERTIFICATION ol= SERVICE
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l I hereby certify that a copy of the foregoing Response to Order to Show Cause was
1 mailed on February 14, 2006, to all counsel and pro se parties of record.
cHAMBERs OF THE i·loNoRABl.E WILLIAM l. GARFINKEL
U.S. District Court l
915 Lafayette Boulevard
Bridgeport, Connecticut 06604
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MICHAEL s. HILLIS l
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