Free Statement of Material Facts - District Court of Connecticut - Connecticut

Case 3:O3—cv-O1055—AVC Document 84 Filed O1/17/2006 Paget of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
DOLORES FONSECA, RAFAEL FONSECA, : CRIMINAL ACTION NUMBER
AND MELANIE FONSECA, :
Plaintiffs, : 3:03cv01055(AVC)
v.
JASON ALTERIO, JORGE LARREGUI,
AND THE CITY OF BRIDGEPORT :
Defendants 1 JANUARY 13, 2006
PI..AINTIFFS’ LOCAL RULE 56Ia)2 STATEMENT
IN RESPONSE TO DEFENDANTS CITY OF BRIDGEPORT
AND LARREGUFS RULE 56(a)1 STATEMENT
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted. ,
5. Admitted.
6. Denied.
6.(sic) Admitted that Alterio arrived while Larregui was talking to Mrs. Fonseca. Denied
that Alterio asked Larregui what happened. The plaintiff is unable to admit or deny
whether Alterio asked Mrs. Fonseca what had happened.
7. Admitted.
8. Admitted.
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Case 3:03-cv-01055-AVC Document 84 Filed 01/17/2006 Page 2 of 4
9. Admitted.
10. Admitted.
11. Plaintiff is unable to admit or deny.
12. Admitted.
13. Admitted, except denied that Alterio could not see her face and did not see that
she was injured.
14. Plaintiff is unable to admit or deny because Melanie Fonseca, who was 7 years old
when the incident took place and only 8 or 9 years old when Defendant deposed her,
was unable to remember and/or verbalize much about the incident.
15. Plaintiff is unable to admit or deny because Melanie Fonseca, who was 7 years
old when the incident took place and only 8 or 9 years old when Defendant deposed
her, was unable to remember and/or verbalize much about the incident.
16. Plaintiff is unable to admit or deny because Melanie Fonseca, who was 7 years
old when the incident took place and only 8 or 9 years oid when Defendant deposed
her, was unable to remember and/or verbalize much about the incident.
17. Plaintiff is unable to admit or deny because Melanie Fonseca, who was 7 years
old when the incident took place and only 8 or 9 years old when Defendant deposed ·
her, was unable to remember and/or verbalize much about the incident.
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Case 3:03-cv-01055-AVC I Document 84 Filed 01/17/2006 Page 3 of 4
18. Admitted.
19. Admitted.
20. Plaintiff is unable to admit or deny.
21. Admitted to extent that prosecutor objected to dismissal of criminal case, that
criminal case was tried before a jury, that trial court denied motion forjudgment of
acquittal and that jury acquitted Dolores Fonseca of ail charges.
THE PLAINTIFFS,
. DOLORES FONSECA, RAFAEL FONSECA
AND E FONSECA
. DIANE POLAN
Law Offices of Attorney Diane Polan, LLC
it 129 Church Street, Suite 802
New Haven, CT 06510
po|[email protected]
Telephone: 203-865-5000
Facsimile: 203-865-2177
Federai Bar No. ctO0223
Their Attorney
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Case 3:03-cv-01055-AVC Document 84 Filed 01/17/2006 Page 4 of 4
CERTIFICATION
This is to certify that a copy of the foregoing has been sent via first class mail,
postage prepaid, this 13th day of January, 2006, to the following counsel and parties of
record:
Attorney Barbara Brazzel—|\/lassaro
Office of the City Attorney
999 Broad Street, 2"" Floor
Bridgeport, CT 06604-4328
E-mail: [email protected]§clgeport.ct.us
Elliot B. Spector, Esquire
Noble, Spector, Young & O’Connor ‘
One Congress Street, Fourth Floor
Hartford, CT 06114
E-mail: [email protected]
DIANE POLAN l
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