Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00968-WIG

Document 121

Filed 11/04/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT THOMAS MATYASOVSZKY et al. on behalf of themselves and all others similarly situated, Plaintiffs, V. HOUSING AUTHORITY OF THE CITY OF BRIDGEPORT et al. Defendants. : : : CIVIL ACTION NO. : : 3:03 CV 968 (WIG) : : : : NOVEMBER 4, 2004 :

OBJECTION TO MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION FOR PRELIMINARY INJUNCTION Defendants claim that they need additional time to review the exhibits submitted by plaintiffs in support of their motion for a preliminary injunction. Many of the exhibits were previously submitted in support of prior motions, including the motion for class certification, and more importantly, the motion of Judith Montes for a temporary restraining order, filed in January, 2004. See: Montes v. Housing Authority of the City of Bridgeport et al., 3:04 CV 1 (WIG). In support of the injunction motion, plaintiffs also submitted charts recording data concerning current tenants of Fireside Apartments and Harborview. These charts were

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Case 3:03-cv-00968-WIG

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originally provided to defendants in the spring of 2004 as part of the disclosure of an expert witness. Additionally, the defendants' counsel review the files from which this data was taken contemporaneously with the review performed by plaintiffs' counsel. Defendants also have all relevant data in the Bridgeport Housing Authority and are able to print out all or any part of that data. They have had approximately five months to review this information and should not be given more time to do so now. For the foregoing reasons, defendants' request for additional time should be denied. THE PLAINTIFFS,

BY __________________________ Alan Rosner, Esq. (CT 10414) 1115 Main Street, Suite 415 Bridgeport, CT 06604 (203) 384-1245 Fax (203) 384-1246 [email protected]

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Case 3:03-cv-00968-WIG

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CERTIFICATION This is to certify that a copy of the foregoing has been served by regular first class mail and by fax (2033-357-7915) to Michael Ryan, Esq., and James Mahar, Esq., Ryan Ryan Johnson & Deluca, P.O. Box 3057, Stamford, CT 06905.

_________________________ Alan Rosner

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