Free Motion for Judgment - District Court of Connecticut - Connecticut

A i' Case 3:03-cv-0060@RU Document 49 Filed 11/263003 Page1 of 3 N
ri.? il ii? lvl l
UNITED STATES DISTRICT COURT l t A ‘‘‘‘' °
DISTRICT OF CONNECTICUT
. Zllll} lllllll 2l-1 ij it ° Eq !
ROBERT L. BROCKWAY, JR. ;
z crvn. Acrrbiy,i>t_Q._‘»‘- I Ai A z i
Plaintiff : 3;03CVO0609 (SRU) .
v. . { *
YALE UNIVERSITY; JEROME N. FRANK zi
LEGAL SERVICES ORGANIZATION OF
YALE LAW SCHOOL; RICHARD C. LEVIN, 1 I
President of the University, Official Capacity;
ROBERT A. SOLOMON, Director of JEROME N. 2
FRANK LEGAL SERVICES ORGANIZATION i
OF YALE LAW SCHOOL, I/O; ANTHONY T. : I
KRONMAN, Dean of Yale Law School, I/0;
CARROLL LEE LUCHT, Law Professor, ;
and Attorney at Law, I/O; STEPHEN WIZNER,
Law Professor, and Attorney at Law, I/O. :
Defendant(s) NOVEMBER 21, 2003
1’LAIN’I`IFF’S DEMAND FOB JUDGMENT
In accordance with Fed. R. of Civ. P. 54 (c) Demand for Judgment
and (1) Costs Other than Attm·neys’ Fees the plaintiff respectfully submits this
Demand for Judgment.
This due to the following established facts: l
I
l— The defendants have failed to reply by November 20, 2003 as required by Court
I
Order.
l
2~ The defendants have failed, to refute the plaintiff s evidence, as has been presented in
this matter. l
1
3- The defendants filed a Motion for Interrogatories, and Request for Production which
plaintiff answered, and subsequently the plaintiff tiled his own Request for
l
i‘i·e · e-e- ij;. ·;-L-A A- —,-,-. ..;_..;_- .. ._ _, _ _, _ _, _ _, p __,__ __T_W__ __,, pp y _ y __ _,,_ _ _
-e,· TTT A -`"* - Y*`< 7*% I`.? ii‘. i ‘ii.';i I
-. .. ll. .. ._ _. nininininini _ if
`"‘i‘ s ··-- `Qii ‘_;.s· ~ ~;_— -.;i..;_.. .. .. ._ _, ,_ _; _ _, _ _' V _ _ __:_ T____rr rr__ U _ y _ _ _ _ _, __
.s.. ii . . ‘·e. i e;·;.i ; ?

i Case 3:03-cv-OO60@RU Document 49 Filed 11/267%)% Page 2 of 3 i
J J l
Production. Defendants never complied in turn, and ignored plaintiffs request. This I
further indicates, defendants’ continued unwillingness, to participate in these ,
deliberations.
4- The plaintiff has submitted a detailed Cost Analysis, of expenses incurred, during the
course of this matter.
!
5- The defendants have refused to honor Court Order for required conferencing.
6— The plaintiff has submitted a Motion for Sanctions against defendants, due to
l
documented unwillingness of defendants to cooperate, with Court ordered ’
conferencing process.
The plaintiff respectfully asserts that there is no just reason for delay in
this matter, due to the demonstrated absence of interest by the defendants, to participate
in the deliberations of this honorable Court. A reasonable person would conclude that the
plaintiffs Demand for Judgment should be granted, and that an equitable financial
remedy by found, for his established complaints. p
Accordingly it is respectfully requested that, this honorable Court
adjudge this matter in the plaintiff s favor, and order iinancial relief as it deems
reasonable.
RESPECTFULLY SUBMITTED,
/} / /
' / A `
’ i·` L. roc ay, Jr. '
28 Boston Terrace
Guilford, Connecticut 06437
(203) 2l4—O202
l
I
2 l

t 1 I I
1 Case 3:03-cv-0060 — U Document 49 Filed 1 1/2 /2 O3 Page 3 of 3
, {W I} ;
5
` I 5
BROCKWAY V. YALE UNIVERSITY, ET AL
USDC, BRIDGEPORT CIVIL ACTION NO.3:03CVOO609 (SRU) 1
CERTIFICATION I
This is to certify that the foregoing PLAINTIFF’S DEMAND FOR JUDGMENT I
has been served in person on November 21, 2003 to the law office of PATRICK M.
1
NOONAN and BROCK T. DUBIN of DELANEY, ZEMETIS, DONAHUE, DURHAM I
& NOONAN, P.C., Concept Park-Suite 306, 741 Boston Post Road, Guilford, CT x
I
06437.
I
ll . fl P a
' ¤ ert L, roc way, Jr.
1

I
1
I
3 I
I