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


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Date: November 6, 2003
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State: Connecticut
Category: District Court of Connecticut
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N ' ` Case 3:03-cv-0060S@RU Document 47 Filed 11/0%)% Page 1 of 3
UNITED STATES DISTRICT COURT F I L E D
DISTRICT OF CONNECTICUT
ROBERT L. BROCKWAY, JR. 3 mn] NOV _5 ID 2: Bl
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Plaintiff : 3:0 "i)0i609 (SRU
V. . :
YALE UNIVERSITY; IEROME N. FRANK
LEGAL SERVICES ORGANIZATION OF
YALE LAW SCHOOL; RICHARD C. LEVIN, :
President of the University, Official Capacity;
ROBERT A. SOLOMON, Director of JEROME N. I
FRANK LEGAL SERVICES ORGANIZATION
OF YALE LAW SCHOOL, I/O; ANTHONY T. 1
KRONMAN, Dean of Yale Law School, UO;
CARROLL LEE LUCHT, Law Professor, :
and Attorney at Law, I/O; STEPHEN WIZNER, .
Law Professor, and Attorney at Law, I/O. :
Defendant(s) NOVEMBER 4, 2003
i PLAINTIFF’S MEMORANDUM OF LAWS
IN SUPPORT OF ANSWER TO DEFENDANTS’ MOTIQN TO DISMISS
Connecticut Rules of Court (1999) Chapter 3. Appearances Sec. 3··7
Consequence of Filing Appearance states the following:
"(a) Except by leave of the judicial authority, no attorney shall be permitted
to appear in court or to be heard in behalf of a party until the att0rney’s appearance p
has been entered." l
l
On December 22, 1999 these defendants filed a substantive legal document,
during the plaintiff s appellate deliberations, within the honorable United States Court of
Appeals for the Second Circuit. These defendants did not enter an Appearance either I

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N I ’ Case 3:03-cv-O060®QU Document 47 Filed 1 1/O@O3 Page 2 of 3
J before filing this document, nor did they tile an Appearance through out the course of this
Appeal. This document was sent to opposing legal counsel, and tothe Court.
l These defendants presumably were representing Yale Law School, and Yale \
N University; however, neither of these parties was a defendant, nor had legal standing in C
l mentioned appeal. These defendants performed an illegal act.
This act typities defendants’ pattern of intent to disregard plaintiff s rights, and J
their retaliation against plaintiff s empowerment of his rights, which have been I
previously documented. _
These defendants jeopardized the plaintiff s case, violated the Law, and the Rules
of Court. Accordingly the p1aintiH pleads for his labor, and expenses as earlier l
specified.
RESPECTFULLY SUBMITTED,
/1 . i
gfgad WZ i
’ obert L. rockway, Jr. ` ,
28 Boston Terrace l
Guilford, Connecticut 06437 i
(203) 214-0202
2 I
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l t Case 3:03-cv-0060 :8 U Document 47 Filed 1 1/O O3 Page 3 of 3
l ir rei.,
I I
BROCKWAY V. YALE UNIVERSITY, ET AL
USDC, BRIDGEPORT CIVIL ACTION NO.3 :03 CV00609 (SRU)
CERTIFICATION
This is to certify that the foregoing PLAINTIFFS MEMORANDUM OF LAWS R
IN SUPPORT OF ANSWER TO DEFENDANTS’ MOTION TO DISMISS has been
served in person on November 4, 2003 to the law office of PATRICK M. NOONAN and
BROCK T. DUBIN ofDELANEY, ZEMETIS, DONAHUE, DURHAM & NOONAN,
P.C., Concept Park-Suite 306, 741 Boston Post Road, Guilford, CT 06437.
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Robert L. Brockway, Jr. {
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