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

I Case 3:03-cv-00441-JCH Document 42 Filed O4/07/2004 Page 1 of 2
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I UNITED STATES DISTRICT COURT L E D U
DISTRICT OF CONNECTICUT mm] APR n
I . `l P 32 35
I I STANLEY CHANCE : CIVIL ACTION NO] (JCH) I
I . V, . i mitpgftlfiiil
I CONNECTICUT HEALTHCARE : ’
I WORKERS COMPENSATION TRUST : APRIL 7, 2004
I PLAINITFFS’ OPPOSITION TO DEFENDNAT CONNECTICUT I
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I After review of all case law the plaintiff, Stanley Chance does not dispute the
I defendant position that the Compensation Commission has exclusive jurisdiction over
I workman’s compensation claims and this is established in the District Court as well. See
I Myers —v- Arcudi, 915 F .Supp. 522 (D. Conn. 1996).
I However, the backbone of the plaintiffs complaint is not the defendants failure to I
I award compensation benefits per se. I
The backbone of the plaintiffs’ complaint is the defendant’s reasons for their
denying the plaintiffs workman’s compensation benefits, which is in the compliant so the
plaintiff is not going to get repetitive. I
Under the doctrine of Respondent Superior, the defendants are just as liable for
the action of defendant Kemco since they are a party to the conspiracy as well.
Even if assurnimg that the plaintiff cannot maintain this action under respondent I
superior, he very well can maintan this action for Tort for negligence and fraud. I
The defenant motion to dismiss should be denied. I
The plaintiff opologizes to the Court and Attoreny Cohen for filing pleading on *
the 7m instead of the 5 and he did not mean to cause any undue delay or disrespect to I
either of you, the Court or Attoreny Cohen. `
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I Case 3:03-cv-00441-JCH Document 42 Filed O4/07/2004 Page 2 of 2
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N r RBSPECFULLY SUBMITTED
THE PLAINTIFF
N tanley Chance, PRO SE:
. 99 Jetland Stree
Bridgepoit, CT. 06606 N
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N CERTIFICATION N
U I herby certify that a copy of the forgoing was mailed on April 7, 2004 to:
Andrew Cohe, Esq. N
Letizia, Ambrose & Falls I
l Church Street I _ jv { __,.
New Haven, CT. 06510 T"
tanley Cha Pro Se
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