Free Order on Motion for Default Judgment - District Court of Connecticut - Connecticut


File Size: 62.9 kB
Pages: 1
Date: March 9, 2004
File Format: PDF
State: Connecticut
Category: District Court of Connecticut
Author: unknown
Word Count: 486 Words, 3,073 Characters
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URL

https://www.findforms.com/pdf_files/ctd/21972/141.pdf

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I /15* / Case 3:03-cv-00109-AVC Document 141 Filed O3/08/2004 Page 1 of 1 p
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0 IN THE UNITED STATES DISTRICT COURT j `
(L? DISTRICT OF CONNECTICUT i [ "`
JJ DUTKIEWICZ, etal, CIVIL ACTION NO.·B:03—CV-IO9 (AVC r" 1
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5 gTA'£`E O,F CONNECTICUT : '
-i-4 DEPARTMENT OF CHILDREN AND
ij CL FFAMILIES, et al, I l i
'U U Dejiandams i Septembelri4, 2003
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ii EQ/IOTI@l FOR DEFAULT JUDGEMENT AGAINST DEFENDANTS l*DNNIE MASKERY, K
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U @q NBOW IN A TEAR WORKSHOPS, LLC AND PEDIATRIC ASSOCIATES l
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3 On August 20, 2003, Plaintiffs filed a "l\/lotion for Default" with tire clerk against Bonnie
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ij, Maskery (“Maskery") and Rainbow In a Tear Workshops, LLC (°‘Rainbow") land Pediatric Associates I
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Ag ("Pediatric") for failing to tile an appearance and an answer to the complaint. Judgment should be ‘
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Q`; entered in favor of the Plaintiffs and as a result of the Defendants failure to file, it is deemed to be an
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E admission that the demands ofthe Plaintiff` s complaint are valid and true. p
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Q In the case of Pediatric, the monetary damages, which include purliiive and compensatory
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gl , damages in the amount of $500,00000, be awarded to the Plaintiffs. That Pediatric created, allowed and l
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. g . ff Q promoted an atmosphere of being “DCF happy" which harmed the Plaintiffs denied them their due
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5 rtg 1 11 ` process rights and civil rights. Pediatric is responsible for policy and training do to their actions and
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(U `111 QI inactions, office personnel along with both Drs. Hodder and Clark conspiredltmd misrepresented the
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"5 `_ gl Plaintiffs children’s records which resulted in the false charges of "Medical lNeglect" and "Physicai
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(G - _ Neglect". Office personnel took a perfectly normal child’s record and proceeded to go through those
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Q (D 1; my records and pick and choose three and four word sound bites without explanatieii and wrote it on a pre
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3 J`, fj made form by Pediatric and faxed that information to DCF.
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gi Up to April 12, 2003, when the investigation started by DCF, Pediatric lied no concern what so
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*' Q ever nor did Drs. Hodder and Clark or their office staff on what they were about to unleash on the
if § Plaintiffs. This practice of putting any old inforination on the form even if it alas 4-years old from the '
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