Free Objection - District Court of Connecticut - Connecticut


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Date: July 16, 2008
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State: Connecticut
Category: District Court of Connecticut
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Case 3:01-cv-02374-CFD

Document 124

Filed 07/16/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

: : : v. : : TOWN OF STONINGTON, ET AL, : Defendants :

EDWARD BROWN, Plaintiff,

3:01-CV-02374 (CFD)

July 16, 2008

PLAINTIFF'S OBJECTION TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

The plaintiff, Edward Brown, by and through his undersigned counsel, hereby objects to Defendant's Motion for Summary Judgment and in opposition thereto submits the following: 1. The plaintiff's Local Rule 56(a)(2) Statement and Counter Statement of disputed

material facts; 2. 4. Exhibits A and B, and; Memorandum of Law.

For the reasons more clearly set forth in the accompanying memorandum of law, the plaintiff respectfully submits that there is sufficient evidence upon which a jury may conclude that the defendants used excessive force against Mr. Brown and violated his First Amendment rights. WHEREFORE, for these reasons and those more fully set forth in the accompanying exhibits and memorandum, the defendant's motion must be denied.

Case 3:01-cv-02374-CFD

Document 124

Filed 07/16/2008

Page 2 of 2

Respectfully submitted, THE PLAINTIFF, EDWARD BROWN

BY: /s/ John F. Geida /s/ John F. Geida, Esq. Fed Bar No. Ct27468 The Law Office of Norman A. Pattis, LLC 649 Amity Road, PO Box 280 Bethany, CT 06524 Tel. 230.393.3017 Fax. 203.393.9745 His Attorney

CERTIFICATION I hereby certify that on July 16, 2008, a copy of the foregoing was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.

BY: /s/ John F. Geida /s/ John F. Geida, Esq. Fed Bar No. Ct27468 The Law Office of Norman A. Pattis, LLC 649 Amity Road, PO Box 280 Bethany, CT 06524 Tel. 230.393.3017 Fax. 203.393.9745 His Attorney