Free Response - District Court of Connecticut - Connecticut

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i r Case 3:00-cv-OO65Q—CFD Document 113 Filed O9/29/2004 Page 1 of 3
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FOR THE DISTRICT OF CONNECTICUT `
E§E5`§§¥H1]¥]B`¤ZJ`§¥K%`EE§LiKL`LE§EEf }}i`ET§§A ``````` ; i CIVIL ACTION NO.;
NORTHEASTERN OPEN INVITATIONAL INC. I 3:00 CV 650 (CFD)
Plaintiffs Z y
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: September 23, 2004
JOHN NYEIVICHEK and CATHI NYEIVICHEK Z f
Defendants Q
OBJECTION TO MOTION TO ENFORCE JUDGMENT
The court entered a judgment by stipulation on December 1, 2004. At issue is
Paragraph 3 of the Stipulation (p. 3, line 2 et gz; of the transcript as attached to the Plaintiffs {
motion): 5
"Three. For the periods set forth below John and Cathi Nyemchek will not own,
organize, permit others to organize in their names, or lead people to believe that they own or
have organized:
a. Competitions in Connecticut for ten years;
b. Competitions in New York, New Jersey, Massachusetts, for one year;
c. Unsanctioned competitions in New York, New Jersey or Massachusetts for three [
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d. Competitions in Connecticut, New York, New Jersey or Massachusetts for 90
days of any existing competit:ion for ten years."
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i _ Case 3:00-cv-OO650=CFD Document 113 Filed O9?%2004 Page 2 of 3
i At issue here is subsection (c) "unsanctioned competitions in New York, New Jersey or
Massachusetts for three years".
We are organizing a Dancesport International Championship in White Plains on June 3-
5, 2005. A copy of the ad is attached to the PIaintiff's motion as Exhibit A. The ad notes:
"Sanctioned by USABDA's USA DanceSport Council". As such, it does not violate Stipulation E
3(c) since the event is plainly sanctioned not unsanctioned as asserted by the Plaintiffs.
This motion is frivolous and harassing. We respectfully request that this court deny the
motion.
THE DEFENDANTS
BY ’ l; /
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By -’ iii I, ·-
CATHI NY CHEK
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{ __ - - "" Case 3:00-cv-006£20=SZFD Document 113 Filed O9{29j2004 Page 3 of 3
! CERTIFICATION
This is to certify that a copy of the foregoing has been sent on September 23, 2004, via
certified mail, postage prepaid to Attorney Leon Kaatz, 111 Oak Street, Hartford, CT 06106
and to Attorney John Linderman, McCormick Paulding & Huber LLP, 185 Asylum Street,
Hartford, CT 06103 and pro se parties of record: I
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