Free Motion for Contempt - District Court of Connecticut - Connecticut


File Size: 54.3 kB
Pages: 3
Date: December 31, 1969
File Format: PDF
State: Connecticut
Category: District Court of Connecticut
Author: unknown
Word Count: 390 Words, 2,478 Characters
Page Size: 611.28 x 790.92 pts
URL

https://www.findforms.com/pdf_files/ctd/22930/23.pdf

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I Case 3:03-cv-O1 Document 23 Filed 07/34,42006 Page 1 of 3
_ ..
UNITED STATES DISTRICT COURT I
_ _ DISTRICT OF CONNECTICUT -
SECURITY INSURANCE COMPANY OF :
_ HARTFORD, as successor to FIRE AND :
. CASUALTY INSURANCE COMPANY OF :
CONNECTICUT, : CIVIL NO. 3:03 CV 1000(PCD)
I Petitioner,
TRUSTMARK INSURANCE COMPANY, JULY 31, 2006 P
Respondent.
- APPLICATION FOR ORDER OF C ONTEMPT
AND FOR ORDER TO SHOW CAUSE
" Petitioner Security Insurance Company of Hartford, as successor to Fire and
Casualty Insurance Company of Connecticut, by its attorneys, Robinson & Cole LLP, I
respectfully moves this Court to hold Trustmark Insurance Company in contempt, enter
judgment against Trustmark for $9,424,337 plus interest and expenses, and grant petitioner
such other and further relief as the Court may think just and proper. Petitioner further
requests that Trustmark be ordered to show cause why an Order of Contempt should not
enter against it. The grounds for this application are set forth in the supporting
memorandtun of law, dated July 31, 2006, and the Declaration of Dennis T. Haver, made
I July 26, 2006.

Case 3:03-cv-O1 Document 23 Filed 07/<3’:l=é2006 Page 2 of 3
I ·__e 3 ‘
` SECURITY INSURANCE COMPANY OF
. I HARTFORD, as successor to FIRE &
CASUALTY INSURANCE COMPANY OF
CONNECTICUT
Frank F. Coul r. (ct 05230)
I I Robinson & Cole LLP
280 Trumbull Street I
. Hartford, Connecticut 06103-5397 `
Tel: (860) 275-8200
. Fax: (860) 275-8299
Of Counsel: .
David J. craig I U
Kathryn C. Ellsworth · {IE
Dewey Ballantine LLP ‘ I
1301 Avenue ofthe Americas
New York, New York 10019-6092 I
Tel: (212) 259-8000 ‘ `
Fax: (212) 259-6333 ` — ·

Case 3:03-cv-O10,QQ;PCD Document 23 Filed 07/3-1.42006 Page 3 of 3
‘.‘_»
‘ CERTIFICATION
i This is to certify that on this 31st day of July, 2006, a copy ofthe foregoing
. Application for Order of Contempt and for Order to Show Cause was served by first class
_ mail, postage prepaid, on the following cotmsel of record:
David Spector, Esq. _
p Everett I. Cygal, Esq. -
Schiff, Hardin & White ·
6600 Sears Tower _
· Chicago, IL 60606-5600
Jeffrey R. Hellman, Esq.
‘ Zeisler & Zeisler, P.C. ` p
558 Clinton Avenue
P.O. Box 3186 ‘
Bridgeport, CT 06605-0186 ‘ U E Q _ .
‘ Frank F. Coulom, Jr. ·