Free Motion for Reconsideration - District Court of Connecticut - Connecticut

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{ I Case 3:03-cv-OO998—JG|\/I Document 46 Filed O1/21/2005 Page1 of 2
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{ { INF§gETE;1IgED STATES DISTRICT COURT
{ ISTRICT OF CONNECTICUTIHUS [D 2;
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{ A : lFJ"é`K’?lli]l` COURT
{ SANTIAGO E. CARTAGENA E 3:03 CV CT
| THAMES VALLEY WATER DATE: JAN. 20, 2005
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{ MOTION FOR RECONSIDERATION {
{ The plaintiff, Santiago Cartagena hereby moves this Honerable Court to F
{ grant a Motion For Reconsideration on this Honorable Court's ruling dated {
{ Dec.22, 2004. The plaintiff, upon belief and knowledge, believes Atty. Thomas
{ W. Bucci, plaintiff's "former" counsel failed to provide adequate notice in
{ his Motion To Withdraw Apperance (Dkt.#38), failed to communicate his reasons
for withdrawing and failed to provide realistic legal direction in regard to
my case. The plaintiff believes he was intimated, threatened and harrassed by {
Atty. Bucci and his secretary on or about 9/31/ 2004. All of this was in res—
ponse to a debate on attorney fees. The plaintiff was a member of the Pre-
Paided Legal Services and paid a monthly rate. Atty. Bucci was initially very
interested in the plaintiff case v. the defendant, and accepted the plaintiff's
case on a contingency basis, why the need for legal fees? The plaintiff cannot
remember recieving the Dec. 22, 2004 Motion to Withdraw w/ it's certification
of service, which Atty. Bucci is legally bound to supply! Additionally, Atty. {
Bucci mailed, via certified mail a letter dated January 3, 2005 which warned {
the plaintiff of date deadlines...on or before December 17, 2004 and mentioned {
...0n or before January 5, 2005. The delivery notice from the U.S. Postal {
service is dated l-6-05. In all due respect how could the plaintiff properly {
A respond to these past due dates? The plaintiff believes these facts are grounds {
{ for "good cause" and prays that this Honorable Court will grant this Motion For {
{ Reconsideration as well as revoking the order to dismiss and the motion to {
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I Case 3*03-cv-00998—JG|\/I Document 46 Filed 01/21/2005 Page 2 of 2
I withdraw appearance. The plaintiff has a legimate right to seek redress from the
I defendant, both the State of Ct.'s Commission on Human Rights and Opp'ty, as well
I as the EEOC concur. This case is very important to the plaintiff and the minor
I children the plaintiff supports.
I Dated at Pawcatuck, Connecticut, this 20th of January, 2005.
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I ~“ Santiagé E. Cartagena
I Pro Se
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I CERTIFICATION gé I3 yy
I THIS IS T0 CERTIFY that on the 20th day of January, 2005 the foregoing Motion For
I Reconsideration, was mailed via first class mail to the following:
IRichard J. Pascal,Esq.
P.O. Box 310
Norwich, Ct. 06360
Atty. Thomas W. Bucci
855 Main St.
Bridgeport, Ct.06604
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