Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00968-WIG

Document 22

Filed 10/20/2003

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT THOMAS MATYASOVSZKY on behalf of himself and all other similarly situated Plaintiff, V. HOUSING AUTHORITY OF THE CITY OF BRIDGEPORT, ET AL. Defendants. : : : : : : : : : : : :

CIVIL ACTION NO. 3:03 CV 968 (RNC)

OCTOBER 20, 2003

OBJECTION TO MOTION TO INTERVENE The undersigned Defendants, HOUSING AUTHORITY OF THE CITY OF BRIDGEPORT, COLLIN VICE, individually and in her official capacity as Executive Director of the Housing Authority of the City of Bridgeport, and JONAS DE GUZMAN, individually and in his official capacity as Special Assistant to the Executive Director of the Housing Authority of the City of Bridgeport Housing Authority of the City of Bridgeport, in the above-captioned matter, hereby object to intervener Judith Montes' Motion for Permissive Intervention pursuant to FRCP 24(b) on the grounds that the proposed intervenor has failed to establish the requisite common questions of law or fact. In addition, intervention will unduly delay the resolution of this action and the proposed intervenor's interests are adequately represented. Accordingly, the Motion to Intervene should be denied. The Defendants submit the attached Memoranda of Law in Opposition to Motion to Intervene. Oral Argument Requested Testimony Not Required

Case 3:03-cv-00968-WIG

Document 22

Filed 10/20/2003

Page 2 of 2

THE DEFENDANTS,

By: Michael T. Ryan, Esq. (ct 05685) Ryan, Ryan, Johnson & Deluca, LLP 80 Fourth Street, P.O. Box 3057 Stamford, CT 06905 Juris No. 52525 Phone No. 203-357-9200 CERTIFICATE OF SERVICE I hereby certify that on October 20, 2003, a copy of the above was mailed to the following counsel and pro se parties of record: Alan Rosner, Esq. Law Offices of Alan Rosner 1115 Main Street, Suite 415 Bridgeport, CT 06604 Attorney for Plaintiff, Thomas Matyasovszky, on Behalf of Plaintiff Class Jennifer Vickery, Esq. Law Offices of Alan Rosner 1115 Main Street, Suite 415 Bridgeport, CT 06604 Attorney for Plaintiff, Thomas Matyasovszky, on Behalf of Plaintiff Class

___________________________________ Michael T. Ryan, Esq.
I:\Procases\1742.007\objection101503.wpd 1742.007