Free Sealed Motion - District Court of Connecticut - Connecticut

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UNITED STATES DISTRICT COURT ‘ I I I. .1 E I I
DISTRICT OF CONNECTICUT ‘
THOMAS MATYASOVSZKY et al., on behalf of :
themselves and all others similarly situated, :
Plaintiffs, : CIVIL ACTION NO.
: 3:03 CV 968 (WIG)
V. : l i
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HOUSING AUTHORITY OF THE CITY OF 2 SEPTEMBER 21, 2004 .
BRIDGEPORT et al. :
Defendants. :
MOTION TO AMEND COMPLAINT
AND JOIN PATSY MICHELLE AS A PARTY DEFENDANT
Plaintiffs, pursuant to Rules l5(a) and 20(a) of the Federal Rules of Civil
Procedure, hereby move this Court for an order granting leave to amend the complaint I
and to join Patsy Michelle, recently appointed Acting Executive Director ofthe Housing
Authority of the City of Bridgeport (“BHA"), as a party defendant. Plaintiffs also seek to
add the facts of persons granted leave to intervene as plaintiffs in this case. This motion is
based on the following facts: |
I. This action was filed on May 30, 2003 against defendant Collin Vice, as »Z I
Executive Director of the BHA, and others, to challenge their policy and practice of 5
operating a public housing complex intended equally for both elderly and disabled tenants
an an “eIderly only" complex. Plaintiffs have alleged violations of the state and federal i
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fair housing acts, the Americans with Disabilities Act and the Rehabilitation Act.
2. Defendant Vice served as Executive Director until December 22, 2003, when R
she was terminated from her position. Ms. Vice oversaw the unlawful operation of
Fireside Apartments as :1 de facto "elderly only" complex, and failed and refused to
rescind the discriminatory practices and policies that denied disabled persons access to \
public housing intended for disabled persons. ’
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3. Defendant Judit Grot`—Tisza was hired on December 22, 2003 to serve as
Acting Executive Director. She continued the same illegal policies and practices which
prompted tiling of this case in the first instance. l
4. In or about August, 2004, defendant Grof-Tisza resigned her position and was
replaced as Acting Executive Director by Patsy Michelle. Proposed defendant Michelle Q
has also failed to rescind the discriminatory practices of the BHA and has failed to
remediate the harm caused to current and past disabled applicants who were entitled to be
considered for elderly/disabled housing at Fireside Apartments but were precluded from
receiving such consideration because of the BHA’s illegal actions and policies.
5. This is the second request to join a new party to this action and the second
request to amend the complaint.
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S THE PLAINTIFFS, Q
BY @a,,_YE,sN_
Alan Rosner, Esq. (Ct 10414) ‘
1115 Main Street, Suite 415 __ I
Bridgeport, CT 06604 `
(203) 384-1245
Fax (203) 384-1246
Alanros11er@a<>I.com
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` CERTIFICATION
This is to certify that a copy ofthe foregoing motion has been served by regular
first class mail postage prepaid on this 21S' day of September, 2004 to Michael
Ryan, Esq., Ryan, Ryan Johnson & Deluca, LLP, P.O. Box 3057, 80 Fourth _
Street, Stamford, CT 06905-3057. {
Alan Rosner l
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