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

Case 3:03-cv-00943-AWT

Document 119

Filed 06/07/2007

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT GARY SESSION, Plaintiff V. EDWIN RODRIGUEZ, ET AL. Defendants JUNE 5, 2007 CIVIL ACTION NO. 3:03-cv- 00943 (AWT)

OBJECTION TO DEFENDANT CITY OF NEW HAVEN'S MOTION FOR SUMMARY JUDGMENT The Plaintiff hereby objects to the Defendant city of New Haven's Motion for Summary Judgment dated January 22, 2007 on Counts One, Two and Three of the Revised Complaint dated June 29, 2005. There are genuine disputes as to the material facts of this case precluding the granting of summary judgment. In support of the Objection, the Plaintiff re-alleges and incorporates by reference herein his Responses to the individual Defendants' Rodriguez and Coppola's Rule 56(a)(1) Statement of Material Facts Not in Dispute, his own Rule 56(a)(2) Statement of Material Facts Not in Dispute and his memorandum of Law in Opposition to the individual Defendants' Motion for Summary Judgment. The Plaintiff further submits, a reply to the Defendant City of New Haven's Statement of Additional Facts Not in

Case 3:03-cv-00943-AWT

Document 119

Filed 06/07/2007

Page 2 of 3

Dispute, a memorandum of Law and numerous exhibits including several prior Court decisions and prior sworn testimony of the individual defendants. THE PLAINTIFF GARY SESSION

By____________________________ Roy S. Ward, Esq. 3695 Post Road, Suite 203 Southport, CT 06890 Tel: (203) 255-9829 Fax: (203) 255-9839 Fed. Bar No. CT 11618

CERTIFICATION I hereby certify that on June5, 2007 a copy of the foregoing was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the Court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing through the Court's CM/ECF System.

________________________ /Roy S. Ward/

Case 3:03-cv-00943-AWT

Document 119

Filed 06/07/2007

Page 3 of 3