UNITED STATES DISTRICT COURT F I L E
DISTRICT OF CONNECTICUT
ROBERT L. Bnoc1
Plaintiff ; 3:03CV00609( . iU)--' * i
V. . i =
YALE UNIVERSITY; JEROME N. FRANK l
LEGAL SERVICES ORGANIZATION OF
YALE LAW SCHOOL; RICHARD C. LEVIN, :
President ofthe University, Official Capacity;
I ROBERT A. SOLOMON, Director of JEROME N. :
FRANK LEGAL SERVICES ORGANIZATION
OF YALE LAW SCHOOL, I/O; ANTHONY T. : l
KRONMAN, Dean of Yale Law School, I/O; i
CARROLL LEE LUCHT,_Law Professor, : .
and Attorney at Law, I/O; STEPHEN WIZNER,
Law Professor, and Attorney at Law, I/O. :
Defendant(s) OCTOBER 29, 2003 j
PLAINTIFFS ADDITIONAL MEMORANDUM
OF LAWS REGARDING l)EFENDANTS’ MOTION TO DISMISS l
Plaintiff respectfully submits this additional Memorandum of Laws
regarding Defendants’ Motion to Dismiss dated October 10, 2003.
On page 3 lines 13 and 15 of Plaintiff s Answer to Defendants’ Motion
to Dismiss dated October 17, 2003 the plaintiff asserts that "These defendants were
indeed licensed Attorneys at Law with special privileges to practice in federal Courts of
Law. They were indeed officers of the federal and state Courts, and certainly acted under
the color of state, and federal law. Similarly these very same defendants acting as federal
officers, set up a pattern of discrimination violating the plaintiff s civil, and
Constitutional rights to a fair trial."
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g ._ · Case 3:03-cv-OO60?=Sj%U Document 45 Filed 10/3{/25>O3 Page 2 of 3 r
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The plaintiffs assertion that, the defendants acted under color ofthe
state, is substantiated by the following Connecticut General Statute:
Sec.5l-85. Authority and powers of commissioners of the Superior Court. Each attorney-
at—law admitted to practice within the state, while in good standing, shall be a
commissioner ofthe Superior Court and, in such capacity, may, within the state, sign R
writs and subpoenas, take recognizances, administer oaths and take depositions and ,
acknowledgments of deeds. Each such attorney may also issue subpoenas to compel the
I attendance of witnesses and subpoenas duces tocum in administrative proceedings ....
The signing of a writ by a lawyer as a commissioner ofthe superior court is not a mere
ministerial act." (142 C.411. Cited 162 C. 255).
RESPECTFULLY SUBMITTED, I
Robert L. grockway, Jr. i
28 Boston Terrace i
Guilford, Connecticut 06437
(203) 214-0202
i
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. · Case 3:03-cv-0O60§€`SjQU Document 45 Filed 10/3g42003 Page 3 of 3 ’
BROCKWAY V. YALE UNIVERSITY, ET AL
USDC, BRIDGEPORT CIVIL ACTION NO.3 :O3CV00609 (SRU)
CERTIFICATION
This is to certify that the foregoing PLAIN`T1FF’S ADDITIONAL p
MEMORANDUM OF LAWS REGARDING DEFENDANTS’ MOTION TO DISMISS ¤
has been mailed postage prepaid on October 29, 2003 to the law office of PATRICK M.
NOONAN and BROCK T. DUB1N0fDELANEY, ZEMETIS, DONAHUE, DURHAM
I & NOONAN, PC., Concept Park·~Suite 306, 741 Boston Post Road, Guilford, CT
06437. I
,A,%1/$9.. · · .
Ro ert L. Brock ay, Ir.
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