Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:03-cv-00432-JCH

Document 69

Filed 07/17/2006

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

CHASE CROSSROADS WATERFORD SQUARE, LLC, Plaintiff, V. THE MAY DEPARTMENT STORES COMPANY, Defendant.

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CIVIL ACTION NO. 3:03CV00432 (JCH)

JULY 14, 2006

PLAINTIFF'S MOTION FOR PERMISSION TO AMEND PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW The plaintiff in the above­entitled matter hereby moves the Court to allow the plaintiff to amend its Proposed Findings of Fact and Conclusions of Law (dated June 23, 2006). Specifically, the plaintiff requests permission to file the accompanying Amended Proposed Findings of Fact and Amended Conclusions of Law, which add Paragraph 41 to the plaintiff's proposed findings of fact and a corresponding Paragraph 8 to the plaintiff's proposed conclusions of law. Both amendments pertain to a matter that was Both

inadvertently overlooked when the original document was prepared.

amendments are based on the express language of the operative guarantee

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Case 3:03-cv-00432-JCH

Document 69

Filed 07/17/2006

Page 2 of 2

agreement and consequently present no issue of unfair surprise or undue prejudice to the defendant. PLAINTIFF, CHASE CROSSROADS WATERFORD SQUARE, LLC

By___________________________________ Richard P. Weinstein, Esquire of WEINSTEIN & WISSER, P.C. 29 South Main Street, Suite 207 West Hartford, CT 06107 Telephone No. (860) 561-2628 Facsimile No. (860) 521-6150 Federal Bar No. ct06215

CERTIFICATION This is to certify that on the 14th day of July, 2006, a copy of the foregoing was served upon: Jeffrey J. Tinley, Esquire Tinley, Nastri, Renehan & Dost, LLP 60 North Main Street, 2nd Floor Waterbury, CT 06702-1403

_____________________________________ Richard P. Weinstein

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