Free Reply to Response to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00208-WWE

Document 33

Filed 05/11/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PRISONER ROBERT REID : CIVIL ACTION NO. 3:03CV208 (JCH) Plaintiff : : v. : : JOHN ARMSTRONG, ET AL., : Defendant : MAY 9, 2005

DEFENDANTS' OBJECTION TO PLAINTIFF'S MOTION FOR RECONSIDERATION The defendants hereby object to the plaintiff's April 15, 2005 motion for reconsideration of the court's ruling on cross-motions for summary judgment. In support of this objection, the defendants note that the plaintiff has merely restated unavailing arguments previously asserted in his own motion for summary judgment. Plaintiff's persistence in challenging his inmate classification here in Connecticut ignores clearly established law, and perhaps more importantly, disregards his own record of significantly violent behavior while in custody and while at liberty. Conceding, as he does, on the first page of his motion for reconsideration "that the Constitution creates no right to receive parole nor does it entitle any inmate to a particular institutional classification," it is submitted that the plaintiff's motion is frivolous. Wherefore, for the foregoing reasons, the plaintiff's motion for reconsideration should be denied.

Case 3:03-cv-00208-WWE

Document 33

Filed 05/11/2005

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RICHARD BLUMENTHAL ATTORNEY GENERAL

BY:

_____/s/____________________________ Terrence M. O'Neill Assistant Attorney General Federal Bar No. 10835 110 Sherman Street Hartford, CT 06105 Tel: (860) 808-5450 Fax: (860) 808-5591 Email:[email protected]

Case 3:03-cv-00208-WWE

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Filed 05/11/2005

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CERTIFICATION

I hereby certify that a copy of the foregoing was mailed in accordance with Rule 5(b) of the Federal Rules of Civil Procedure on this 9th day of May, 2005, first class postage prepaid to: Robert Reid, No. 262849 Corrigan CI 986 Norwich-New London Tpke. Uncasville, CT 06382

_______/s/___________________________ Terrence M. O'Neill Assistant Attorney General