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

Case 3:03-cv-00149-WIG

Document 148

Filed 04/25/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT FERRON SHORTER JR., Plaintiff, v. HARTFORD FINANCIAL SERVICES GROUP, INC., Defendant. : : : : : : : : : :

CASE NO. 3:03-cv-149(WIG)

APRIL 25, 2005

PLAINTIFF'S MOTION TO AMEND/CORRECT AFFIDAVITS IN SUPPORT OF MOTION FOR ATTORNEY'S FEES AND COSTS (doc. ##127, 147) Plaintiff Ferron Shorter Jr., by and through his undersigned counsel, hereby moves to amend/correct his (a) Affidavit of Rachel M. Baird filed on February 22, 2005, as Exhibit 1 to Plaintiff's Memorandum of Law in Support of Attorney's Fees and Costs (doc. #127) and (b) Second Affidavit of Rachel M. Baird filed on April 22, 2005, as Exhibit 2 to Plaintiff's Brief in Reply to Defendant's Memorandum of Law in Opposition to Plaintiff's Motion for Attorney's Fees and Costs (doc. #147). A Corrected Affidavit of Rachel M. Baird is attached hereto as Exhibit 1 to amend/correct the previously filed Exhibit 1 to Docket Entry No. 127. A Corrected Affidavit of Rachel M. Baird is attached hereto as Exhibit 2 to amend/correct the previously filed Exhibit 2 to Docket Entry No. 147. In support, as cause for the amendment/corrections, Plaintiff offers: 1. The Affidavit of Rachel M. Baird filed on February 22, 2005, as Exhibit 1 to

Docket Entry No. 127 is missing page three, as filed. The Corrected Affidavit of Rachel M. Baird attached as Exhibit 1 to the instant motion contains page three and is complete.

Case 3:03-cv-00149-WIG

Document 148

Filed 04/25/2005

Page 2 of 3

2.

The Second Affidavit of Rachel M. Baird filed on April 22, 2005, as Exhibit 2 to

Docket Entry No. 147 is dated February 22, 2005, instead of April 22, 2005, on its page 2. The Corrected Affidavit of Rachel M. Baird attached as Exhibit 2 to the instant motion is dated April 25, 2005, on its second page consistent with the date the Oath was administered. For the foregoing reasons, Plaintiff respectfully requests the amendments/corrections as described in the instant motion.

PLAINTIFF FERRON SHORTER JR.

BY:

________________________ Rachel M. Baird (ct12131) Law Office of Rachel M. Baird 379 Prospect St Torrington CT 06790-5239 Tel: (860) 626-9991 Fax: (860) 626-9992

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Case 3:03-cv-00149-WIG

Document 148

Filed 04/25/2005

Page 3 of 3

CERTIFICATION I HEREBY CERTIFY that a copy of the foregoing Plaintiff's Motion to Amend/Correct Affidavits in Support of Attorney's Fees and Costs (doc. ##127, 147), with its Exhibits 1 and 2 containing the Corrected Affidavit of Rachel M. Baird and the Corrected Second Affidavit of Rachel M. Baird, respectively, was mailed first-class, postage paid to the following counsel of record on April 25, 2005. Plaintiff further represents that the missing page 3 of the Affidavit filed on February 22, 2005, as Exhibit 1 to Docket Entry 127 was provided by facsimile to the following counsel on March 17, 2005: Margaret J. Strange James F. Shea Jackson Lewis LLP 55 Farmington Ave Ste 1200 Hartford CT 06105

______________________________ Rachel M. Baird

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