Free Statement of Material Facts - District Court of Connecticut - Connecticut

Case 3:03-cv-00069-CFD

Document 35

Filed 08/19/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT KEITH JOHNSON, Plaintiff, v. JAMES KEENEY, Defendant. : : : : : : : NO. 3:03CV-0069 (CFD)(WIG)

AUGUST 18, 2004

DEFENDANT'S LOCAL RULE 56(A)(2) STATEMENT Pursuant to Local Rule 65(a)(2), the defendant hereby files the following response to the plaintiff's Local Rule 56(as)(1) Statement: 1. Denied. See Statement of Diane Johnson attached to Trooper Keeney's Affidavit attached to the defendant's Motion for Summary Judgment dated April 26, 2004. 2. Denied. See Statement of Diane Johnson attached to Trooper Keeney's Affidavit attached to the defendant's Motion for Summary Judgment dated April 26, 2004. 3. Admitted. 4. Admitted. 5. Admitted except for that portion which alleges that Keith Johnson "explained to the Vernon police officer the agreement he had with Diane Johnson for the purchase of the vehicle." As to that portion of paragraph 5, the defendant has no knowledge or information with which to either admit or deny the plaintiff's statement. 6. Admitted. 7. Admitted. 8. Denied. See Trooper Keeney's Affidavit attached to the defendant's Motion for

Case 3:03-cv-00069-CFD

Document 35

Filed 08/19/2004

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Summary Judgment dated April 26, 2004. 9. Admitted. 10. Admitted. 11. Admitted. 12. Admitted. 13. Admitted except as to the contents of conversations between Keith Johnson and his attorney. As to the contents of these conversations, the defendant has no knowledge. 14. Admitted. 15. Admitted.

Disputed Issues of Material Fact For the reasons outlined in the defendant's Motion for Summary Judgment and the accompanying Memorandum of Law dated April 26, 2004, the defendant submits that there are no disputed issues of material fact in this case.

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Case 3:03-cv-00069-CFD

Document 35

Filed 08/19/2004

Page 3 of 3

DEFENDANT James Keeney RICHARD BLUMENTHAL ATTORNEY GENERAL By: __/s/_____________________ Stephen R. Sarnoski Assistant Attorney General MacKenzie Hall 110 Sherman Street Hartford, Connecticut 06105 Tel. (860) 808-5450 Federal bar #ct05129 E-mail: [email protected]

CERTIFICATION This is to certify that a copy of the foregoing Motion was mailed, first-class, postage pre-paid, to all pro se parties and/or counsel of record on this the ________ day of _________________, ______.

Keith Johnson #272700 MacDougall Correctional Institution 1153 East Street South Suffield, Connecticut 06080

__/s/_________________________ Stephen R. Sarnoski Assistant Attorney General

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