Free Motion for Summary Judgment - District Court of Connecticut - Connecticut

Case 3:02-cv-02105-RNC

Document 61

Filed 06/30/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

CLEAN WASTE, INC., Plaintiff, v. FIRST NATIONS FIN. SERVS., INC. ET AL Defendants. CASE NO. 3:02CV2105 (RNC)

DEFENDANT FIRST NATIONS FINANCIAL SERVICES, INC. MOTION FOR SUMMARY JUDGEMENT

Defendant First Nations Financial Services, Inc. (Hereinafter "First Nations") hereby moves for Summary Judgement as to all counts plead against as follows: 1. That the applicable Statute of Limitations bars any action for negligence against First Nations pursuant to Connecticut General Statutes 52-584 in that the acts complained of occurred in October 1999 and the complaint was filed on November 27, 2002 after the two year Statute of Limitations had expired; 2. That the applicable Statute of Limitations bars any actions for any torts against First Nations pursuant to Connecticut General Statutes 52-577 in that the acts complained of occurred in October 1999 and the complaint was filed on November 27, 2002 after the three year Statute of Limitations had expired; and 3. The Policy for which that complaint sought coverage was not in force until October 2000 and the renewal did not involve this defendant.

Case 3:02-cv-02105-RNC

Document 61

Filed 06/30/2007

Page 2 of 2

As set forth in the accompanying filings, the action against First Nations is time barred and First Nations was not involved in obtaining coverage for the Plaintiff in October 2000, the effective date of the policy for which the claim is made here. Therefore, it is requested that Judgement enter in favor of the Defendant against the Plaintiff for all claims asserted against the Defendant.

DEFENDANT BY:__________/s/_____________ Frank J. Liberty ct14089 The Liberty Law Firm, LLC 105 Huntington Street New London, CT 06320 860-437-7722

CERTIFICATION I hereby certify that on June 30 , 2007, a copy of the following Motion and Memorandum of Law , Affidavit of Frank J. Liberty and Local Rule Statement regarding Defendant's Summary Judgement was filed electronically and served by mail upon anyone unable to accept electronic filing. Notice of this filing will be sent to all parties by operation of the Court's electronic filing as indicated on the Notice of Electronic filing. The parties may access this filing through the Court's CM/ECF System.

___/s/___________ Frank J. Liberty