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

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Case 3:O2—cv-O1950;PCD Document 22 Filed 1 1/10/2003 Page 1 of 2 `
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IN THE UNITED STATES DISTRICT COURT i
FOR THE DISTRICT OF CONNECTICI1IEmad States District 001:3 i
District of Gcrmccticur.
FILE?) AT NEW HAVEN
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STEPHEN F. GRAY, ASSIGNEE, ···········U· ·"i,g········éT·di;r·i···2°O 3 .
WILLIAM DUBINSKY & SONS, INC. : rp Cl I
d/b/a DUBINSKY, MUSTO & PARMALEE, _ RLY--4-5-3§é· j
Piamarr `
2 Civil No. 302C\/01950 PCD !
v.
CITY FRUIT & PRODUCE CO., LLC., I
et al., :
Defendants. :
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PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT
COMES NOW plaintiff, Stephen F. Gray, Assignee, William Dubinsky & Sons,
Inc. d/b/a Dubinsky, Musto & Parmalee, by and through counsel, and pursuant to Rule 56
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of the Federal Rules of Civil Procedure and Local Rule 9, moves for the entry of l
summary judgment against defendants, City Fruit & Produce Co., LLC, and John
Falcone, on the grounds that there is no genuine dispute as to any material fact and
plaintiff is entitled to judgment as a matter of law. In support thereof, plaintiff
respectfully refers the Court to the Local Rule 9 (c) (1) Statement, the Affidavit of i
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Stephen F. Gray attached thereto as Exhibit A, and the Memorandum of Law filed i
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herewith.
WHEREFORE, Plaintiff respectfully requests that its Motion for Summary
Judgment be granted and that judgment be entered in favor of plaintiff and against
defendants, City Fruit & Produce Co., LLC, and John Falcone, jointly and severally, in
the amount of $36,137.18.
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i Case 3:02-cv-O19PO‘=PCD Document 22 Filed 11/40%,2003 Page 2 of 2
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X Respectfully submitted, J
I BERDON, YOUNG & M I
( Stu A. Margolis, #CT08803 Q
Peter A. Berdon, #CT09573 y
132 Temple Street (
New Haven, CT 06510
(203) 772- 3740

and K
McCARRON & D I
Mary Je ssett, #CT 10925
4910 as Ave., NW #18 f
Washington, D.C. 20016
(202) 364-0400
Counsel for Plaintiff i
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of Plaintiffs Motion for Summary Judgment, `
Statement of Material Facts as to Which There is No Genuine Dispute, Memorandum of
Law an proposed Order, were mailed, postage prepaid, this L9 day of
»&La~ Paul . Gentile, Esq., Gentile & Dickler, 15 Maiden Lane, New York, NY 10038. ,
Stuart A. Margolis, sq.
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