Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

Case 3:01-cv-02205-PCD

Document 48

Filed 03/02/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

LYNN BALDONI; Plaintiff VS. THE CITY OF MIDDLETOWN; J. EDWARD BRYMER; DOMENIQUE S. THORNTON; Defendants

: : : : : : : : :

CIVIL ACTION NO. 3:01CV2205 (PCD)

MARCH 2, 2004

MEMORANDUM IN SUPPORT OF MOTION FOR RECONSIDERATION Pursuant to D.Conn.L.Civ.R. 7(c), the Defendants have moved this Court to reconsider its Ruling on Plaintiff's Motion for Leave to Amend Complaint dated February 26, 2004. That ruling granted the Plaintiff's motion, allowing her to amend her Complaint. However, the ruling was issued before the Defendants had an opportunity to file an objection, which has since been filed, on March 1, 2004. For the reasons stated in the Objection to Plaintiff's Motion for Leave to Amend Complaint attached hereto as Exhibit A, the Court should reconsider its ruling, and overrule the Plaintiff's Motion. The Defendants' objection was timely filed under the Local Rules. Plaintiff filed her Motion on February 19, 2003. Under Local Rule 7(a)(1), parties are allowed twentyone (21) days after a motion is filed in which to file a memorandum in opposition. In the present case, the Court decided the Plaintiff's Motion well before twenty-one days had

One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105

Case 3:01-cv-02205-PCD

Document 48

Filed 03/02/2004

Page 2 of 2

elapsed. As such, the Court should reconsider its decision, taking into account the persuasive arguments contained in the attached Objection.

THE DEFENDANTS CITY OF MIDDLETOWN J. EDWARD BRYMER DOMENIQUE THORNTON

By James M. Sconzo of Fed. Bar # ct04571 HALLORAN & SAGE LLP One Goodwin Square 225 Asylum Street Hartford, CT 06103

CERTIFICATION This is to certify that on this 2nd day of March, 2004, a copy of the foregoing was mailed, postage prepaid, to: James S. Brewer, Esq. Attorney Erin O'Neil 818 Farmington Avenue West Hartford, CT 06119 Trina Solecki, Esq. City Attorney P.O. Box 1300 Middletown, CT 06457 ________________________ James M. Sconzo
521773.1(HSFP)

-2­
One Goodwin Square 225 Asylum Street Hartford, CT 06103

HALLORAN & SAGE LLP

Phone (860) 522-6103 Fax (860) 548-0006 Juris No. 26105