Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

Case 3:00-cv-01011-JCH

Document 88

Filed 03/31/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

DANTE DELORETO Plaintiff v. SEBASTIAN SPADA and GARY CHUTE Defendants

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Case No. 3:00cv1011 (JCH)

March 30, 2004

DEFENDANTS REPLY TO PLAINTIFF S MEMORANDUM OF LAW MOTION, AFFIDAVIT, RESPONSE, SUMMARY JUDGMENT ETC. On February 5, 2004, the Defendants filed a Motion For Summary Judgment (Dkt. No. 59). On March 11, 2004, the

Honorable Janet C. Hall filed a Notice to Pro Se Litigant (Dkt. No. 71). In the document, the Honorable Janet C. Hall informed the pro se plaintiff the following: . . . the plaintiff must demonstrate to the court that material issues of fact exist such that granting summary judgment would not be appropriate. The plaintiff may not rely on conclusory allegations, from either his complaint or his motions. DeLoreto must present evidence to the court in the form of affidavits, deposition testimony, or records that substantiate his claim that the defendants unlawfully seized the plaintiff.

Case 3:00-cv-01011-JCH

Document 88

Filed 03/31/2004

Page 2 of 3

On or about March 18, 2004, plaintiff filed a memorandum of law, motion; affidavit, response, summary judgement, sworn affidavit; case criminal nolled. The plaintiff s memorandum in opposition of defendants motion for summary judgment relies on He did not present evidence to

conclusionary allegations.

the court in the form of affidavits, deposition testimony or records that substantiate his claim that the defendants unlawfully seized the plaintiff. There was no evidence presented which would allow a jury to find in his favor. Therefore, the defendants respectfully request that their motion for summary judgment be granted in their favor. DEFENDANTS By Office of Corporation Counsel

__________________________________ Irena J. Urbaniak Attorney for Defendants Office of the Corporation Counsel City of New Britain 27 West Main Street New Britain, Connecticut 06051 Tel. (860) 826-3420 Federal Bar Number ct01322 -2-

Case 3:00-cv-01011-JCH

Document 88

Filed 03/31/2004

Page 3 of 3

CERTIFICATION I hereby certify that on March 30, 2004, a copy of the above was mailed to the pro se plaintiff: Dante DeLoreto 33 Maxwell Drive Wethersfield, Connecticut 06109

__________________________________ Irena J. Urbaniak Attorney at Law

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