Free Motion to Amend/Correct - District Court of Connecticut - Connecticut

Case 3:03-cv-OO(i4§WWE Document 12 Filed 11 @20% 5 §ja§e7#g¤§ ammo
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UNITED STATES DISTRICT COURF
DISTRICT OF CONNECTICUT .e4_
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RICHARD _ SCPHRILLO, AUGUSTO CIVIL ACTION NO_.__3_: 0r3,C‘}Z§Qjl·(WW E)
CORREIA and RANDOLPH BoND, U5 saga 1 t;l_Q_J{,}..,Â¥{ jg
Plaintiffs, ` Eli? `GIJ ` \ A
vs. November 3, 2003
TOWN OF STRATF ORD, and in their `
individual and official capacities EILEEN -
MURPHY, MICHAEL FEENEY,
DORINDA BORER, MARK BARNPLART,
JACK OBERNESSOR, MICHAEL SINGH,
and SANDRA ZALIK
Defendants.
MOTION TO ADD PLAINTIFF AND AMEND COMPLAINT
Plaintiffs, Richard Schirillo, Augusto Correia, and Randolph Bond, by their
attorney, move the court pursuant to Fed. R. Civ. P. l5(a) and 20 for an order permitting
Plaintiffs to add an additional plaintiff to the above- captioned case and amend the
complaint accordingly.
Plaintiffs seek to add Ronald Brenton (hereinafter "Brenton") as a plaintiff and
amend the complaint to include Brenton as an additional plaintiff and his causes of
action. Brenton’s claims against Defendants share common questions of fact and law as
Plaintiffs’ claims against Defendants. Brenton, as well as Plaintiffs, were all employees
NO ORAL ARGUNIENT REQUESTED

Y . Case 3:03-cv-OO@l5WWE Document 12 Filed 1]Z@2003 Page 2 of .4
of the Town of Stratford’s water treatment plant and subject to collective bargaining
agreements that vested them with a legally cognizable property interest in the same heart
and hypertension benefits mandated for Municipal Fire and Police Personnel under
C.G.S. §7-433(cz). Brenton’s, as well as Plaintiffs’, causes of actions allege Defendants’
failure to provide a fomm or process by which they could pursue their heart and
hypertension benefits, in addition to, Defendants’ failure to provide any notice or
information reasonably calculated to apprise them of the process by which they could
obtain said benefits.
Additionally, the following teclmical amendments to the Complaint were made:
(1) paragraph 32 of the First Amended Complaint reflects the changes made to paragraph
31 removing "Schirillo" and replacing it with "plaintiff’ s"; (2) paragraph 61 of the First
Amended Complaint reflects the changes made to paragraph 60 removing C.G.S. § 31- U
294c(a) and replacing it with C.G.S. § 294c(b); (3) paragraph 67 of the First Amended
Complaint reflects changes made to paragraph 66 removing “plaintiff Shirillo" and ;
replacing it with "p1aintiff”; and (4) the paragraphs of the First Amended Complaint have
been re-numbered in accordance with the aforementioned changes.
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1 ‘ Case 3:03-cv-OOQEEWWE Document 12 Filed 1U0®2003 Page 3 of 4
This is P1aintiffs’ first request to amend their complaint. A copy of the proposed
First Amended Complaint is attached hereto as Exhibit “A".
Respectfhlly Submitted,
THE PLAINTIFFS
RIC · M':. '· "é A , AUGUSTO
CO W PH BOND
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Byi s-»· (
Jame ¤· 1 win, Esq. ct/08535
COL ALDWIN & CRAFT, LLC.
1261 Post Road, P.O. Box 577
Fairfield, CT 06824
Telephone: (203) 319-0800
Facsimile: (203) 319-1210
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{ I Case 3:03-cv-OOQ4§NWE Document 12 Filed 1167252003 Page 4 of 4
CERTIFICATION
I hereby certify that a copy of the foregoing was mailed this 3"1 day of November
2003 to the following counsel of record:
Warren Holcomb, Esq.
BERCHEM, MOSES & DEVLIN, P.C.
75 Broad Street
Milford, CT 06460
Telephone: (203) 783-1200
Facsimile: (203) 882-0045
Richard J. Buturla, Esq.
BERCI-[EM, MOSES & DEVLIN, P.C.
75 Broad Street
Milford, CT 06460
Telephone: (203) 783-1200
Facsimile: (203) 882-0045
‘ S. Dave Vatti, Esq.
LAW OFFICES OF S.DAVID VATTI, LLC,
375 Bridgeport Avenue, 3rd Floor
Shelton, CT 06484-3961
Telephone: (203) 944-9392
Facsimile: (203) 944-6012 ' ‘
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