UNITED STATES DISTRICT COURT I I 1 ii I i
DISTRICT OF CONNECTICUT ZW! 2n D I: U C]
HENDERSON ii 1 ·. ` [YQ
303CV665 (MRK) . _$]`
VS.
GREENWICH
MOTION FOR SANCTIONS
` “ LOCAL RULEI I "
A. Violation subdivision (b)
l.The defendant may not deny allegations in the complaint on the basis of
lack of information and belief if the infomation is within the actual knowledge
of the defendant. Because the denial of summary judgement was to matters
which would be within the actual knowledge of the Town of Greenwich (D),
the denial raises no issue and is, in effect, an admission ofthe truth of the
allegations in the complaint.
2.The issues litigated in doctrine 3:02CR29SRU are final and binding upon
all subsequent litigation between the parties regarding that issue.
B. Sanctions ‘
1. I request one hundred thousand dollars in legal fees as a direct result of
the violation of subdivision (B).
’Y.»ratu»
Case 3:03-cv-00665-IVIRK Document 72 Filed 12/20/2006 Page 2 of 2
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CERTIFICATION
This is to certify that a copy of the foregoing has been mailed on the above—captioned
date
to all counsel and pro se parties of record:
Valerie E. Maze, Esq.
Attorneys for Defendant
TOWN OF GREENWICH
Town Hall, P.O. Box2540
Greenwich, CT 06836-2540
Terence Henderson, Pro se
5360 Broadway #7c
Bronx, NY 10463