Free Motion for Judgment - District Court of Connecticut - Connecticut

“ Case 3:03-cv-01010-JBA Document 81 Filed O3/O2/2005 Page 1 of 3 I
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UNITED STATES DISTRICT COURT NEW Elmxmlis Cf
DISTRICT OF CONNECTICUT
CECIL YOUNG :
Plaintiff, CIV. NO. 3:03CV1010 (JBA) ,
vs.
CITY OF BRIDGEPORT HOUSING
AUTHORITY, ET AL :
Defendants MARCH 2, 2005
MOTION FOR JUDGMENT PURSUANT TO RULE 50(a)j2) ,
The Defendant, City of Bridgeport, respectfully requests that the Court grant
judgment in its favor prior to the submission of this case to the jury. I
The Defendant, City of Bridgeport, contends that it is entitled to judgment i
because: i
1. The Plaintiff has no evidence that the Defendant, City of Bridgeport, {
terminated his employment as a result of his exercise of the First Amendment, and [
2. The speech, which the Defendant contends was a matter of public concern,
was a personal matter and not public concern. J
3. The Defendant, City of Bridgeport, has no evidence of a causal connection
that the termination was for any substantial reason other than financial restraints.
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_ é Case 3:03-cv-O1OfM)5JBA Document 81 Filed O3/82¢?OO5 Page 2 of 3 [
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Therefore, the Defendant, City of Bridgeport, requests that the Court enter
judgment in its favor. A memorandum and affidavit in support of the motion are
attached hereto.
me DEFENDANT
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By:
Barbara Brazzel-Nlassaro
Associate City Attorney
orsics or THE cirv Artorzrviav
999 Broad Street- 2"°' Floor
Bridgeport, CT 06604 ,
Telephone #203/576-7647 l
Fed. Bar No. 05746 Q
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_ r Case 3:03-cv-O1?-OjJBA Document 81 Filed O3/{32/$005 Page 3 of 3 {
CERTIFICATION
This is to certify that a copy of the foregoing "|\/lotion for Judgment Pursuant to
Rule 50(a)(2)" has been hand delivered on this 2"d day of March, 2005, to:
Thomas J. Weihing, Esq. E
Daly, Weihing & Bochanis
1115 Main Street, Suite 710
Bridgeport, CT 06604
Michael T. Ryan, Esq.IJames Mahar, Esq.
Ryan, Ryan, Johnson & Deluca, LLP
80 Fourth Street
Stamford, CT 06905
Magistrate Judge Joan G. Margolis
United States District Court
141 Church Street
New Haven, CT 06510
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Barbara Brazzel-Massaro I
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