Free Response - District Court of Connecticut - Connecticut

Case 3:03-cv-01010-JBA Document 110 Filed O4/11/2005 Page 1 of 3
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
CECIL YOUNG :
: CIV. NO. 3:03CV1010 (JBA)
Plaintiff :
vs. r Z
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CITY OF BRIDGEPORT HOUSING :
AUTHORITY, ET AL :
Defendants APRIL 8, 2005 I
OBJECTION TO MOTION FOR PERMISSION TO AMEND JOINT TRIAL
MEMORANDUM TO ADD AN ADDITIONAL TRIAL EXHIBIT i
The Plaintiff, Cecil Young, in the above captioned matter, hereby respectfully
submits the instant objection to the Defendants, Bridgeport Housing Authority and Colin
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Vice's Motion for Permission to Amend Joint Trial Memorandum to Add an Additional I
Trial Exhibit dated April 1, 2005. The Plaintiff objects on the grounds that the proposed I
additional exhibits are immaterial, irrelevant, hearsay, and self-sewing. The Plaintiff
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does not waive objection based on lack of foundation. (Federal Rule of Evidence 401- |
407; Federal Rule of Evidence 801-802; Federal Rule of Evidence 901.) In addition, the
Plaintiff objects to the proposed additional exhibits pursuant to Paragraph 8(b) of the
Joint Trial Memorandum Instructions, which states in pertinent part: "Exhibits not listed,
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_ Case 3:03-cv-0610-JBA Document 110 Filed {0451 1/2005 Page 2 of 3
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except those used solely in rebuttal or for impeachment, will not be admissible at trial,
except for good cause shown." The Defendants, in their Motion for Permission to
Amend Joint Trial Memorandum to Add an Additional Trial Exhibit, have failed to show
good cause as to why their proposed additional exhibits should be allowed to be added
. to the Joint Trial Memorandum.
For the foregoing reasons the Plaintiff hereby respectfully requests this Court to {
deny the Defendants’ Motion for Permission to Amend Joint Trial Memorandum to Add ,
an Additional Trial Exhibit and sustain the instant objection.
THE PLAINTIPE . l
BY: Y" , 1
DA & B%CHANlS
11.15 Main Stre t, Suite 710 l
Bridgeport, CT 06604
Tel. No. 203-333-8500 \
Juris N0. 08235 _
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Case 3:03-cv-0 10-JBA Document 110 Filed 051/1 1/2005 Page 3 of 3 I
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CERTIFICATION j
This is to certify that copies of the foregoing have been mailed on this the S"' day
of April, 2005 to:
Barbara Brazzel-I\/lassaro I
Associate City Attorney . i
Office of the City Attorney I
999 Broad Street I
Bridgeport, CT 06604
Michael T. Ryan, Esq.
James It/lahar, Esq.
Ryan, Ryan, Johnson & Deluca, LLP
80 Fourth Street I
Stamford, CT 06905 J N
BY: l {J `_Y_
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