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

Case 3:03-cv-01009-SRU

Document 80

Filed 03/07/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOSEPH ATTIAS & HAIM ATTIAS VS. PATRONS MUTUAL INSURANCE COMPANY OF CONNECTICUT : : : : : : CIVIL ACTION NO. 3:03 CV 01009 (SRU) MARCH 3, 2005

DEFENDANT'S MOTION TO AMEND ITS LOCAL RULE 56(a)1 STATEMENT The defendant, Patrons Mutual Insurance Company, filed a Local Rule 56(a)1 Statement with its Motion for Summary Judgment, dated December 14, 2004. The defendant now submits a motion to amend statements numbered 8 and 10 to comply with Local Rule 3, requiring citation to "the affidavit of a witness competent to testify as to the facts at trial." The affidavit of Scott Terra was attached as Exhibit E in the defendant's motion, dated December 14, 2004, but the statements numbered 8 and 10 did not cite to the affidavit. The defendant's statements, and amendments to the statements, indicated in bold, are as follows: 8. The adjustment of said loss was assigned to Scott Terra, a property loss

adjuster for Patrons Mutual Insurance Company. (See Affidavit of Scott Terra, attached hereto as Exhibit E). 10. To date, said property has been neither repaired nor replaced by the insureds.

(See Affidavit of Scott Terra, attached hereto as Exhibit E).

Case 3:03-cv-01009-SRU

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Filed 03/07/2005

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DEFENDANT, PATRONS MUTUAL INSURANCE COMPANY

By

\S\ Heather J. Adams-Beman Skelley Rottner P.C. P.O. Box 340890 Hartford, CT 06134-0890 Tel. (860) 561-7077 Fax (860) 561-7088 Federal Bar No. ct24091

SR/229564/tao 7373-03002

Case 3:03-cv-01009-SRU

Document 80

Filed 03/07/2005

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CERTIFICATION I hereby certify that a copy of the above was mailed via U.S. Mail, postage prepaid, on March 3, 2005, to the following counsel of record: Attorney Cheryl E. Heffernan Farver & Heffernan 2842 Old Dixwell Avenue Hamden, CT 06518 Tel. (203) 288-8266

\S\ Heather J. Adams-Beman
SR/229564/tao 7373-03002