Free Motion for Summary Judgment - District Court of Connecticut - Connecticut

Case 3:03-cv-00987-CFD

Document 19-3

Filed 05/21/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT JOSEPH INTURRI, ET AL. Plaintiffs vs. : CIVIL ACTION NO. 3:03CV987 (CFD)

:

CITY OF HARTFORD, CONNECTICUT; and BRUCE P. MARQUIS, Defendants :

MAY 21, 2004

PLAINTIFFS RULE 56(e) STATEMENT OF FACTS Pursuant to §56(e) of the Federal Rules of Civil Procedure, the parties herein have agreed and stipulated that there are no material facts in dispute. The Stipulated Facts are attached hereto. Plaintiffs also attach five affidavits, one for each plaintiff, swearing to the fairness and accuracy of the depiction of their respective tattoo in each photograph attached thereto as an Exhibit. The affidavits are attached as follows: 1. Affidavit of plaintiff Joseph Inturri; referencing Exhibit A (photograph); 2. Affidavit of plaintiff Stephen Miele; referencing Exhibit B (photograph); 3. Affidavit of plaintiff Matthew Rooney; referencing Exhibit C (photograph); 4. Affidavit of plaintiff Darren Besse; referencing Exhibit D (photograph); and 5. Affidavit of plaintiff Mark Castagna; referencing Exhibit E (photograph).

WHEREFORE, the foregoing is submitted by plaintiffs in support of their Motion for Summary Judgement, filed the date of this statement.

Case 3:03-cv-00987-CFD

Document 19-3

Filed 05/21/2004

Page 2 of 2

THE PLAINTIFFS, BY JON L. SCHOENHORN Federal Bar No. ct00119 Jon L. Schoenhorn & Associates 97 Oak Street Hartford, CT 06106 Tel: (860) 278-3500 Fax: (860) 278-6393

CERTIFICATION I hereby certify that a copy of the foregoing was mailed, via first class mail, on the date of this pleading to: Helen Apostolidis, Esq. City of Hartford Corporation Counsel 550 Main Street Hartford, CT 06103 Fed. Bar No. ct05534 Tel. No. (860) 543-8575 Fax No. (860) 722-8114 ___________________________ Jon L. Schoenhorn