Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

1 1TC_ase 3:03-cv—009 CH Document 15 Filed 11/2 003 Page 1 of 2 .
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1 UNITED STATES DISTRICT COURT U3 1111311 ig _1·_
1 DISTRICT OF CONNE(‘_)T|CUT 1 —"e?1 111*11-T?l*T H g__ `,_;
1 EDWARD ROOT : 1
VS. : NO. 3:03CV949(JCH)
1 TIMOTHY LISTON : NOVEMBER 20, ,..1.1
I PLA|NTIFF’S MEMORANDUM IN OPPOSITIONIT`; .
1 I TO DEFENDANT’S MOTION TO STRIKE ji I Tm
The defendant filed an extraordinary motion to strike the`_p1aihtiff1g5
opposition to his reply brief on November 17, 2003. ln the event co$t grants
the motion to strike, the plaintiff requests oral argument. It is apparent from the
face of the defendant’s reply brief that he either does not understand the file he
is defending or has wilfully misrepresented it to the court in his reply brief. The
facts as he recites them simply are not the facts pled. 1
As pleaded, the State presents a shocking case of prosecutorial 1
_ misconduct. This is no ordinary case of prosecutor acting within the course and I
scope of his duty. It is a case of outright fraud: About a prosecutor
masquerading as a judge and unilaterally informing those who rely upon him that 1
the court has ordered something which it has not ordered. One would have
hoped for better from the Attorney General of the State of Connecticut than a
defense which refuses to acknowledge the evident facts apparent on the face of 1
the pleadings.
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l ' Case 3:03-cv-OO94i9=»}CH Document 15 Filed 11/24,3003 Page 2 of 2
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l THE PLAINTIFF
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l orman A. Pattis
Williams and Pattis, LLC
I 51 Elm Street, Suite 409 l
` ' New Haven, CT 06610
I 2%.562.9931
FAX; 203.776.9494
l Federal Bar No. ct1312O
His Attorney 1
CERTIFICATION I
This is to certify that a copy of the foregoing was mailed, first class mail,
postage prepaid, on November 20, 2003, to the following counsel of record:
Robert V. Fisk, lll, Esq. l
110 Sherman Street \
. Hartford, CT 06105 r I 1
Dude l
Norman_A. Pattis V l:
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