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

Case 3:03-cv-00943-AWT

Document 93

Filed 01/22/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT GARY SESSION Plaintiff V. CITY OF NEW HAVEN; STEPHEN COPPOLA; AND EDWIN RODRIGUEZ, Defendants : : : : : : : :

CIV. NO. 3:03CV00943 (AWT)

JANUARY 22, 2007

MOTION FOR SUMMARY JUDGMENT Pursuant to Rule 56, Fed. R. Civ. Proc., and Rules 7 and 56 of the Local Rules of Civil Procedure, the defendant City of New Haven moves for the entry of summary judgment in its favor on Counts One, Two and Three of the Revised Complaint dated June 29, 2005. There is no genuine dispute of any material fact, and defendant the City of New Haven is entitled to judgment as a matter of law. In support of this motion, defendant the City of New Haven adopts the defendants Edwin Rodriguez's and Stephen Coppola's Local Rule 56(a)1 Statement of Material Facts Not in Dispute, and attaches its own statement of additional material facts not in dispute. The defendant City also attaches a Memorandum of Law in Support and "Exhibit A, Affidavit of Chief Ortiz."

ORAL ARGUMENT IS NOT REQUESTED

OFFICE OF THE CORPORATION COUNSEL · CITY OF NEW HAVEN 165 Church Street, New Haven, CT 06510 Telephone (203) 946-7958 · Facsimile (203) 946-7942 · Juris No. 42715

Case 3:03-cv-00943-AWT

Document 93

Filed 01/22/2007

Page 2 of 2

THE DEFENDANT, THE CITY OF NEW HAVEN

BY: /s/:Thomas W. Ude, Jr. Thomas W. Ude, Jr. Corporation Counsel City of New Haven 165 Church Street, 4th Floor New Haven, CT 06510 Federal Bar No. ct06567 Phone: (203) 946-7958 Fax: (203) 946-7942 E-mail: [email protected]

________

CERTIFICATION I hereby certify that on January 22, 2007, a copy of foregoing Renewed Motion for Summary Judgment was filed electronically and served by mail on anyone unable to accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the court's electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this through the court's CM/ECF System. Karen Mayer, Esq. Philip Russell, PC 66 Field Point Road P.O. Box 1437 Greenwich, CT 06836 Meghan Gallagher, Esq. Susman, Duffy & Segaloff, P.C. P.O. Box 1684 New Haven, CT 06507-1684 /s/: Thomas W. Ude, Jr.__________ Thomas W. Ude, Jr.

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OFFICE OF THE CORPORATION COUNSEL · CITY OF NEW HAVEN 165 Church Street, New Haven, CT 06510 Telephone (203) 946-7958 · Facsimile (203) 946-7942 · Juris No. 42715