Free Motion for More Definite Statement - District Court of Connecticut - Connecticut

Case 3:03-cv-00934-WIG

Document 27

Filed 10/25/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SAMMIE GOSS PLAINTIFF, V. BRIDGEPORT HOUSING AUTHORITY, COLLIN VICE, BERNIE WILLIAMS, OLGA PEREZ, WILLIAM BURGOS, MISS RODRIGUES AND MISS DOE DEFENDANTS. : : : : : : : : : : : :

CIVIL ACTION NO. 3:03 CV-00934 (WIG)

OCTOBER 24, 2005

MOTION FOR A MORE DEFINITE STATEMENT The undersigned Defendants, Bridgeport Housing Authority ("BHA"), Collin Vice, Bernie Williams, Olga Perez, William Burgos, Miss Rodriguez and Miss Doe, respectfully move this Court, pursuant to F.R.C.P. § 12(e), to order the Plaintiff to amend her complaint as set forth herein. For the reasons set forth below, the Plaintiff's complaint is so vague and ambiguous that the Defendants cannot frame a response thereto. The Plaintiff's complaint is purportedly brought on behalf of herself and her dog against the BHA and six apparent BHA employees. Her handwritten, four page, single spaced complaint appears to involve at least three separate incidents regarding her contacts with the BHA and its employees. The Plaintiff makes broad claims of housing, age and disability discrimination, including violations of the Americans with Disabilities Act, the Fair Housing Act, Conn. Gen.

Case 3:03-cv-00934-WIG

Document 27

Filed 10/25/2005

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Stats. § 46a-64c, Title VIII of the Civil Rights Act of 1968, enforced through Conn. Gen. Stat. § 46a-58(A), and § 504 of the Rehabilitation Act. F.R.C.P. § 10. Form of Pleadings, states in relevant part: (b) Paragraphs: Separate Statements. All Averments of claim or defense shall be made in numbered paragraphs, the contents of which shall be limited as far as practicable to a statement of a single set of circumstances; . . . Each claim founded upon a separate transaction or occurrence and each defense other than denial shall be stated in a separate count or defense whenever a separation facilitates the clear presentation of the matters set forth.

Wherefore, the Defendants respectfully move the Court to enter an order that the Plaintiff amend her Complaint to: 1. State a separate count for each set of circumstances the Plaintiff alleges were violations of the law; 2. 3. Separate each count into paragraphs; and In each count, identify each and every statute the Plaintiff claims was violated by the Defendants' alleged conduct and which individual Defendants the Plaintiff claims were involved in said conduct. And to serve a Revised Complaint within 10 days of the granting of this motion.

Case 3:03-cv-00934-WIG

Document 27

Filed 10/25/2005

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THE DEFENDANTS, BRIDGEPORT HOUSING AUTHORITY, COLLIN VICE, BERNIE WILLIAMS, OLGA PEREZ, WILLIAM BURGOS, MISS RODRIGUEZ AND MISS DOE

By: James A. Mahar, Esq., (CT 21854) Ryan, Ryan, Johnson & Deluca, LLP 80 Fourth Street, P.O. Box 3057 Stamford, CT 06905 Phone No. 203-357-9200

Case 3:03-cv-00934-WIG

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Filed 10/25/2005

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CERTIFICATE OF SERVICE I hereby certify that on October 24, 2005, a copy of the above was mailed to the following counsel and pro se parties of record: Sammie Goss 10 Ridgeley Avenue Fairfield, CT 06825 Attorney for Pro Se Plaintiff

___________________________________ James A. Mahar, Esq.
I:\Procases\1742.009\mot more definite stmt.wpd 1742.009