Free Reply to Response to Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00373-RNC

Document 92

Filed 08/10/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT RICHARD A. MYERS, ET AL, Plaintiffs V. TOWNSHIP OF TRUMBULL, ET AL, Defendants : : : : : : :

CIVIL ACTION NO: 3:03-CV-00373 (RNC)

AUGUST 9, 2004

REPLY TO PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION OF DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

The Defendants, Spectaguard and Michael (LNU) (hereinafter referred to as the "Spectaguard Defendants"), hereby reply as follows to the Plaintiffs' Memorandum of Law in Opposition to Spectaguard Defendant Motion for Summary Judgment. Said opposition was filed on July 28, 2004 and according to the email notification from the Court Clerk's office, said filing date makes such opposition untimely by two (2) days. Therefore, it is the position of the Spectaguard Defendants that their Motion for Summary Judgment should be granted absent objection as no timely objection was filed. Should oral argument be granted on the objection, the Spectaguard Defendants respectfully reserve their right to respond at said argument to any substantive issues raised by the Plaintiffs in their untimely objection.

Case 3:03-cv-00373-RNC

Document 92

Filed 08/10/2004

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THE DEFENDANTS, SPECTAGUARD and MICHAEL (LNU),

BY: ____________________________ Robert J. Flanagan, Jr., Esq. Cella, Flanagan & Weber, P.C. 21 Washington Avenue North Haven, CT 06473 Tel. (203) 239-5851 Federal Bar No. 18549

Case 3:03-cv-00373-RNC

Document 92

Filed 08/10/2004

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CERTIFICATION THIS IS TO CERTIFY that a copy of the foregoing was mailed, postage prepaid, to the following counsel: Cynthia H. Hardaway, Esq. Hunt, Hamlin & Ridley Military Park Building 60 Park Place, Suite 1602 Newark, NJ 07102 Michael T. McCormack, Esq. Tyler, Cooper & Alcorn, LLP 185 Asylum Street CityPlace I 35th Floor Hartford, CT 06103-3802 Stuart Brown, Esq. Hassett & George 555 Franklin Avenue Hartford, CT 06114

_________________________ ROBERT J. FLANAGAN, JR.

Case 3:03-cv-00373-RNC

Document 92

Filed 08/10/2004

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