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

Case 3:01-cv-02158-WWE Case 3:01-cv-02158-WWE

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Filed 09/08/2005 Filed 09/08/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT DONALD WAINRIGHT, ET AL., Plaintiffs, v. OSM COMMUNICATIONS, INC., ET AL., Defendants. : : : : : : : :

CIVIL ACTION NO. 3:01-CV-02158 (WWE)

: September 8, 2005

MOTION FOR SUMMARY JUDGMENT OF DEFENDANTS OSM COMMUNICATIONS, INC. AND ROBERT E. POLANSKY

Pursuant to the Federal Rules of Civil Procedure, Rule 56(c) the defendant ROBERT E. POLANSKY moves for summary judgment on the complaint and defendant OSM COMMUNICATIONS, INC. moves for summary judgment on the issue of liability on its counterclaims. The grounds for this motion are that there is no dispute as to any material fact and this defendant is entitled to judgment as a matter of law. This motion is supported by an affidavit of this defendant and excerpts from the deposition testimony of each of the plaintiffs all as more fully appears from the brief filed herewith. DEFENDANTS ROBERT E. POLANSKY And OSM COMMUNICATIONS, INC. By: _______________________________ Michael P. Goldsmith, Esq. 38 West 21st Street -- 5th Floor New York, NY 10010-6977 Telephone: (212) 677-4441 ext. 18

Case 3:01-cv-02158-WWE Case 3:01-cv-02158-WWE

Document 124 Document 114

Filed 09/08/2005 Filed 09/08/2005

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Federal Bar No. phv0219 Attorney for Defendants OSM Communications, Inc. and Robert E. Polansky

CERTIFICATE OF SERVICE This is to certify that on this 8th day of September 2005, a copy of the foregoing motion was deposited in the United States mail, first-class, postage prepaid, addressed to: Robert E. Arnold, Esq. Law Offices of Robert E. Arnold, LLC 205 Church Street, Suite 310 New Haven CT 06510-1805 J. Michael Sulzbach, Esq. 385 Orange Street New Haven, CT 06511

_____________________________ Michael P. Goldsmith, Esq.