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


File Size: 37.1 kB
Pages: 2
Date: December 8, 2004
File Format: PDF
State: Connecticut
Category: District Court of Connecticut
Author: unknown
Word Count: 357 Words, 2,106 Characters
Page Size: Letter (8 1/2" x 11")
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https://www.findforms.com/pdf_files/ctd/15563/71.pdf

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Case 3:01-cv-02374-CFD

Document 71

Filed 12/09/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : CIVIL NO. 3:01CV 2374 (CFD) : V. : : THE TOWN OF STONINGTON, ET AL : DECEMBER 8, 2004 EDWARD BROWN, ET AL

PLAINTIFF MENARD'S OPPOSITION TO DEFENDANTS' MOTION FOR BOND The plaintiff Jeffrey Menard asks the court to deny the defendants' Motion for Bond, dated December 6, 2004. The general rule on costs is that costs follow the event. The purpose of this rule is to compensate the winning party for the vindication of its position. While the plaintiff Jeffrey Menard does acknowledge that the Local Rules of Civil Procedure specifically provide an exception to this general rule, another exception is where a "public interest" litigant, such as the plaintiff in this case, proceeds against a public/governmental entity to seek redress of violations of his civil rights. If the public interest litigant wins, he or she should not be personally out of pocket for acting in the public interest, and if he or she loses, they should not be penalized for either clarifying the law or testing an issue of public interest and importance. Wherefore the plaintiff Jeffrey Menard asks the court to deny the defendants' Motion for Bond.

Case 3:01-cv-02374-CFD

Document 71

Filed 12/09/2004

Page 2 of 2

THE PLAINTIFF JEFFREY MENARD
R. = US R. Edward Phillips DN: CN =I amEdward Phillips, Cdocument Reason: the author of this Date: 2004.12.08 12:28:35 -05'00' Digitally signed by R. Edward Phillips

By:

R. Edward Phillips, Esquire One Union Plaza, Second Floor New London, CT 06320 (860) 444-0437 # CT20999

CERTIFICATION This is to certify that a copy of the foregoing was mailed or electronically delivered on December 8, 2004 to: Beatrice S. Jordan, Esquire Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114-1190 (860) 249-1361 Mr. Edward Brown 4 Marlene Drive Ledyard, CT 06339

R. Edward Phillips

Digitally signed by R. Edward Phillips DN: CN = R. Edward Phillips, C = US Reason: I am the author of this document Date: 2004.12.08 12:28:54 -05'00'

R. Edward Phillips, Esquire