Free Motion to Reopen Case - District Court of Connecticut - Connecticut

Case 3:01-cv-02224-CFD

Document 55

Filed 10/26/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

SHERRI PAULEY, ET AL VS. TOWN OF ANSONIA, ET AL

: : : : :

NO. 3:01CV02224 (CFD)

OCTOBER 20, 2005

MOTION TO REOPEN The plaintiffs, SHERRI PAULEY AND DAVID PAULEY, pursuant to Fed. Rule Civ. Proc. §59(e), respectfully request this Court to reopen the judgment and allow the plaintiffs to amend their complaint. In support of this motion, the plaintiffs represent as follows: 1. On September 28, 2005, this Court granted the defendants' summary

judgment motion as to the equal protection claim. 2. In its electronic order, this Court invited the plaintiffs to reopen the judgment

and amend their complaint within thirty (30) days of the order. 3. The First Amendment theory of the plaintiffs' was not pled inadvertently,

though the issues have been framed such that there is no prejudice to either party to reopen the judgment. 4. The reopening of this judgment is required to prevent a manifest injustice.

WHEREFORE, for the foregoing reasons, the plaintiffs request that this Court grant their motion to reopen the judgment.

Case 3:01-cv-02224-CFD

Document 55

Filed 10/26/2005

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THE PLAINTIFFS

BY: ________________________________ NORMAN A. PATTIS Fed. Bar No. ct13120 Law Offices of Norman A. Pattis LLC 649 Amity Road Bethany, CT 06524 (203) 393-3017

CERTIFICATION This is to certify that a copy of the foregoing was sent via first class mail, postage prepaid, on the above date, to the following counsel of record:

Attorney Thomas Gerarde Attorney Beatrice S. Jordan Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114 ________________________________ NORMAN A. PATTIS

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