Free Statement of Material Facts - District Court of Connecticut - Connecticut

Case 3:01-cv-02224-CFD

Document 50

Filed 04/08/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

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

: : : : :

NO.: 3:01CV02224 (CFD)

APRIL 7, 2005

REPLY TO PLAINTIFFS' LOCAL RULE 56(a)2 STATEMENT 1. Upon information and belief, the Ansonia Police Department has a

policy, practice and custom of not taking civilian complaints in context of neighborhood disputes. (Complaint ¶15) REPLY: this claim. 2. The policy, practice and custom was endorsed and ratified by defendant Denied. In addition, plaintiffs have not cited any admissible evidence for

Chief Hale. (Complaint ¶15) REPLY: this claim. 3. The plaintiffs requested to file written civil complaints to the Ansonia Denied. In addition, plaintiffs have not cited any admissible evidence for

Police Department and were denied their write (sic) on four occasions. (Pl. Exb. 1 at 27, 32, 42, 43; Pl. Exb. 5; Pl. Exb. 6) REPLY: Denied.

Case 3:01-cv-02224-CFD

Document 50

Filed 04/08/2005

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DEFENDANTS, TOWN OF ANSONIA, SERGEANT ZALINSKY AND KEVIN HALE

By_/S/ Melinda A. Powell_____ Melinda A. Powell Ct 17049 Howd & Ludorf, LLC 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (Fax) [email protected]

CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U.S. Mail, to the following counsel of record this 7th day of April, 2005. Kim Coleman Waisonovitz, Esquire Law Offices of Norman A. Pattis 649 Amity Road P.O. Box 280 Bethany, CT 06524 ____________________________ Melinda A. Powell

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