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


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Date: March 9, 2005
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State: Connecticut
Category: District Court of Connecticut
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Case 3:01-cv-02224-CFD

Document 46

Filed 03/11/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT SHERRI PAULEY, ET AL Plaintiff VS. TOWN OF ANSONIA, ET AL Defendant : : : Case No. 3:01CV02224 (CFD) : : : MARCH 8, 2005 :

PLAINTIFF'S RULE 56 (a)2 STATEMENT OF MATERIAL FACTS IN DISPUTE A. 1. 2. 3. 4. 5. 6. Plaintiff's Response to Defendants' Rule 56(a)(1) Statement Admit. Admit. Admit. Admit. Admit. Deny. James and Sharon Hoffman made 19 complaints while the Pauleys' made 11 complaints (Pl. Exb. 3). 7. Deny. Sherri Pauley testified throughout her deposition that the Hoffmans were making false allegations concerning the Pauleys, including results of police investigations. (Pl. Exb. 1; Pl. Exb. 3) 8. Deny. David Pauley testified throughout his deposition that the Hoffmans

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were making false allegations concerning the Pauleys, including results of police investigations. (Pl. Exb. 2; Pl. Exb. 3) 9. 10. Deny. See #7 & #8. Deny. Many of the false allegations are substantiated by the police officers own reports. (Pl. Exb. 3) 11. 12. 13. 14. 15. Deny. See preceding 5 answers. (Exb. 3.) Admit. Admit. Admit. Admit and also arrested at this time were Sherri Pauley and her fifteen year old son. 16. 17. Admit. Deny. Plaintiffs had shared this knowledge with the defendants (Complaint ¶12, 13; Exb. 1, Exb. 2) 18. Deny. The plaintiffs' request to file a written complaint against the Hoffmans was denied by the town of Ansonia and the police department on four occasions (Pl. Exb 1 at 27, 32, 42, 43; Pl. Exb. 5; Pl. Exb. 6) 19. 20. 21. Admit. Admit. Admit as to this is a statement made by Kevin Hale in his affidavit. -2-

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22. 23. 24. 25. 26.

Admit as to this is a statement made by Kevin Hale in his affidavit. Admit as to this is a statement made by Kevin Hale in his affidavit. Admit as to this is a statement made by Kevin Hale in his affidavit. Admit as to this is a statement made by Kevin Hale in his affidavit. Admit as to this is a statement made by Kevin Hale in his affidavit.

B. 1.

Plaintiff's Rule 56(a)(2) Statement of Material Facts in Dispute Upon information and belief, the Ansonia Police Department has a policy, practice and custom of not taking civilian complaints in the context of neighborhood disputes. (Complaint ¶15)

2.

This policy, practice and custom was endorsed and ratified by defendant Chief Hale. (Complaint ¶15)

3.

The plaintiffs requested to file written civil complaints to the Ansonia Police Department and were denied their write on four occasions. (Pl. Exb 1 at 27, 32, 42, 43; Pl. Exb. 5; Pl. Exb. 6)

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THE PLAINTIFF

____________________________ Kim Coleman Waisonovitz, Esq. Federal Bar No. ct25759 Law Office of Norman Pattis,LLC P.O. Box 280 Bethany, CT 06524 Tel: 203.393.3017 Fax: 203.393.9745 Plaintiff's Attorney

CERTIFICATION This is to certify that a copy of the foregoing was sent via first class mail, postage prepaid, on March 8, 2005, to the following parties and counsel of record:

Beatrice Jordan, Esq. Howd & Ludorf 65 Wethersfield Avenue Hartford, CT 06114

Kim Coleman Waisonovitz -4-