Free Motion for Reconsideration - District Court of Connecticut - Connecticut

Case 3:01-cv-01986-AVC

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ---------------------------------------X JAMIE DROMERHAUSER, Plaintiff, -againstEVERILDO REYES, ---------------------------------------X Defendant. JUNE 15, 2004 MOTION ­ F.R.C.P. 60(b)

MOTION TO VACATE AND FOR RECONSIDERATION 3:01 CV1986(AVC)

Plaintiff, Jamie Dromerhauser, respectfully moves this Court for an Order vacating the order of August 18, 2003 and for reconsideration. MEMORANDUM
A.STATEMENT

OF FACTS

1. This action arises from an automobile accident that took place on November 11, 2000, on Route 15, in Trumbull, Connecticut. Plaintiff, Jamie Dromerhauser was the

operator of a vehicle that came into contact with the vehicle operated by defendant Reyes, after he lost control of his vehicle and the vehicle struck the roadway divider. 2. As a result of this accident plaintiff, Jamie Dromerhauser sustained serious personal injuries, including but not limited to, a tear of the meniscus of the left knee requiring surgery and a mallet deformity to the pinky

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finger of his right hand. 3. Prior counsel received the Court's order of July 7, Due to a clerical error the report

2003 on July 11, 2003.

to the Court was not properly filed. 4. The undersigned attorney has been retained to proceed

with this matter. The undersigned is duly licensed to practice in the District Court of Connecticut, and maintains an office in Hamden, Connecticut. 5. The undersigned is prepared to prosecute this action, to completion, as required by law.
B.DISCUSSION

Based upon the aforesaid, plaintiff respectfully requests that the Court Vacate the Order and Judgment dated August 18, 2003, and for whatever further relief this Court deems just and proper. C. CONCLUSION. Plaintiff respectfully requests that the motion be granted in all respects. Dated: __________________ THE PLAINTIFF ________________________ BY ROBERT M. SINGER, ESQ. 2572 WHITNEY AVE. HAMDEN, CT 06518 203-248-8278 Fed. Bar #08696

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ---------------------------------------X JAMIE DROMERHAUSER, Plaintiff, -againstEVERILDO REYES, ---------------------------------------X Defendant.

MOTION TO VACATE AND FOR RECONSIDERATION 3:01 CV1986(AVC)

ORDER RE: MOTION ­ F.R.C.P. 60(b) The foregoing motion, having come before the Court, this _____________ day of __________, 2004, and due notice having been given to all interested parties, as required by law. IT IS ORDERED THAT

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THE MOTION IS HEREBY GRANTED/DENIED Dated___________________ __________________________ Alfred V. Covello, UNITED STATES DISTRICT JUDGE

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ---------------------------------------X JAMIE DROMERHAUSER, Plaintiff, -againstEVERILDO REYES, ---------------------------------------X Defendant.

MOTION TO VACATE AND FOR RECONSIDERATION 3:01 CV1986(AVC)

CERTIFICATION OF SERVICE I hereby certify that on this 15th day of June, 2004, I mailed a copy of the foregoing , by first class mail, postage prepaid to: Andrew Turret, Esq. One Century Tower 265 Church St. Suite 802 New Haven, CT 06510-7014

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Mark Gould, Esq. One Century Tower 265 Church St. Suite 802 New Haven, CT 06510-7014

BY___________________ ROBERT M. SINGER ATTORNEY FOR PLAINTIFF 2572 Whitney Avenue Hamden, CT 06518 203-248-8278 FED BAR #08696

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