Free Response to Motion - District Court of Delaware - Delaware

Case 1 :04-cv-01275-KAJ Document 56 Filed 07/O1/2005 Page 1 of 1
A IN THE UNITED STATES DISTRICT COURT __
FOR THE DISTRICT OF DELAWARE
Don’s Hydraulics, Inc. :
Plaintiff : Civil Action No.: 04-1275 KAJ
vs. :
Colony Insurance Company and
Truck Tech Industries, Inc., and :
Tipco Technologies, Inc. : J
Defendants
DEFENDANT, COLONY INSURANCE CO’S, RESPONSE TO PLAINTIFF’S
CROSS MOTION FOR SUMMARY JUDGMENT
Defendant, Colony Insurance Company, hereby responds to plaintiff, Don’s Hydraulics,
_ Inc.’s Cross Motion for Summary Judgment and avers that the damages sought by plaintiff are,
as a matter of law, not covered by the insurance policy at issue in this oase.. Defendant, Colony
Insurance Company, therefore requests srumnary judgment in its favor and against plaintiff The
reasons therefore are more fully set forth in the accompanying Motion. ·
FIGIOLA & FACCIOLO
/s/ Anthony A. Fi gliola
Anthony A. Figliola, Jr. (I.D. # 957)
. 1813 Marsh Road, Suite A
Wilmington, DE 19810
(302) 475-0460
Attorney for Defendant Colony Insurance
Dated: July 1, 2005 company