Motion for Summary Judgement

UNITED STATES DISTRICT COURT

FOR THE

DISTRICT OF CONNECTICUT

 

Mrs. D., on her own behalf
and as mother of John D.,

Plaintiff,

CIVIL ACTION NO.
V.                                                                                39cv00469 (AHN)                                                         October 17, 1996

George Apuzzi,
Superintendent of Stafford Public
Schools

THE STAFFORD BOARD OF EDUCATION

          Defendants.

 

MOTION FOR SUMMARY JUDGMENT

Plaintiff Mrs. D., pursuant to Rule 56 of the Federal Rules of Civil Procedure and Rule 9 c (1) of the Local Rules of Civil Procedure moves that the Court enter summary judgement for plaintiff on the ground that there is no genuine issue as to any material fact and that the plaintiff is entitled to judgement as a matter of law.

ORAL ARGUMENT REQUESTED

NO TESTIMONY REQUIRED

Plaintiff is the prevailing party from a special education due process hearing and consequently is seeking

attorneys’ fees and costs. This motion is based on the Hearing Officer’s Order which included a Stipulated Agreement signed by both parties. The grounds of this motion are more fully set forth in Plaintiff’s Memorandum Of Law In Support Of Plaintiff’s Motion For Summary Judgment.

Plaintiff further moves that if summary judgement is not rendered in her favor for all of the relief prayed for, that the Court grant plaintiff partial summary judgement and ascertain what material facts are actually and in good faith controverted, and thereupon make an order specifying the facts that appear without substantial controversy and directing such further proceedings in the action as are just.

PLAINTIFF

By________________________________
Anne Louise Blanchard
Connecticut Legal Services, Inc.
P.O. Box 258
872 Main Street
Willimantic, CT 06226
Tel. (860) 456-1762
Fed. Bar. No. ct08718

CERTIFICATION

I hereby certify that a copy of the foregoing Motion for Summary Judgment was mailed, postage prepaid on this day of Octoer, 1996 to:

Attorney Michael P. McKeon

Law Offices of Sullivan, Schoen, Campane & Connon, LLC.

646 Prospect Avenue

Hartford, CT 06105-4286

Anne Louise Blanchard

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