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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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