Doe v. City of Albuquerque

Filing 43

Opposed MOTION for Summary Judgment by John Doe. (Egan, Brendan)

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Doe v. City of Albuquerque Doc. 43 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO JOHN DOE, Plaintiff, v. CITY OF ALBUQUERQUE, Defendant. PLAINTIFF' S MOTION FOR SUMMARY JUDGMENT COMES NOW PLAINTIFF, through and by the undersigned counsel, and pursuant to Fed. R. Civ. P. 56 respectfully requests this Court to enter summary judgment against Defendant on all claims set forth in Plaintiff's Complaint for Declaratory and Injunctive Relief and to grant such further relief as it deems fair and equitable. Grounds for this Motion are set forth in the accompanying Memorandum in Support of Motion for Summary Judgment. CIV. NO. 08-1041 MCA/LFG Respectfully submitted, ACLU of NEW MEXICO /s/ Brendan Egan 5/15/2009 George Bach Brendan Egan Staff Attorneys P.O. Box 566 Albuquerque, NM 87103 (505) 243-0046 Facsimile (505) 266-5916 Maureen A. Sanders Co-Legal Director ACLU of New Mexico Sanders & Westbrook, PC 102 Granite Avenue, NW Albuquerque, NM 87102 (505) 243-2243 OF COUNSEL Attorneys for Plaintiff I HEREBY CERTIFY that on May 15, 2009, I filed the foregoing pleading electronically through the CM/ECF system and caused the following parties and/or counsel to be served electronically through the CM/ECF system: Gregory S. Wheeler & Peter H. Pierotti Assistant Albuquerque City Attorneys P.O. Box 2248 Albuquerque, NM 87103 Attorneys for Defendant /s/ Submitted Electronically 5/15/09 Brendan Egan 2

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