Gero v. City of TauntonCross MOTION for Partial Summary JudgmentD. Mass.May 26, 2017UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS ____________________________________ ) NANCY GERO, ) Plaintiff, ) ) v. ) C.A. NO. 1:11-cv-10039-MLW ) CITY OF TAUNTON , ) Defendant. ) ____________________________________) DEFENDANT’S CROSS-MOTION FOR PARTIAL SUMMARY JUDGMENT Pursuant to Fed. R. Civ. P., Rule 56, the City of Taunton hereby cross-moves for partial summary judgment with respect to Counts One and Two of Plaintiff’s Third Amended Complaint. In support thereof, the Court is respectfully referred to the City’s Statement of Additional Facts which are not in dispute, together with the City’s Memorandum in Opposition to Plaintiff’s Motion for Partial Summary Judgment and in Support of the City’s Cross-Motion for Partial Summary Judgment. As explained more fully therein, the City of Taunton submits that this Court should grant the City’s Cross-Motion for Partial Summary Judgment as to Counts I & II because the Plaintiff lacks standing to seek City wide injunctive relief. Respectfully submitted, By the Defendant, CITY OF TAUNTON, By its attorneys, PIERCE DAVIS & PERRITANO LLP /s/ Jason W. Crotty Jason W. Crotty, BBO #656313 John J. Davis, BBO #115890 10 Post Office Square, Suite 1100N Boston, MA 02109-4603 (617) 350-0950 jcrotty@piercedavis.com Dated: May 26, 2017 Case 1:11-cv-10039-MLW Document 135 Filed 05/26/17 Page 1 of 2 - 2 - CERTIFICATE OF SERVICE I hereby certify that the foregoing, filed through the Electronic Case Filing System, will be sent electronically to the registered participants as identified on the Notice of Electronic Filing and that a paper copy shall be served upon those indicated as non-registered participants on May 26, 2017. /s/ Jason W. Crotty Jason W. Crotty Case 1:11-cv-10039-MLW Document 135 Filed 05/26/17 Page 2 of 2
