Case 3:18-cv-13092-ZNQ-TJB Document 61 Filed 02/07/22 Page 1 of 2 PageID: 589

DASTI, MURPHY, McGUCKIN, ULAKY,

KOUTSOURIS & CONNORS
PATRICK F. VARGA, ESQ. [ID No. 306502020]
620 West Lacey Road
Forked River, New Jersey 08731
(609) 971-1010 FAX (609) 971-7093
Attorneys for Defendants Richard Bosley, Theodore Kucowski, Trevor Crowley, Kevin
Chesney and Edward Travisano

UNITED STATES DISTRICT COURT

DISTRICT OF NEW JERSEY

PAUL C. WILLIAMS
Civil Action No. 3:18-13092 (BRM-TJB)

Plaintiff(s),
vs. Notice of Motion for Summary Judgment

RICHARD BOSLEY, individually and in

his official capacity; THEORDORE
KUCOSKI, individually and in his official
capacity; TREVOR CROWLEY,
individually and in his official capacity;
KEVIN CHESNEY, individually and in his
official capacity; EDWARD TRAVISANO,
individually and in his official capacity.

Defendant(s).

To: Paul C. Williams, Pro Se

35 Broad Street, #C4
Toms River, NJ 08753
DASTI, MURPHY
McGUCKIN, ULAKY,
PLEASE TAKE NOTICE that on March 21, 2022, the undersigned will apply to the
KOUTSOURIS & CONNORS

COUNSELLORS AT LAW
above named Court at the United States District Court House, Trenton, New Jersey for the entry

of an Order Granting Summary Judgment in favor of Defendants Richard Bosley, Theodore

620 WEST LACEY ROAD
FORKED RIVER, N.J. 08731

Kucowski, Trevor Crowley, Kevin Chesney and Edward Travisano.

Defendants will rely upon the Certifications, Statement of Undisputed Facts and Brief

Annexed hereto.
 Case 3:18-cv-13092-ZNQ-TJB Document 61 Filed 02/07/22 Page 2 of 2 PageID: 590

Respectfully Submitted,

DASTI, MURPHY, McGUCKIN, ULAKY,

KOUTSOURIS & CONNORS
Attorneys for Defendants
Dated: February 7, 2021
By:/s/ Patrick F. Varga__________
Patrick F. Varga, Esquire

CERTIFICATE OF MAILING

I hereby certify that on February 7, 2022 the within Notice of Motion, Letter Brief, and

proposed form of Order was filed via electronically filing; and one copy of same was sent via

regular and certified mail to:

Paul C. Williams, Pro Se

35 Broad Street, #C4
Toms River, NJ 08753

DASTI, MURPHY, McGUCKIN,

ULAKY, KOUTSOURIS & CONNORS
Attorneys for Defendants,

DASTI, MURPHY
Dated: February 7, 2022 BY: /s/ Patrick F. Varga______________
McGUCKIN, ULAKY, PATRICK F. VARGA, ESQ.
KOUTSOURIS & CONNORS

COUNSELLORS AT LAW

620 WEST LACEY ROAD

FORKED RIVER, N.J. 08731