On February 23, 2021 a
Motion-Secondary
was filed
involving a dispute between
Jason Penna,
and
Angelo G. Tranquillo,
Mortgage Electronic Registration Systems, Inc. As Nominee For Homebridge Financial Services, Inc.,
for P10 - Property - Partition
in the District Court of New Haven County.
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DOCKET NO.: AAN-CV21-6041868-S : SUPERIOR COURT
JASON PENNA : J.D. OF ANSONIA/
: MILFORD
V. : AT MILFORD
ANGELO G. TRANQUILLO, ET AL. : APRIL 14, 2022
OBJECTION TO DEFENDANT’S MOTION FOR EXTENSION OF TIME
The Plaintiff, JASON PENNA, hereby objects to the Defendant’s, Angelo G. Tranquillo,
Request for Extension of Time to respond to Plaintiff’s First Set of Interrogatories Requests for
Production [Entry No. 114.00] and Defendant’s Request for Extension of Time to respond to
Plaintiff’s Request for Admissions [Entry No. 115.00]. The Plaintiff has given the Defendant every
courtesy possible in this matter, including a revised scheduling order with an extended discovery
response deadline of May 29, 2022. In turn, the Defendant has continually delayed this case since
its commencement, and such delays substantially prejudice the Plaintiff. These requests for
extensions of time are a further dilatory tactic to prevent this matter from moving forward.
WHEREFORE, the Plaintiff objects to any extensions of time for the Defendant to respond
to the Plaintiff’s discovery requests.
THE PLAINTIFF,
BY: /s/ 419756
Francis Lieto, Esq.
Goldman Gruder & Woods, LLC
105 Technology Drive
Trumbull, CT 06611
Tel: (203) 880-5333
Fax: (203) 880-5332
flieto@goldgru.com
Juris No. 035172
CERTIFICATION
I hereby certify that a copy of the foregoing was mailed or electronically delivered this
14th day of April 2022 to all counsel and self-represented parties of record and that written consent
for electronic delivery was received from all counsel and self-represented parties of record who
were electronically served:
COTTER COTTER & MULLINS
6515 MAIN STREET
SECOND FLOOR, SUITE 10
TRUMBULL, CT 06611
BENDETT & MCHUGH PC
270 FARMINGTON AVENUE, SUITE 151
FARMINGTON, CT 06032
/s/ 419756
Francis Lieto, Esq.
Commissioner of the Superior Court
Document Filed Date
April 14, 2022
Case Filing Date
February 23, 2021
Category
P10 - Property - Partition
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DOCKET NO.: AAN-CV21-6041868-S : SUPERIOR COURT JASON PENNA : J.D. OF ANSONIA/ : MILFORD V. : AT MILFORD ANGELO G. TRANQUILLO, ET AL. : APRIL 14, 2022 OBJECTION TO DEFENDANT’S MOTION FOR EXTENSION OF TIME The Plaintiff, JASON PENNA, hereby objects to the Defendant’s, Angelo G. Tranquillo, Request for Extension of Time to respond to Plaintiff’s First Set of Interrogatories Requests for Production [Entry No. 114.00] and Defendant’s Request for Extension of Time to respond to Plaintiff’s Request for Admissions [Entry No. 115.00]. The Plaintiff has given the Defendant every courtesy possible in this matter, including a revised scheduling order with an extended discovery response deadline of May 29, 2022. In turn, the Defendant has continually delayed this case since its commencement, and such delays substantially prejudice the Plaintiff. These requests for extensions of time are a further dilatory tactic to prevent this matter from moving forward. WHEREFORE, the Plaintiff objects to any extensions of time for the Defendant to respond to the Plaintiff’s discovery requests. THE PLAINTIFF, BY: /s/ 419756 Francis Lieto, Esq. Goldman Gruder & Woods, LLC 105 Technology Drive Trumbull, CT 06611 Tel: (203) 880-5333 Fax: (203) 880-5332 flieto@goldgru.com Juris No. 035172 CERTIFICATION I hereby certify that a copy of the foregoing was mailed or electronically delivered this 14th day of April 2022 to all counsel and self-represented parties of record and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were electronically served: COTTER COTTER & MULLINS 6515 MAIN STREET SECOND FLOOR, SUITE 10 TRUMBULL, CT 06611 BENDETT & MCHUGH PC 270 FARMINGTON AVENUE, SUITE 151 FARMINGTON, CT 06032 /s/ 419756 Francis Lieto, Esq. Commissioner of the Superior Court