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NO: (X06) UWY CV 21 5028294S SUPERIOR COURT
NANCY BURTON : COMPLEX LITIGATION DOCKET
v. : AT WATERBURY
DAVID PHILIP MASON, ET AL : APRIL 22, 2022
OBJECTIONS TO PLAINTIFF’S INTERROGATORIES AND
REQUESTS FOR PRODUCTION DATED FEBRUARY 23, 2022
Pursuant to Practice Book §§13-7, 13-8 and 13-10, the defendant, Elinore
Carmody, hereby objects to plaintiff's interrogatories and requests for production,
dated February 23, 2022, as follows:
INTERROGATORIES
4. What is your educational background, including the names and locations
of the high school(s) and post-high school educational facilities you have attended, the
dates thereof and the degree(s), if any, you obtained and the dates thereof.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence.
5. State your date of birth and where you were born.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence.
7. State all careers you have pursued in your lifetime and the individuals
and entities by whom you have been employed, their locations and the dates of your
employment at each.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence.
8. Were you employed by “George” magazine and, if so, in what position(s)
and the dates thereof and the reasons for your departure.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is not reasonably calculated to lead to the discovery of
admissible evidence.
9. State when you have communicated with Bryan Hurlburt, Commissioner,
Connecticut Department of Agriculture and whether you have received
communications from him; the substance of each such communication, the dates
thereof, the modes of communication (i.e., via telephone, email, remote (i.e., over
“ZOOM” and such technologies), in person and by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
10. State whether you have communicated with Jeremiah Dunn, chief animal
control officer, Connecticut Department of Agriculture, and whether you have received
communications from him; the substance of each such communication, the dates
thereof, the modes of communication (i.e., via telephone, email, remote (i.e., over
“ZOOM” and such technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
11. State whether you have communicated with Charles DellaRocco, a
Connecticut Department of Agriculture animal control officer and whether you have
received communications from him; the dates thereof, the substance of each such
2
communication, the modes of communication (i.e., via telephone, email, remote (i.e.,
over “ZOOM” and such technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
12. State whether you have communicated with David Philip Mason
regarding Plaintiff and her goats and whether you have received communications from
him; the dates thereof, the substance of each such communication, the modes of
communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such
technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
13. State whether you have communicated with Julia Pemberton regarding
Plaintiff and her goats and whether you have received communications from her; the
dates thereof, the substance of each such communication, the modes of
communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such
technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
14. State whether you have communicated with Margaret O’Donnell
regarding Plaintiff and her goats and whether you have received communications from
3
her; the dates thereof, the substance of each such communication, the modes of
communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such
technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
15. State whether you have communicated with David Philip Mason
regarding Plaintiff and her goats and whether you have received communications from
him; the dates thereof, the substance of each such communication, the modes of
communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such
technologies), in person, by mail.
OBJECTION: See the objection to interrogatory no. 12.
16. State whether you have communicated with Michael Thompson
regarding Plaintiff and her goats and whether you have received communications from
him; the dates thereof, the substance of each such communication, the modes of
communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such
technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
17. State whether you have communicated with Alice Smith, executive
assistant to Redding First Selectman, regarding Plaintiff and her goats and whether
you have received communications from her; the dates thereof, the substance of each
such communication, the modes of communication (i.e., via telephone, email, remote
(i.e., over “ZOOM” and such technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
4
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
18. State whether you have communicated with Plaintiff Nancy Burton and
whether you have received communications from her; the dates thereof, the substance
of each such communication, the modes of communication (i.e., via telephone, email,
remote (i.e., over “ZOOM” and such technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that the
information sought can be obtained with equal or geater
facility by the plaintiff herself. The defendant further objects
to this interrogatory insofar as it is duplicative of prior
discovery served on the defendant.
19. State whether you have attended gatherings with others at the Redding
Town Hall (remotely or in person) concerning Plaintiff and her goats and if so state the
dates when such gatherings took place and identify all who attended.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
20. State whether you have communicated with Susan Winters and whether
you have received communications from her; the dates thereof, the substance of each
such communication, the modes of communication (i.e., via telephone, email, remote
(i.e., over “ZOOM” and such technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
5
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
21. State whether you have communicated with judicial and clerical
personnel at the Danbury Superior Court regarding Plaintiff, her litigation there and her
goats and whether you have received communications from such personnel; the
dates thereof, the substance of each such communication, the modes of
communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such
technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
22. State whether you have communicated with State Senator Will Haskell
and whether you have received communications from him; the dates thereof, the
substance of each such communication, the modes of communication (i.e., via
telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by
mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
23. State whether you have communicated with members of the news
media regarding Plaintiff and her goats and whether you have received
communications from him/her/them; the dates thereof, the substance of each such
communication, the modes of communication (i.e., via telephone, email, remote (i.e.,
over “ZOOM” and such technologies), in person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
6
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
24. State whether you have communicated with Lia Albo regarding Plaintiff
and her goats and whether you have received communications from her; the dates
thereof, the substance of each such communication, the modes of communication
(i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in
person, by mail.
OBJECTION: The defendant objects to this interrogatory on the grounds
that it is overly broad, unduly burdensome, vague,
ambiguous and not reasonably calculated to lead to the
discovery of admissible evidence. The defendant further
objects to this interrogatory on the ground that it seeks
information that is within the scope of the litigation privilege.
The defendant further objects to this interrogatory insofar as
it is duplicative of prior discovery served on the defendant.
REQUESTS FOR PRODUCTION
1. In accordance with Practice Book Section 13-9 et seq., the defendant,
Elinore Carmody, is directed to identify and provide Plaintiff with copies of all
documents, records and materials of whatever kind and however stored which are
responsive to Plaintiff’s Request for Interrogatories Nos. 9-24 as submitted
simultaneously to her on this date.
OBJECTION: See the objections to interrogatories nos. 9 through 24,
above, which are incorporated herein by reference.
7
DEFENDANT,
ELINORE CARMODY
By_/s/ Philip T. Newbury, Jr. _________
Philip T. Newbury, Jr.
Kristan M. Jakiela
Howd & Ludorf, LLC
65 Wethersfield Avenue
Hartford, CT 06114-1121
(860) 249-1361
(860) 249-7665 (Fax)
Juris No.: 28228
E-mail: pnewbury@hl-law.com
E-mail: kjakiela@hl-law.com
8
CERTIFICATION
This is to certify that a copy of the foregoing Objections to Plaintiff’s
Interrogatories and Requests for Production Dated February 23, 2022, was or will
immediately be mailed or delivered electronically or non-electronically on April 22,
2022, to all parties and pro se parties of record and that written consent for electronic
delivery was received from all attorneys and self-represented parties receiving
electronic delivery.
Nancy Burton Steven J. Stafstrom, Jr., Esquire
154 Highland Avenue Pullman & Comley, LLC
Rowayton, CT 06853 850 Main Street, P.O. Box 7006
NancyBurtonCT@aol.com Bridgeport, CT 06601
sstafstrom@pullcom.com
Kimberly Bosse, Esquire David B. Stanhill, Esquire
James N. Tallberg, Esquire Michael D. Riseberg, Esquire
Karsten & Tallberg, LLC Christine N. Parise, Esquire
500 Enterprise Drive, Suite 4B Rubin and Rudman, LLP
Rocky Hill, CT 06067 53 State Street
kbosse@kt-lawfirm.com Boston, MA 02109
jtallberg@kt-lawfirm.com dstanhill@rubinrudman.com
mriseberg@rubinrudman.com
cparise@rubinrudman.com
Jonathan E. Harding, Esquire
Matthew I. Levine, Esquire
AG-Environment
165 Capitol Ave., 5th Floor
Hartford, CT 06106
Jonathan.harding@ct.gov
matthewlevine@ct.gov
/s/ Philip T. Newbury, Jr.______________
Philip T. Newbury, Jr.
9
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NO: (X06) UWY CV 21 5028294S SUPERIOR COURT NANCY BURTON : COMPLEX LITIGATION DOCKET v. : AT WATERBURY DAVID PHILIP MASON, ET AL : APRIL 22, 2022 OBJECTIONS TO PLAINTIFF’S INTERROGATORIES AND REQUESTS FOR PRODUCTION DATED FEBRUARY 23, 2022 Pursuant to Practice Book §§13-7, 13-8 and 13-10, the defendant, Elinore Carmody, hereby objects to plaintiff's interrogatories and requests for production, dated February 23, 2022, as follows: INTERROGATORIES 4. What is your educational background, including the names and locations of the high school(s) and post-high school educational facilities you have attended, the dates thereof and the degree(s), if any, you obtained and the dates thereof. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. 5. State your date of birth and where you were born. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. 7. State all careers you have pursued in your lifetime and the individuals and entities by whom you have been employed, their locations and the dates of your employment at each. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. 8. Were you employed by “George” magazine and, if so, in what position(s) and the dates thereof and the reasons for your departure. OBJECTION: The defendant objects to this interrogatory on the grounds that it is not reasonably calculated to lead to the discovery of admissible evidence. 9. State when you have communicated with Bryan Hurlburt, Commissioner, Connecticut Department of Agriculture and whether you have received communications from him; the substance of each such communication, the dates thereof, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person and by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 10. State whether you have communicated with Jeremiah Dunn, chief animal control officer, Connecticut Department of Agriculture, and whether you have received communications from him; the substance of each such communication, the dates thereof, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 11. State whether you have communicated with Charles DellaRocco, a Connecticut Department of Agriculture animal control officer and whether you have received communications from him; the dates thereof, the substance of each such 2 communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 12. State whether you have communicated with David Philip Mason regarding Plaintiff and her goats and whether you have received communications from him; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 13. State whether you have communicated with Julia Pemberton regarding Plaintiff and her goats and whether you have received communications from her; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 14. State whether you have communicated with Margaret O’Donnell regarding Plaintiff and her goats and whether you have received communications from 3 her; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 15. State whether you have communicated with David Philip Mason regarding Plaintiff and her goats and whether you have received communications from him; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: See the objection to interrogatory no. 12. 16. State whether you have communicated with Michael Thompson regarding Plaintiff and her goats and whether you have received communications from him; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 17. State whether you have communicated with Alice Smith, executive assistant to Redding First Selectman, regarding Plaintiff and her goats and whether you have received communications from her; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, 4 ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 18. State whether you have communicated with Plaintiff Nancy Burton and whether you have received communications from her; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that the information sought can be obtained with equal or geater facility by the plaintiff herself. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 19. State whether you have attended gatherings with others at the Redding Town Hall (remotely or in person) concerning Plaintiff and her goats and if so state the dates when such gatherings took place and identify all who attended. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 20. State whether you have communicated with Susan Winters and whether you have received communications from her; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further 5 objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 21. State whether you have communicated with judicial and clerical personnel at the Danbury Superior Court regarding Plaintiff, her litigation there and her goats and whether you have received communications from such personnel; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 22. State whether you have communicated with State Senator Will Haskell and whether you have received communications from him; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 23. State whether you have communicated with members of the news media regarding Plaintiff and her goats and whether you have received communications from him/her/them; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, 6 ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. 24. State whether you have communicated with Lia Albo regarding Plaintiff and her goats and whether you have received communications from her; the dates thereof, the substance of each such communication, the modes of communication (i.e., via telephone, email, remote (i.e., over “ZOOM” and such technologies), in person, by mail. OBJECTION: The defendant objects to this interrogatory on the grounds that it is overly broad, unduly burdensome, vague, ambiguous and not reasonably calculated to lead to the discovery of admissible evidence. The defendant further objects to this interrogatory on the ground that it seeks information that is within the scope of the litigation privilege. The defendant further objects to this interrogatory insofar as it is duplicative of prior discovery served on the defendant. REQUESTS FOR PRODUCTION 1. In accordance with Practice Book Section 13-9 et seq., the defendant, Elinore Carmody, is directed to identify and provide Plaintiff with copies of all documents, records and materials of whatever kind and however stored which are responsive to Plaintiff’s Request for Interrogatories Nos. 9-24 as submitted simultaneously to her on this date. OBJECTION: See the objections to interrogatories nos. 9 through 24, above, which are incorporated herein by reference. 7 DEFENDANT, ELINORE CARMODY By_/s/ Philip T. Newbury, Jr. _________ Philip T. Newbury, Jr. Kristan M. Jakiela Howd & Ludorf, LLC 65 Wethersfield Avenue Hartford, CT 06114-1121 (860) 249-1361 (860) 249-7665 (Fax) Juris No.: 28228 E-mail: pnewbury@hl-law.com E-mail: kjakiela@hl-law.com 8 CERTIFICATION This is to certify that a copy of the foregoing Objections to Plaintiff’s Interrogatories and Requests for Production Dated February 23, 2022, was or will immediately be mailed or delivered electronically or non-electronically on April 22, 2022, to all parties and pro se parties of record and that written consent for electronic delivery was received from all attorneys and self-represented parties receiving electronic delivery. Nancy Burton Steven J. Stafstrom, Jr., Esquire 154 Highland Avenue Pullman & Comley, LLC Rowayton, CT 06853 850 Main Street, P.O. Box 7006 NancyBurtonCT@aol.com Bridgeport, CT 06601 sstafstrom@pullcom.com Kimberly Bosse, Esquire David B. Stanhill, Esquire James N. Tallberg, Esquire Michael D. Riseberg, Esquire Karsten & Tallberg, LLC Christine N. Parise, Esquire 500 Enterprise Drive, Suite 4B Rubin and Rudman, LLP Rocky Hill, CT 06067 53 State Street kbosse@kt-lawfirm.com Boston, MA 02109 jtallberg@kt-lawfirm.com dstanhill@rubinrudman.com mriseberg@rubinrudman.com cparise@rubinrudman.com Jonathan E. Harding, Esquire Matthew I. Levine, Esquire AG-Environment 165 Capitol Ave., 5th Floor Hartford, CT 06106 Jonathan.harding@ct.gov matthewlevine@ct.gov /s/ Philip T. Newbury, Jr.______________ Philip T. Newbury, Jr. 9