Motion-Secondary: SANSONE, DOMINIC v. LENNON, RALSTON G Et Al

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                                DOCKET NO. HHD-CV-20-6127575-S : SUPERIOR COURT

DOMINIC SANSONE : J.D. OF HARTFORD

vs. 4 AT HARTFORD

RALSTON G. LENNON and
J.B. HUNT TRANSPORT, INC. 3 JULY 26, 2022

DEFENDANT’ S REPLY TO PLAINTIFF’ S OBJECTION TO DEFENDANT!’ S
MOTION FOR ORDER OF COMPLIANCE DATED JULY 12, 2022

The Defendant’s in the above matter hereby file the
following reply to plaintiff’s objection to defendant’s motion

for order of compliance dated July 12, 2022.

Procedural and Discovery History

Plaintiff seems to take the position that since they filed
an in lieu of Appearance for the plaintiff on August 18, 2021,
they have no responsibility for outstanding discovery prior to

that date.

However, the undersigned immediately contacted Attorney
Tiffany Sabato, and sent her a copy of the letter sent to prior
plaintiffs’ counsel which indicated the undersigned would be
handling the file and that Attorney Michael DelSole had

retired.Additionally, we discussed a trial continuance. Attorney
Sabato indicated she was getting married and needed additional
time. On 12/10/21 the defendants filed a Motion for Order of
Compliance and on 2/14/22 the Court ordered full compliance by

3/7/22.

On 3/4/22 the plaintiff apparently emailed Attorney
DelSole who had retired from the firm a link to some
compliance. On 3/7/22 the plaintiff filed supplemental
compliance of 2019 and 2020 Tax Returns, again sent only to

Attorney DelSole and not the undersigned.

Additionally, on 3/7/22 the plaintiff attached subpoena’s
to out of state providers that did not include a Commission to
take out of state deposition via subpoena. To date, no records
have been provided from Catholic Family Health in Missouri and
Dr. Jeffrey Schaberg of Signature Orthopedics in Missouri. It
is unknown if the providers even responded to plaintiff’s

worthless out of state subpoenas.The undersigned warned plaintiff's counsel that the
subpoena’s were not valid, but she wished to proceed in that

manner.

On 3/23/22 the undersigned’s office reached out to
plaintiff for their 3/4/22 compliance and what was sent to
Attorney DelSole was re-sent to the undersigned which did not

include any tax returns, nor were complete records provided.

On 6/7/22 the plaintiff again filed supplemental
compliance of random records many of which were duplicates that
had already been provided and never advised the undersigned of
the status of the subpoena’s or the outstanding records and
bills previously requested. To date the following records

remain outstanding:

de J. Mark Hall PhD records for 1/21/21, 2/2/21 and all
medical and billing records from 4/13/22 to present;

2. VA in Connecticut- the only records provided were
10/11/18 and an MRI report of 8/12/20. We have no
records from 2019 and nothing from February 2022 to
present;

8. Melinda Smith PCP at VA;

4, Alex Rodriguez Vocational Rehab VA;© nr Aw

10.
11.

12.

13.

14.

15.

16.

17.
18.

Pharmacy Records VA;

Acupuncture Clinic VA;

Manchester Memorial Hospital;

May Chiropractic;

Hartford Hospital Pain Center, we were not provided
the intake and questionnaire forms, or medical
records for 8/15-8/16/2019, 10/24/19 and 11/22/19 and
a readable billing statement;

Anna Perrone MD;

West Hartford Acupuncture need billing record for
3/12/21;

Medical Marijuana License. All records from the
provider that authorized him to have a medical
marijuana license;

VA Missouri;

All Military Records;

Dr Gheith in Missouri who apparently provided reason
for him to file for disability;

Select Physical Therapy in Missouri. Records provided
indicate he had 11 visits but only 4 dates of
treatment were provided;

Chiropractic Missouri;

Jefferson Barracks VA hospital in Missouri.Missing Employment Records

1. Bradley Morris Agency, plaintiff now indicates in her
objection that this company has no records. Since
plaintiff testified repeatedly in his deposition
about his use of this agency then plaintiff should
provide a statement from them as part of his
compliance under oath.

2s UPS no records provided

Tax Returns

All Tax Returns from 2015 through 2018 and 2021 have not
been provided contrary to what the plaintiff stated in her
objection they were not provided in their 3/4/22 compliance. In
fact, the plaintiff’s compliance of 3/7/22 of 2019 and 2020 tax

returns, were the only tax returns provided to date.

As to plaintiff's service animal we withdrew our request
per plaintiff’s representations, and it was not included in the

motion to compel.CONCLUSION

The defendants have given the plaintiff plenty of time to
comply with the Court’s orders. There is a trial date scheduled
for September 22, 2022, and the defendant cannot complete the
plaintiff’s deposition until discovery has been completely
provided as they relate directly to his current alleged

injuries.

THE DEFENDANTS,

ELLEN M. COSTELLO
DEL SOLE & DEL SOLE, LLP
JURIS NO. 101674

ELLENC@DELSOLEDELSOLE . COM

BCERTIFICATION

I hereby certify that a copy of the foregoing has been mailed
postage prepaid and/or sent via electronic mail and/or via
facsimile on this date to the following:

Tiffany Lynn Sabato, Esquire
Goff Law Group LLC

433 South Main Street, Suite 328
West Hartford, CT 06110

Ellen M. Costello