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  • BURTON,NANCY v. MASON,DAVID PHILIPM00 - Misc - Injunction document preview
  • BURTON,NANCY v. MASON,DAVID PHILIPM00 - Misc - Injunction document preview
  • BURTON,NANCY v. MASON,DAVID PHILIPM00 - Misc - Injunction document preview
  • BURTON,NANCY v. MASON,DAVID PHILIPM00 - Misc - Injunction document preview
  • BURTON,NANCY v. MASON,DAVID PHILIPM00 - Misc - Injunction document preview
  • BURTON,NANCY v. MASON,DAVID PHILIPM00 - Misc - Injunction document preview
						
                                

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NO: (X06) UWY-CV21-5028294-S SUPERIOR COURT NANCY BURTON : COMPLEX LITIGATION DOCKET v. : AT WATERBURY DAVID PHILIP MASON, ET AL : AUGUST 11, 2022 OBJECTION TO PLAINTIFF’S MOTION FOR FURTHER EXTENSION OF TIME TO RESPOND TO DISCOVERY (#361.00) The defendants, Elinore Carmody and Dennis Gibbons, hereby object to the plaintiff’s motion for a further extension of time to “respond and object” to the defendants’ interrogatories and requests for production served on March 29, 2022. This is the plaintiff’s third motion for extension of time. (See Dkt. # 345.00 and # 350.00). The responses were due on July 27, 2022.1 The defendants object to any further extension of time to object to the requests, as her objections have been waived since they were not filed by the deadline of July 27, 2022. As to the responses, the defendants request an order that the plaintiff submit her responses forthwith, and that no further extensions will be granted. WHEREFORE, it is respectfully requested that the objection to plaintiff’s motion for a further extension of time be sustained. 1 The plaintiff makes a misrepresentation in her motion that she had an extension of time to August 10, 2022, to respond to the discovery requests. The court’s order, which was entered by agreement at the status conference on July 13, 2022, was that she had an extension to July 27, 2022. (See Dkt. # 350.00 and # 350.10). DEFENDANTS, ELINORE CARMODY AND DENNIS GIBBONS By_/s/ Philip T. Newbury, Jr. _________ Philip T. Newbury, Jr. \ 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 2 CERTIFICATION This is to certify that a copy of the foregoing Objection to Plaintiff’s Motion for Further Extension of Time to Respond to Discovery (#361.00) was or will immediately be mailed or delivered electronically or non-electronically on August 11, 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., Esq. 154 Highland Ave. 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 James N. Tallberg, Esquire Michael D. Riseberg, Esquire Karsten & Tallberg, LLC Christine Parise, Esquire 500 Enterprise Drive, Suite 4 David B. Stanhill, Esquire Rocky Hill, CT 06067 Rubin and Rudman, LLP kbosse@kt-lawfirm.com 53 State Street jtallberg@kt-lawfirm.com Boston, MA 02109 mriseberg@rubinrudman.com Jonathan E. Harding, Esq. cparise@rubinrudman.com Matthew I Levine, Esq. dstanhill@rubinrudman.com AG-Environment 165 Capitol Ave., 5th Floor Hartford, CT 06106 Jonathan.harding@ct.gov Matthew.levine@ct.gov _/s/ Philip T. Newbury, Jr. ___________ Philip T. Newbury, Jr. 3