Party Statement: BURTON,NANCY v. MASON,DAVID PHILIP

• 
• 
• 
• 

						
                                
Preview
                                DOCKET NO.         (X06) UWY -CV21-5028294-S

                  NANCY BURTON                                                                     SUPERIOR COURT
                           Plaintiff
                                                                                                   COMPLEX LITIGATION
                                             v.                                                    DOCKET
                                                                                                   AT WATERBURY
                  DAVID PHILIP MASON, Et Al.
                           Defendants                                                              OCTOBER 25, 2022


                                               AFFIDAVIT OF JONATHAN E. HARDING
                         GOOD FAITH AFFIDAVIT PURSUANT TO CT PRACTICE BOOK§                                           13-lO(i)


                           I, Jonathan E. Harding, do hereby depose and swear:

                       1.  I am over eighteen (18) years of age and believe in the obligation of an oath.

                       2.   I am a counsel of record for the Defendants,         State of Connecticut Department of

                           Agriculture ("Department"), Bryan P.          Hurlburt,   Commissioner of Agriculture

                           ("Commissioner"), and Charles DellaRocco,             State Animal    Control Officer ("State

                           Defendants").

                       3.   On March 21, 2022, the Court granted an application for subpoena for Jeremiah Dunn,

                           Chief State Animal Control Officer.         (Entry No.    320.10.)

                       4.   Contained in that subpoena were requests for documents that State Defendants believe

                           are objectionable and privileged.

                       5.  At the Court's suggestion, the undersigned affiant filed an Objection to Requests for

                           Production (Entry No.      357.00) to address this conflict,      on July 25, 2022.

                       6.   The Objection was filed by State Defendants and addressed to the Plaintiff, Nancy

                           Burton.




                                                                            1
                       7.  The undersigned      affiant sent no   less than eight e-mails to the Plaintiff to      schedule a time

                           to conference on narrowing the        scope of discovery     temporally    and to  exclude attorney-

                           client and deliberative privilege      documents to resolve this      objection.

                       8.  The undersigned affiant never received a substantive response on scheduling                  a

                           conference    on this  discovery   issue.

                       9.  No   conference was     ever held on this issue.




                                                                                                   rding, Esq.
                                                                                    sistant     orney   General
                                                                                            e of the Attorney    General
                                                                                 Counsel for:    State Defendants


                           Subscribed and sworn to before me by           Jonathan E.   Harding on this     25th day of October

                  2022.




                                                                                 Kaelah   Smith
                                                                                 Commissioner of the       Superior Court
                                                                                 Juris No.   442725




                                                                            2