On September 27, 2021 a
Request,Application
was filed
involving a dispute between
Cheryl Chiari-Mccarthy,
and
Edahol Independent Distributor, Inc.,
Edgardo Hoyos,
for V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
in the District Court of New Haven County.
Preview
DOCKET NO.: NNH-CV21-6117634-S : SUPERIOR COURT
CHERYL CHIARI-MCCARTHY 3 J.D. OF NEW HAVEN
V. AT NEW HAVEN
EDGARDO HOYOS, ET AL. 3 FEBRUARY 10, 2023
JOINT REQUEST TO CONTINUE TRIAL
NOW COMES the Defendants, EDGARDO HOYOS and EDAHOL INDEPENDENT
DISTRIBUTOR, INC., who respectfully request this Honorable Court to continue the trial,
currently scheduled for April 4, 2023, to September of 2023, or to a date this Honorable Court
deems appropriate. In support of this motion, the defendants respectfully state the following:
1.
That the deposition of the Plaintiff, Cheryl Chiari-McCarthy, has not been taken by
counsel for the undersigned defendants;
That Plaintiff continues to disclose supplemental records;
That the undersigned counsel needs time to investigate and become familiar with the
allegations made by the Plaintiff, the discovery completed to date, the possibility of
experts and the damages alleged;
That the undersigned counsel may need to depose plaintiff's disclosed medical providers;
That under the circumstances this matter is not ripe for trial;
That the parties have requested J-ADR (see Pleading No. 127.00); and
That Plaintiffs counsel has assented to this motion.
WHEREFORE, the Defendants respectfully requests that this Honorable Court continue
the trial to September of 2023 or a time this Honorable Court deems appropriate.The Defendants,
Edgardo Hoyos and Edahol Independent
Distributor, Inc.,
By Their Attorneys,
/s/ Melissa M. Modzelewski
Melissa M. Modzelewski, Esq. 443084
/s/ Patrick J. Markey
Patrick J. Markey, Esq. 435739
Markey Barrett, PC
360 Bloomfield Avenue, Suite 301
Windsor, CT 06095
Telephone: (860) 607-3265
Facsimile: (413) 273-7361
mmodzelewski@markeybarrett.com
pmarkey@markeybarrett.com
CERTIFICATE OF SERVICE
I, Patrick J. Markey, Esquire, hereby certify that a copy of the above was mailed or
electronically delivered on February 10, 2023, to all counsel and pro se parties of record as follows:
Via Email: rjweber@rjwlawyer.com
& svollero@rjwlawyer.com
Weber & Rubano, LLC
R.J. Weber, III, Esq.
401 Center Street
Wallingford, CT 06492
/S/ Patrick J. Markey
Patrick J. Markey, Esquire
Document Filed Date
February 10, 2023
Case Filing Date
September 27, 2021
Category
V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
DOCKET NO.: NNH-CV21-6117634-S : SUPERIOR COURT CHERYL CHIARI-MCCARTHY 3 J.D. OF NEW HAVEN V. AT NEW HAVEN EDGARDO HOYOS, ET AL. 3 FEBRUARY 10, 2023 JOINT REQUEST TO CONTINUE TRIAL NOW COMES the Defendants, EDGARDO HOYOS and EDAHOL INDEPENDENT DISTRIBUTOR, INC., who respectfully request this Honorable Court to continue the trial, currently scheduled for April 4, 2023, to September of 2023, or to a date this Honorable Court deems appropriate. In support of this motion, the defendants respectfully state the following: 1. That the deposition of the Plaintiff, Cheryl Chiari-McCarthy, has not been taken by counsel for the undersigned defendants; That Plaintiff continues to disclose supplemental records; That the undersigned counsel needs time to investigate and become familiar with the allegations made by the Plaintiff, the discovery completed to date, the possibility of experts and the damages alleged; That the undersigned counsel may need to depose plaintiff's disclosed medical providers; That under the circumstances this matter is not ripe for trial; That the parties have requested J-ADR (see Pleading No. 127.00); and That Plaintiffs counsel has assented to this motion. WHEREFORE, the Defendants respectfully requests that this Honorable Court continue the trial to September of 2023 or a time this Honorable Court deems appropriate.The Defendants, Edgardo Hoyos and Edahol Independent Distributor, Inc., By Their Attorneys, /s/ Melissa M. Modzelewski Melissa M. Modzelewski, Esq. 443084 /s/ Patrick J. Markey Patrick J. Markey, Esq. 435739 Markey Barrett, PC 360 Bloomfield Avenue, Suite 301 Windsor, CT 06095 Telephone: (860) 607-3265 Facsimile: (413) 273-7361 mmodzelewski@markeybarrett.com pmarkey@markeybarrett.com CERTIFICATE OF SERVICE I, Patrick J. Markey, Esquire, hereby certify that a copy of the above was mailed or electronically delivered on February 10, 2023, to all counsel and pro se parties of record as follows: Via Email: rjweber@rjwlawyer.com & svollero@rjwlawyer.com Weber & Rubano, LLC R.J. Weber, III, Esq. 401 Center Street Wallingford, CT 06492 /S/ Patrick J. Markey Patrick J. Markey, Esquire