Motion-Secondary: BURTON,NANCY v. MASON,DAVID PHILIP

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                                X06-UWY-CV-21-5028294 S
NANCY BURTON                                        SUPERIOR COURT
         V.                                         JUDICIAL DISTRICT OF
                                                    WATERBURY
DAVID PHILIP MASON
 ETAL.                                              APRIL 17, 2023


  PLAINTIFF’S REPLY TO DEFENDANTS’ OBJECTIONS TO MOTION FOR STAY




   Plaintiff replies to State Defendants’ and the Carmody/Gibbons Defendants’
objections to her Motion for Stay dated April 12, 2023 seeking an “IMMEDIATE”
(emphasis added) stay of these proceedings effective through May 1, 2023.
    Plaintiff faces a brief deadline of April 27 by which to file her Appellate Court brief, as
to which the Appellate Court has indicated it will not extend the date further.
   State Defendants reference Plaintiff's motion for extension of time to file her
appellate brief in the Appellate Court dated March 13, 2023.
    Unfortunately, although that motion expresses a spirit of optimism regarding her
vision, Plaintiff's vision has deteriorated significantly since March 13, 2023 and the new
eyeglasses she obtained are virtuaslly worthless and do not obviate chronic blurring and
other related issues as Plaintiff had anticipated as regards her near vision. Plaintiff is no
longer blind in one eye, but eyestrain from reading and writing are painful and
oppressive and probably detrimental to her recovery. Plaintiff is under continuing
medical care.
    This condition translates to a very slow pace of progress on the brief and does not
allow ffor time to adequately reply to the present objection.
   The interests of justice and fair play argue for granting of the motion. Defendants
remain free to file responsive pleadings to advance their interests in this matter.
THE PLAINTIFF   a
OO:
J asa      ee
       drton
       Toss Highway
Redding CT 06896
Tel. 203-313-1510
NancyBurtonCT@aol.com
CERTIFICATION
This is to certify that a copy of the foregoing was delivered electronically on April 17,,
2023 to all counsel of record as below:

Michael D. Riseberg, Esq.
Christine N. Parise, Esq.
Daniel B. Stanhill, Esq. Rubin and Rudman LLP
53 State Street, 15!" Floor
Boston MA 02109
Tel. 617-330-7000
mriseberg@rubinrudman.com
 parise@ribinrudman.com
dstanhill@rubinrudman.com

Matthew Levine, Esq!
Jonathan Harding, Esq.
231 Capitol Ave.
Hartford CT 06106
Matthew.Levine@ct.gov
Jonathan.Harding@ct.gov

James N. Tallberg, Esq.
Kimberly A. Bosse, Esq.
Karsten & Tallberg, LLC
500 Enterprise Drive Suite 4B
Rocky Hill CT 006067
Tel. 860-233-5600
jtallberg@kt-lawfirm.com
kbosse@kt-lawfirm.com

Philip T. Newbury, Jr., Esq.
Howd & Ludorf, LLC
65 Wethersfield Ave.
Hartford CT 06114-1121
Tel. 860-249-1361
pnewbury@hi-law.com

Steven Stafstrom, Esq.                     Alexander W. Ahrens, Esq
Pullman Comley, LLC                        Melick & Porter, LLP
850 Main Street                            900 Main Street South
Bridgeport T 06601                         Southbury CT 06488
SStafstrom@pullcom.com                     aahrens@melicklaw.com
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