On April 21, 2021 a
Order
was filed
involving a dispute between
Nancy Burton,
and
Bryan Hurlburt,Commissioner,Ct Dept Of Agriculture,
Building Department, Town Of Redding Ct,
Charles Dellarocco, Animal Control Officer,Ct Dept. Of Agriculture,
David Philip Mason,
Dennis Gibbon,
Department Of Agriculture,State Of Connecticut,
Elinore Carmody,
Health Department,Town Of Redding Ct Town Hall,Redding,
Julia Pemberton First Selectman,Town Or Redding,
Mark O'Donnell Chief Of Police,
Police Department,Town Of Redding Ct Town Hall,
Susan Winters,
Town Of Redding,Connecticut C O Town Clerk,
for M00 - Misc - Injunction
in the District Court of New Haven County.
Preview
X06-UWY-CV-21-5028294 S
NANCY BURTON SUPERIOR COURT
V. JUDICIAL DISTRICT OF :
WATERBURY
DAVID PHILIP MASON
ETAL. MARCH 28, 2023
MOTION FOR REARGUMENT
Plaintiff moves for reargument of the decision of the trial court (Bellis, J.) granting
Defendants Carmody and Gibbons’ motions for judgment in part.
The motion is premised upon a non-substantive assertion of facts with no bearing
whatsoever on the merits of this case as well as a mischaracterization of the facts of
this case.
This case was commenced after the said defendants harassed and intimidated
Plaintiff with death threats and other serious harm and circulated false, malicious and
deliberate statements concerning Plaintiff and her goats, even to the extent of
haranguing Superior Court personnel and judges by name in an attempt to influence
judicial decisionmaking against Plaintiff. The record is replete with these facts, as well
as the conclusion of then-state veterinarian Mary Jane Lis, DVM, to dismiss the
complaint by Carmody and others against Plaintiff in 2018, finding each goat individually
in good health and well cared for. No valid evidence was ever presented to the contrary.
THIS IS A PRACTICE BOOK SECTION 11-11 MOTION.
Thus, when the State began its investigation in the fall of 2020, they were aware that
Plaintiff's goats were healthy, well cared for and flourishing under the devoted care of
Plaintiff.
Plaintiff attaches hereto a photograph she took of a group of her goats peacefully
grazing on leaves and pasture grasses in a state of contentment at the very moment the
State began its investigation. Obviously the state blinded itself to the truth to pursue this
harassing case.. Yet Defendant Carmody perverted the facts and flooded the
community and social and news media with false and ignorant claims that the mere fact
that the goats ate maple leaves was proof that they were malnourished and underfed by
Plaintiff.
Plaintiff attaches hereto and incorporates herein a motion for extension of time nunc
pro tunc to move for reargument.
THE PLA FF
AP
Za
‘on
Cross 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 March 28,
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
cparise@ribinrudman.com
dstanhill@rubinrudman.com
Matthew Levine, Esq.
Jonathan Harding, Esq.
231 Capitol Ave.
Hartford CT 06106
Matthew.Levine@ct.go
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@hl-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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Document Filed Date
March 28, 2023
Case Filing Date
April 21, 2021
Category
M00 - Misc - Injunction
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in New Haven County
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X06-UWY-CV-21-5028294 S NANCY BURTON SUPERIOR COURT V. JUDICIAL DISTRICT OF : WATERBURY DAVID PHILIP MASON ETAL. MARCH 28, 2023 MOTION FOR REARGUMENT Plaintiff moves for reargument of the decision of the trial court (Bellis, J.) granting Defendants Carmody and Gibbons’ motions for judgment in part. The motion is premised upon a non-substantive assertion of facts with no bearing whatsoever on the merits of this case as well as a mischaracterization of the facts of this case. This case was commenced after the said defendants harassed and intimidated Plaintiff with death threats and other serious harm and circulated false, malicious and deliberate statements concerning Plaintiff and her goats, even to the extent of haranguing Superior Court personnel and judges by name in an attempt to influence judicial decisionmaking against Plaintiff. The record is replete with these facts, as well as the conclusion of then-state veterinarian Mary Jane Lis, DVM, to dismiss the complaint by Carmody and others against Plaintiff in 2018, finding each goat individually in good health and well cared for. No valid evidence was ever presented to the contrary. THIS IS A PRACTICE BOOK SECTION 11-11 MOTION. Thus, when the State began its investigation in the fall of 2020, they were aware that Plaintiff's goats were healthy, well cared for and flourishing under the devoted care of Plaintiff. Plaintiff attaches hereto a photograph she took of a group of her goats peacefully grazing on leaves and pasture grasses in a state of contentment at the very moment the State began its investigation. Obviously the state blinded itself to the truth to pursue this harassing case.. Yet Defendant Carmody perverted the facts and flooded the community and social and news media with false and ignorant claims that the mere fact that the goats ate maple leaves was proof that they were malnourished and underfed by Plaintiff. Plaintiff attaches hereto and incorporates herein a motion for extension of time nunc pro tunc to move for reargument. THE PLA FF AP Za ‘on Cross 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 March 28, 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 cparise@ribinrudman.com dstanhill@rubinrudman.com Matthew Levine, Esq. Jonathan Harding, Esq. 231 Capitol Ave. Hartford CT 06106 Matthew.Levine@ct.go 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@hl-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 —— oi / Eg pt ae seg Lis ry ees BS baiea a4 = a a a ry) Va ie Beets bf Fe Le us “S Ma ee a ae ee res e So bikes rane’ cea ra ne a x —, ae 2 a} as a a es os rae fis OE ae ‘ a poe Matas Ese!ey ic ee wi ——, othof feeD Eeee ie) etd an een Paes oe — eo ee | oe 3 Peers EL a 5 ec oe ky or 4 Cv an o am Sal cb ate wy Ys aS aa Mand ig a Fa /( 20ORO re po sfw"ae }- Cros Phi fe 2 ding C by