Order: BURTON,NANCY v. MASON,DAVID PHILIP

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                                X06-UWY-CV-21-5028294 S
NANCY BURTON                                      SUPERIOR COURT
         Vv.                                      JUDICIAL DISTRICT OF
                                                  WATERBURY
DAVID PHILIP MASON
 ETAL.                                            MARCH 28, 2023


    MOTION FOR EXTENSION OF TIME TO FILE MOTIONS FOR REARGUMENT
                                     NUNC PRO TUNC


    Plaintiff moves for an extension of time to file her motions for reargument nunc pro
tunc of the decision of the trial court (Bellis, J.) granting Defendants Carmody, Gibbons
and Mason’s motions for judgment.
   An extension of time nunc pro tunc is warranted in this matter.
    During the course of these proceedings, Plaintiff has suffered from a variety of
emergency and debilitating health conditions, including blindness in one eye, four
emergency eye surgeries, and most recently a sudden vascular condition causing
painful swelling and limiting mobility. Plaintiff has been put on a medical regime of a
variety of medications which cause extreme fatigue, nausea and general physical
distress.
    With her near-vision compromised, she is unable to carry our legal research and
writing without significant delay. Thus, although this filing may appear to be relatively
free of typographical and other errors, its production has been slow, painstaking and
laborious. Plaintiff is prone to severe eyestrain and headaches which limit her
productivity.
    The stresses of this and related litigation have recently been exacerbated when
recently, without prior notice or permission on her part, and in her absence, the Town of
Redding, a defendant herein, with others, willfully trespassed on Plaintiff's property,
caused property damage and carried out exceptionally harmful cutting of her mature
and majestic historic trees on false premises (Cross Highway, Plaintiff's place of
residence, is a municipally-designated scenic road where trees are protected by law
from such deliberate damage). As a consequence, Plaintiff has had to suspend all other
activities, including work on this litigation, to address this emergency. (The tree damage
was done, not in the course of a safety-related exercise, but simply to make it easier for
telephone company workers to install fiber optic cables. (The Redding Tree Warden
. confirmed that the damages trees are on Plaintiff's private property and not subject of
  any governmental right-of-way.)
   Given these unique circumstances, this motion should be granted and justice
thereby served.




                                           THE PLAINTIF        —

                                            fancy Burt
                                                         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  cubinrudman.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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