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

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                                (X06) UWY-CV-21-5028294-S

NANCY BURTON                                      SUPERIOR COURT

                                                  JUDICIAL DISTRICT

              V.                                  OF WATERBURY

DAVID PHILIP MASON

 ETAL.                                            MAY 30, 2023



PLAINTIFF’S REPLY TO DEFENDANTS CARMODY AND GIBBONS’ OBJECTION

 TO PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO FILE TO FILE MOTIONS

                   FOR REARGUMENT NUNC PRO TUNC (#423.00)

   Plaintiff replies herewith to Defendants Carmody and Gibbons’ “Objection to

Plaintiff's Motion for Extension of Time to File Motions for Reargument Nunc Pro Tunc

(#423.00).” (“Objection”), as per Order of the Court (Bellis, J.) entered on April   12, 2023.

   The Objection (#439.00) was filed on April 20, 2023.

   Thereby, the Objection was filed out of compliance with the Order entered by the

Court (Bellis, J.) on April 12, 2023, which required that such Objection be filed on or

before April 19, 2023)

   Therefore, the Objection must be rejected and the underlying motion be granted as

regards these Defendants.

   Such an Order would be consistent with prior orders entered by the trial court in this

case penalizing Plaintiff for a late filing occasioned by inadvertence and/or the severe

close vision impairment Plaintiff has lately experienced, as she has documented in

motions filed with this Court.
Moreover, while Defendants’ counsel reported to the Court that he would file a

response as ordered by the Court, his response was to adopt arguments put forth by

Defendant Mason’s counsel’s #427.00 filing. Such arguments concerned only

Defendant Mason, whose filing did not address the dissimilar and unique circumstances

of Defendants Carmody and Gibbons and thus are the equivalent of not filing an

objection at all, thereby failing to comply with Judge Bellis’ order to their counsel to file

their own objection on or before April 19, 2023.

   For the foregoing reasons, Plaintiff's motion must be granted as to Defendants

Carmody and Gibbons.

                                                   THE PLAINTIFF

                                                     Fi 2
                                                   Nancy Burterr
                                                                      a

                                                   147 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 May 30,
2023 date 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, 15t Floor
Boston MA 02109
Tel. 617-330-7000
mriseberq@rubinrudman.com
  parise@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
jtallberq@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:      ullcom.com               aahrens@melicklaw.com


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