Order: BROWN, CYNTHIA, CONSERVATOR OF THE PERSON AND ESTA Et Al v. SAINT MARY'S HOSPITAL, INC. Et Al

• 
• 
• 
• 

						
                                
Preview
                                DOCKET NO.: UWY-CV21-6060768-S                        :       SUPERIOR COURT

CYNTHIA BROWN, CONSERVATOR                            :       J.D. OF WATERBURY
OF THE PERSON AND ESTATE OF
ELIZABETH STEWART,
CYNTHIA BROWN, INDIVIDUALLY,
AND EDWARD STEWART

VS.                                                   :       AT WATERBURY

SAINT MARY’S HOSPITAL, INC., ET AL                    :       SEPTEMBER 6, 2023

                       MOTION FOR ORDER OF COMPLIANCE

       The Plaintiffs hereby move the Court for an order for compliance because the Defendant,

Middle Connecticut Emergency Physicians, LLC, has failed to respond to the Plaintiffs’ Request

for Disclosure and Production directed to it on March 14, 2023, within the time specified by law.

Accordingly, the Plaintiffs move for:

       An order compelling compliance within 10 (ten) days of this motion;

       An entry of default; and/or,

       An award to the Plaintiff of the cost of this Motion, including a reasonable attorney's fee.

                                              PLAINTIFFS,



                                              By         /s/ 301934
                                                      Thomas P. Cella
                                                      Howard, Kohn, Sprague & FitzGerald
                                                      237 Buckingham Street
                                                      Hartford, CT 06106
                                                      ph: (860)525-3101
                                                      fax: (860)247-4201
                                                      tpc@hksflaw.com
                                     CERTIFICATION

      I hereby certify that this pleading complies with the requirements of Practice Book § 4-7
and a copy of the foregoing was mailed, U.S. Mail, postage prepaid, or electronically delivered
pursuant to Practice Book § 10-13 to all counsel and pro se parties of record who have given
written consent for electronic delivery, on the 6th day of September, 2023, as follows:

Michael Neubert, Esq.
Gretchen Randall, Esq.
Neubert, Pepe & Monteith, P.C.
195 Church Street, 13th Floor
New Haven, CT 06510
Mneubert@npmlaw.com
Grandall@npmlaw.com

Frederick J. Trotta, Esq.
Halloran & Sage, LLP
265 Church Street, 8th Floor
New Haven, CT 06510
trotta@halloransage.com
rooney@halloransage.com
valentino@halloransage.com
pangonyte@halloransage.com

                                             BY       /s/  301934
                                                     Thomas P. Cella




                                              2