Motion,Ex Parte: BURTON,NANCY v. MASON,DAVID PHILIP

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                UWY-CV-5028TK              :SUPERIOR COURT

NANCY BURTON               :JUDICIAL DISTRICT OF WATERBURY

       V.                  :COMPLEX LITIGATION

DAVID PHILIP MASON         :OCTOBER 31, 2023
                                                                  Y’S
                       PLAINTIFF’S OPPOSITION TO DEFENDANT CARMOD
                               MOTION FOR SUMMARY JUDGMENT
                                                  sition to Defendant Carmody’s
   Plaintiff Nancy Burton herewith files her oppo
                                                 First Count (Defamation) of the
Motion for Summary Judgment wit h regard to the
                                             Book §17-44 et seq.
Substitute Fifth Amended Complaint. Practice
                                              follows:
   The First Count alleges in Paragraph 45 as
                                                      ly and publicly circulated and
   Defendant Carmody and Ms. Winters have wide
                                                    g plaintiff, accusing her falsely
published false and defamatory sc reeds targetin
inter alia of ‘using the law to brea’ k the law’;
                                                  although plaintiff timely demanded
                                                  ns, neither Carmody nor Winters
 retraction of the false and offensive publicatio
 complieParagraph 46¢ alleges:
                                                  of the cease and desist order, said
    Prior to the Zoning Commission’s issuance
                                                   harassing plaintiff and interfering
 Mason, Carmody, Gibbons and others took to
                                                 rehome most of her goats in the
 with her ability to carry out her objective to
                                                ing publication of defamatory
 following ways, among others . ..e. Instigat
                                                published on online media channels
 falsehoods about plaintiff and the goats as
                                                ty and malice and discourage goat
 operated by Susan Winters to incite negativi
 adoptions.
                                                        reference herein her    Affidavit
    Plaintiff attaches hereto and incorporates by
                                                    m of La’ w in Opposition    to Motion
 with Exhibit List and Exhibits and Memorandu
                                                              e is no genuine   issue of
 for Summary J udgment. Based on the foregoing, ther
                                                                        ment    as a matter
                      requires a trial and Plaintiff is entitled to udg
                                                                     j
  material fact that
  of law.
NANCY BURTON
THE PLAINTIFF
                    —



147 Cross Highway
Redding CT 06896
Tel. 203-928-3952
NancyBurtonCT@aol.com
CERTIFICATION
This is to certify that a copy of the foregoing Motion for Summary Judgment was
or will be immediately be delivered electronically on or before October 31, 2023
to the following, being counsel of record to all parties of record:

Philip T. Newbury, Jr.
Howd & Ludorf, LLC
100 Great Meadow Road, Suite 201
Wethersfield CT 06109
pnewbury@hl-law.com

Kimberly Bosse, Esq.
James N. Tallberg, Esq.
Karsten & Tallberg, LLC
500 Enterprise Drive, Suite 4
Rocky Hill CT 06067
kbosse@ktlawfirm.com
jtallberg@kt-lawfirm.com

Steven J. Stafstrom, Jr., Esq.
Pullman & Comley, LLC
850 Main Street, P.O. Box 7006
Bridgeport CT 06601
 stafstrom@pullcom.com


                                         AA