Preview
DOCKET NO.: HHD-CV20-6127575-S : SUPERIOR COURT
DOMINIC SANSONE : J.D. OF HARTFORD
:
v. AT HARTFORD
:
RALSTON G. LENNON & J. B. OCTOBER 26, 2023
HUNT TRANSPORT, INC.
433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000
MOTION FOR PERMISSION TO SERVE NON-STANDARD
REQUESTS FOR PRODUCTION
The plaintiff, Dominic Giovanni Sansone, respectfully requests permission to serve non-
standard discovery on the defendant, J.B. Hunt Transport, Inc., because the standard forms are
insufficient in the present matter.
The plaintiff suffered serious injuries including an exacerbation of posttraumatic stress
GROUP
Brooke A. Goff, Esq. Juris #
Juris # 438704
disorder, exacerbation of a prior back injury, headaches, and emotional distress on October 10,
psc
law TJC•ESQ,
2018, when the plaintiff’s vehicle struck a drive shaft that had fallen out of a tractor trailer
GOFF
owned and maintained by the defendant, J.B. Hunt Transport, Inc.
The plaintiff served both defendants with standard interrogatories and requests for
production on June 5, 2020. On November 5, 2020, the defendants, Ralston G. Lennon and J.B.
Hunt Transport, Inc., complied with the discovery requests. However, the standard forms were
insufficient because there exists a great deal of information about the cause of the drive shaft
malfunction, the maintenance and inspection of the truck, and company policies and procedures
that are not attainable via standard interrogatories in this matter.
Practice Book § 13-6(c) provides in relevant part that “the standard interrogatories are
intended to address discovery needs in most cases in which their use is mandated, but they do not
preclude any party from moving for permission to serve such additional discovery as may be
necessary in any particular case.”
-1 -
In the present matter, the plaintiff has alleged negligence against an individual driver and
the trucking company, J.B. Hunt Transport, Inc.. The trucking industry is highly regulated and
there exists a great deal of information that was not produced via standard discovery.
Additionally, the nature of the case is unusual and requires a great deal of additional evidence
and information no obtainable via the standard forms.
433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000
For all of the foregoing reasons, the plaintiff moves for permission to serve the defendant
with nonstandard interrogatories and requests for production, which are attached hereto as
Exhibit A.
THE PLAINTIFF,
GROUP
Brooke A. Goff, Esq. Juris #
By _______/s/ 435415_______
Juris # 438704
Elisabeth M Swanson, Esq.
psc
law
GOFF LAW GROUP LLC
TJC•ESQ,
433 S. Main Street, Suite 328
West Hartford, 06110
GOFF
Telephone: 203-399-0000
Juris #: 438704
-2 -
CERTIFICATION
I hereby certify that a copy of the above was mailed or electronically delivered on the
above date to all counsel and self-represented parties of record and that written consent for
electronic delivery was received from all counsel and self-represented parties of record who were
433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000
electronically served.
Ellen Costello, Esq.
Delsole & Delsole
46 South Whittlesey Avenue
Wallingford, CT 06492
EllenC@delsoledelsole.com
GROUP
Brooke A. Goff, Esq. Juris #
Juris # 438704
psc
law TJC•ESQ,
By ______/s/435415______
GOFF
Elisabeth M Swanson, Esq.
GOFF LAW GROUP LLC
-3 -
TJC•ESQ, psc
GOFF law GROUP
Brooke A. Goff, Esq. Juris #
433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000
Juris # 438704
-4 -
Exhibit A
DOCKET NO.: HHD-CV20-6127575-S : SUPERIOR COURT
DOMINIC SANSONE : J.D. OF HARTFORD
:
v. AT HARTFORD
:
RALSTON G. LENNON & J. B. OCTOBER 26, 2023
HUNT TRANSPORT, INC.
433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000
NON-STANDARD REQUESTS FOR PRODUCTION
The plaintiff, pursuant to § 13-9 of the Connecticut Practice Book, requests the
defendant, J.B. HUNT TRANSPORT, INC., produce for inspection and/or copying all of the
following designated documents which are in the possession, custody, or control of the
defendant, J.B. Hunt Transport, Inc. This request is deemed continuing, pursuant to § 13-5 of the
Connecticut Practice Book, so as to require prompt supplemental answers if the defendants
discover new material or information between the time productions are made and the time of
trial.
GROUP
Brooke A. Goff, Esq. Juris #
1. The pre-trip inspection report created prior to the subject trip on October 10,
Juris # 438704
psc
law
2018;
TJC•ESQ,
2. The pre-trip inspection report form in place on October 10, 2018;
GOFF
3. The maintenance records for the subject truck from October 10, 2017 through
November 10, 2018;
4. Any and all video from inside the truck at or around the time the drive shaft fell out
on October 10, 2018;
5. Any and all photos of the subject truck from October 10, 2018, through November
1, 2018;
6. Any and all investigative reports regarding the subject incident including the
preventability analysis;
7. All internal policies and procedures regarding vehicle inspections; and
-1 -
8. The complete OSHA file regarding the subject incident to the extent it exists.
THE PLAINTIFF,
By _______/s/ 435415_______
Elisabeth M Swanson, Esq.
GOFF LAW GROUP LLC
433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000
433 S. Main Street, Suite 328
West Hartford, 06110
Telephone: 203-399-0000
Juris #: 438704
GROUP
Brooke A. Goff, Esq. Juris #
Juris # 438704
psc
law TJC•ESQ,
GOFF
-2 -
CERTIFICATION
I hereby certify that a copy of the above was mailed or electronically delivered on the
above date to all counsel and self-represented parties of record and that written consent for
electronic delivery was received from all counsel and self-represented parties of record who were
electronically served.
433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000
Ellen Costello, Esq.
Delsole & Delsole
46 South Whittlesey Avenue
Wallingford, CT 06492
EllenC@delsoledelsole.com
By ______/s/435415______
GROUP
Brooke A. Goff, Esq. Juris #
Elisabeth M Swanson, Esq.
Juris # 438704
GOFF LAW GROUP LLC
psc
law TJC•ESQ,
GOFF
-3 -
Preview
DOCKET NO.: HHD-CV20-6127575-S : SUPERIOR COURT DOMINIC SANSONE : J.D. OF HARTFORD : v. AT HARTFORD : RALSTON G. LENNON & J. B. OCTOBER 26, 2023 HUNT TRANSPORT, INC. 433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000 MOTION FOR PERMISSION TO SERVE NON-STANDARD REQUESTS FOR PRODUCTION The plaintiff, Dominic Giovanni Sansone, respectfully requests permission to serve non- standard discovery on the defendant, J.B. Hunt Transport, Inc., because the standard forms are insufficient in the present matter. The plaintiff suffered serious injuries including an exacerbation of posttraumatic stress GROUP Brooke A. Goff, Esq. Juris # Juris # 438704 disorder, exacerbation of a prior back injury, headaches, and emotional distress on October 10, psc law TJC•ESQ, 2018, when the plaintiff’s vehicle struck a drive shaft that had fallen out of a tractor trailer GOFF owned and maintained by the defendant, J.B. Hunt Transport, Inc. The plaintiff served both defendants with standard interrogatories and requests for production on June 5, 2020. On November 5, 2020, the defendants, Ralston G. Lennon and J.B. Hunt Transport, Inc., complied with the discovery requests. However, the standard forms were insufficient because there exists a great deal of information about the cause of the drive shaft malfunction, the maintenance and inspection of the truck, and company policies and procedures that are not attainable via standard interrogatories in this matter. Practice Book § 13-6(c) provides in relevant part that “the standard interrogatories are intended to address discovery needs in most cases in which their use is mandated, but they do not preclude any party from moving for permission to serve such additional discovery as may be necessary in any particular case.” -1 - In the present matter, the plaintiff has alleged negligence against an individual driver and the trucking company, J.B. Hunt Transport, Inc.. The trucking industry is highly regulated and there exists a great deal of information that was not produced via standard discovery. Additionally, the nature of the case is unusual and requires a great deal of additional evidence and information no obtainable via the standard forms. 433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000 For all of the foregoing reasons, the plaintiff moves for permission to serve the defendant with nonstandard interrogatories and requests for production, which are attached hereto as Exhibit A. THE PLAINTIFF, GROUP Brooke A. Goff, Esq. Juris # By _______/s/ 435415_______ Juris # 438704 Elisabeth M Swanson, Esq. psc law GOFF LAW GROUP LLC TJC•ESQ, 433 S. Main Street, Suite 328 West Hartford, 06110 GOFF Telephone: 203-399-0000 Juris #: 438704 -2 - CERTIFICATION I hereby certify that a copy of the above was mailed or electronically delivered on the above date to all counsel and self-represented parties of record and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were 433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000 electronically served. Ellen Costello, Esq. Delsole & Delsole 46 South Whittlesey Avenue Wallingford, CT 06492 EllenC@delsoledelsole.com GROUP Brooke A. Goff, Esq. Juris # Juris # 438704 psc law TJC•ESQ, By ______/s/435415______ GOFF Elisabeth M Swanson, Esq. GOFF LAW GROUP LLC -3 - TJC•ESQ, psc GOFF law GROUP Brooke A. Goff, Esq. Juris # 433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000 Juris # 438704 -4 - Exhibit A DOCKET NO.: HHD-CV20-6127575-S : SUPERIOR COURT DOMINIC SANSONE : J.D. OF HARTFORD : v. AT HARTFORD : RALSTON G. LENNON & J. B. OCTOBER 26, 2023 HUNT TRANSPORT, INC. 433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000 NON-STANDARD REQUESTS FOR PRODUCTION The plaintiff, pursuant to § 13-9 of the Connecticut Practice Book, requests the defendant, J.B. HUNT TRANSPORT, INC., produce for inspection and/or copying all of the following designated documents which are in the possession, custody, or control of the defendant, J.B. Hunt Transport, Inc. This request is deemed continuing, pursuant to § 13-5 of the Connecticut Practice Book, so as to require prompt supplemental answers if the defendants discover new material or information between the time productions are made and the time of trial. GROUP Brooke A. Goff, Esq. Juris # 1. The pre-trip inspection report created prior to the subject trip on October 10, Juris # 438704 psc law 2018; TJC•ESQ, 2. The pre-trip inspection report form in place on October 10, 2018; GOFF 3. The maintenance records for the subject truck from October 10, 2017 through November 10, 2018; 4. Any and all video from inside the truck at or around the time the drive shaft fell out on October 10, 2018; 5. Any and all photos of the subject truck from October 10, 2018, through November 1, 2018; 6. Any and all investigative reports regarding the subject incident including the preventability analysis; 7. All internal policies and procedures regarding vehicle inspections; and -1 - 8. The complete OSHA file regarding the subject incident to the extent it exists. THE PLAINTIFF, By _______/s/ 435415_______ Elisabeth M Swanson, Esq. GOFF LAW GROUP LLC 433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000 433 S. Main Street, Suite 328 West Hartford, 06110 Telephone: 203-399-0000 Juris #: 438704 GROUP Brooke A. Goff, Esq. Juris # Juris # 438704 psc law TJC•ESQ, GOFF -2 - CERTIFICATION I hereby certify that a copy of the above was mailed or electronically delivered on the above date to all counsel and self-represented parties of record and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were electronically served. 433 S MAIN STREET SUITE 328, WEST HARTFORD, CONNECTICUT 06110 • 203-399-0000 Ellen Costello, Esq. Delsole & Delsole 46 South Whittlesey Avenue Wallingford, CT 06492 EllenC@delsoledelsole.com By ______/s/435415______ GROUP Brooke A. Goff, Esq. Juris # Elisabeth M Swanson, Esq. Juris # 438704 GOFF LAW GROUP LLC psc law TJC•ESQ, GOFF -3 -