Motion,Ex Parte: THE CONNECTICUT NOVELTY CO D/B/A MALLOVES JEWELERS v. GRAICHEN, CHRISTINE

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                                DOCKET NO. MMX-CV23-5016264-S                             :   SUPERIOR COURT
                                                           :
 THE CONNECTICUT NOVELTY COMPANY                           :   JUDICIAL DISTRICT OF
 D/B/A MALLOVES JEWELERS,                                  :   MIDDLESEX
                                                           :
 VS.                                                       :   AT MIDDLETOWN
                                                           :
 CHRISTINE GRAICHEN                                        :   FEBRUARY 9, 2024

 PLAINTIFF’S MOTION TO QUASH AND MOTION FOR PROTECTIVE ORDER

       Plaintiff, The Connecticut Novelty Company D/B/A Malloves Jewelers (“Plaintiff”),

respectfully submits this Motion to Quash and Motion for Protective Order relating to

Defendant’s subpoena duces tecum dated January 23, 2024 and served on January 26, 2024.

       As more thoroughly laid out in Plaintiff’s Memorandum in Support, rather than

issue discovery in accordance with the Practice Book, Defendant instead served a subpoena

on Plaintiff on January 26, 2024 seeking categories of documents that are overly broad,

harassing, and fail to provide a reasonable time for compliance. This is a blatant attempt to

circumvent the safeguards of Practice Book Section 13-10. Since Defendant did not provide

Plaintiff with its rightful sixty (60) days within which to answer and/or object to discovery,

the Court should quash the subpoena and require Defendant to serve discovery in

accordance with the Practice Book.

       WHEREFORE Plaintiff respectfully moves that its Motion to Quash and Motion for

Protective Order be granted.




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                                               PLAINTIFF,
                                               THE CONNECTICUT NOVELTY
                                               COMPANY D/B/A MALLOVES
                                               JEWELERS



                                               By: /s/ Jonathan M. Shapiro____
                                                  Jonathan M. Shapiro
                                                  Aeton Law Partners LLP
                                                  311 Centerpoint Drive
                                                  Middletown, Connecticut 06457
                                                  Telephone: (860) 724-2160
                                                  Facsimile: (860) 724-2161
                                                  Email: jms@aetonlaw.com
                                                  Juris No. 433168




                            CERTIFICATION OF SERVICE

      I hereby certify that on February 9, 2024, a copy of the foregoing was sent via

electronic mail to the following attorneys of record:

Claire Howard, Esq.
Madsen & Prestley & Parenteau LLC
402 Asylum Street
Hartford, CT 06103
choward@mppjustice.com



                                                   /s/ Jonathan M. Shapiro____
                                                  Jonathan M. Shapiro




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