On September 27, 2021 a
MEMORANDUM IN SUPPORT OF MOTION for Continuance of Trial
was filed
involving a dispute between
Cheryl Chiari-Mccarthy,
and
Edahol Independent Distributor, Inc.,
Edgardo Hoyos,
for V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
in the District Court of New Haven County.
Preview
DOCKET NO.: NNH-CV-21-6117634-S : SUPERIOR COURT
CHERYL CHIARI-MCCARTHY : J.D. OF NEW HAVEN
v. : AT NEW HAVEN
EDGARDO HOYOS, et al. : FEBRUARY 28, 2024
MEMORANDUM IN SUPPORT OF MOTION TO CONTINUE TRIAL
NOW COMES the defendants, Edgardo Hoyos and Edahol Independent Distributor, Inc.
(“Edahol”) and respectfully request that trial in the above styled action be continued. In support
of their motion, the defendants state as follows:
1. Jury selection in this case is scheduled to commence on March 19, 2024.
2. In February 2024, the plaintiff provided draft supplemental answers to
interrogatories and authorizations for additional medical records to the defendants.
3. The defendants are in the process of collecting medical records pursuant to those
authorizations.
4. Once it has collected all those medical records, which relate to prior treatment of
plaintiff’s right knee, which she claims was injured in the accident in issue, they will need to
send them to their expert so that he can supplement his opinion regarding the plaintiff’s injuries.
5. It will take time beyond March 19, 2024, to assemble all the records and have
them reviewed by defendants’ expert.
WHEREFORE, for the foregoing reasons, the defendants respectfully request that this
court continue trial, which is currently scheduled for March 19, 2024, for at least three months.
Respectfully submitted,
THE DEFENDANTS,
EDGARDO HOYOS AND EDAHOL
INDEPDENT DISTRIBUTOR, INC.
By Their Attorney,
/s/ Patrick J. Markey_______
Patrick J. Markey, Esq.
Markey Barrett, P.C.
360 Bloomfield Avenue, Suite 301
Windsor, CT 06095
Phone (860) 607-3265
Fax (413) 273-7361
Juris No.: 435739
E-mail: pmarkey@markeybarrett.com
CERTIFICATE OF SERVICE
I, Patrick J. Markey, Esq., hereby certify that on this 29th day of February 2024, I served a
copy of the above upon the parties in this action by mailing or electronic delivery to counsel of
record:
rjweber@RJWLAYER.com
svollero@RJWLAYER.com
rsmiley@rjwlawyer.com
R.J. Weber, III, Esq.
401 Center Street
Wallingford, CT 06492
Subscribed under the penalties of perjury.
/s/ Patrick J. Markey
Patrick J. Markey, Esq.
Juris No.: 435739
PJM/jc M992774
Document Filed Date
February 29, 2024
Case Filing Date
September 27, 2021
Category
V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
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DOCKET NO.: NNH-CV-21-6117634-S : SUPERIOR COURT CHERYL CHIARI-MCCARTHY : J.D. OF NEW HAVEN v. : AT NEW HAVEN EDGARDO HOYOS, et al. : FEBRUARY 28, 2024 MEMORANDUM IN SUPPORT OF MOTION TO CONTINUE TRIAL NOW COMES the defendants, Edgardo Hoyos and Edahol Independent Distributor, Inc. (“Edahol”) and respectfully request that trial in the above styled action be continued. In support of their motion, the defendants state as follows: 1. Jury selection in this case is scheduled to commence on March 19, 2024. 2. In February 2024, the plaintiff provided draft supplemental answers to interrogatories and authorizations for additional medical records to the defendants. 3. The defendants are in the process of collecting medical records pursuant to those authorizations. 4. Once it has collected all those medical records, which relate to prior treatment of plaintiff’s right knee, which she claims was injured in the accident in issue, they will need to send them to their expert so that he can supplement his opinion regarding the plaintiff’s injuries. 5. It will take time beyond March 19, 2024, to assemble all the records and have them reviewed by defendants’ expert. WHEREFORE, for the foregoing reasons, the defendants respectfully request that this court continue trial, which is currently scheduled for March 19, 2024, for at least three months. Respectfully submitted, THE DEFENDANTS, EDGARDO HOYOS AND EDAHOL INDEPDENT DISTRIBUTOR, INC. By Their Attorney, /s/ Patrick J. Markey_______ Patrick J. Markey, Esq. Markey Barrett, P.C. 360 Bloomfield Avenue, Suite 301 Windsor, CT 06095 Phone (860) 607-3265 Fax (413) 273-7361 Juris No.: 435739 E-mail: pmarkey@markeybarrett.com CERTIFICATE OF SERVICE I, Patrick J. Markey, Esq., hereby certify that on this 29th day of February 2024, I served a copy of the above upon the parties in this action by mailing or electronic delivery to counsel of record: rjweber@RJWLAYER.com svollero@RJWLAYER.com rsmiley@rjwlawyer.com R.J. Weber, III, Esq. 401 Center Street Wallingford, CT 06492 Subscribed under the penalties of perjury. /s/ Patrick J. Markey Patrick J. Markey, Esq. Juris No.: 435739 PJM/jc M992774