On October 24, 2023 a
Order
was filed
involving a dispute between
Jesus Diaz-Latorre,
and
Angela Marie Lontoc,
for V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
in the District Court of Fairfield County.
Preview
D.N. FST-CV 23-6063721-S SUPERIOR COURT
JESUS DIAZ-LATORRE J.D. OF STAMFORD/NORWALK
Vv. AT STAMFORD
ANGELA MARIE LONTOC MARCH 13, 2024
MOTION FOR ORDER OF COMPLIANCE
The Defendant, Angela Marie Lontoc, respectfully moves this court to set a date within
fourteen (14) days of the granting of this motion by which the Plaintiff, Jesus Diaz-Latorre, must
respond to Defendant’s Interrogatories and Request for Production or otherwise face sanctions
including the preclusion of all medical records and bills not already disclosed pursuant to
Practice Book Section 13-14(b)(4). See Martinv. Brown, Superior Court, judicial district of New
Haven, Docket No. NNH-CV23-6132477 (November 14, 2023, Stewart, J.) (Order Attached as
Exhibit 1). Defendant served upon the Plaintiff, through their counsel, written requests for
answers to standard Interrogatories and Requests for Production, Practice Book Forms 202 and
205 respectively on November 14, 2023. Said service was made in accordance with Practice
Book Sections 13-6(c) and 13-9(b). Therefore, Plaintiff had until January 16, 2024, to respond.
The January 16, 2024, deadline has passed, but to date Defendant has not received Plaintiff’s
compliance with standard discovery.
WHEREFORE pursuant to Practice Book Section 13-14, Defendant moves the court to
set a date within fourteen (14) days of the ruling on this motion by which the Plaintiff must
ORAL ARGUMENT IS NOT REQUESTED
TESTIMONY IS NOT REQUIRED
comply with Defendant’s Interrogatory and Production Requests or face sanctions including the
preclusion of discovery not already disclosed.
DEFENDANT,
ANGELA MARIE LONTOC
By — /s/437412 Ho
KurtJ. Y oung, Jr., Esq.
Ryan Ryan Deluca LLP
1000 Lafayette Blvd., Suite 800
Bridgeport, CT 06604
Juris No. 438500
Phone: 203-549-6650
EXHIBIT 1
ORDER 438580
DOCKET NO: NNHCV236132477S. SUPERIOR COURT
MARTIN, TALKEYSHA JUDICIAL DISTRICT
OF NEW HAVEN
AT NEW HAVEN
BROWN, DIO DAMIEN
Et Al
11/14/2023
ORDER
10/12/2023 111.00 MOTION FOR SANCTIONS ~ PB SEC 13-4 (EXPERT)
The foregoing, having been considered
by the Court, is hereby
ORDER: GRANTED
Tie RR Nae SANE 6 SNY COEEY IR CTS COE SO 107.10 and 108.10. The court finds
that the sanction of Practice Book Section 13-14 and proportional
to the discovery
lapses here. Therefore,
efor the cour order that he plat
evidenceor regarding medical records or bills that were not produced pnor to the date of this
order, November 14, 2023.
438580
Judge: ELIZABETH
JANE STEWART
This document
may be ot verified and has the same Sacanreee
and stamas
Becedires
ondGeneral Statutes and C:
Connecticut
more information. see Section
fechnical Standards (https./jud
ct gow’
LE of the Stateof
Section 4-4,
pservcest sundurds rely schon $1-|-193¢ of the
NNHCV236132477S = 11/14/2023 Page
1 of 1
CERTIFICATE OF SERVICE
I certify that a copy of this document will immediately be mailed or delivered
electronically on March 13, 2024, to all attorneys and self-represented parties of record and that
written consent for electronic delivery was received from all attorneys and self-represented
parties receiving electronic delivery.
Name and address of each party and attomey receiving this document:
Peter Baez, Esq.
Ventura Law
2160 Main Street
Suite 2B
Bridgeport, CT 06606
Attorney for the plaintiff:
pbaez@vrslaw.com; cheryl@venturalaw.com
—---+! (s/437412 a
KurtJ. Y oung, Jr., Esq.
Document Filed Date
March 13, 2024
Case Filing Date
October 24, 2023
Category
V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
D.N. FST-CV 23-6063721-S SUPERIOR COURT JESUS DIAZ-LATORRE J.D. OF STAMFORD/NORWALK Vv. AT STAMFORD ANGELA MARIE LONTOC MARCH 13, 2024 MOTION FOR ORDER OF COMPLIANCE The Defendant, Angela Marie Lontoc, respectfully moves this court to set a date within fourteen (14) days of the granting of this motion by which the Plaintiff, Jesus Diaz-Latorre, must respond to Defendant’s Interrogatories and Request for Production or otherwise face sanctions including the preclusion of all medical records and bills not already disclosed pursuant to Practice Book Section 13-14(b)(4). See Martinv. Brown, Superior Court, judicial district of New Haven, Docket No. NNH-CV23-6132477 (November 14, 2023, Stewart, J.) (Order Attached as Exhibit 1). Defendant served upon the Plaintiff, through their counsel, written requests for answers to standard Interrogatories and Requests for Production, Practice Book Forms 202 and 205 respectively on November 14, 2023. Said service was made in accordance with Practice Book Sections 13-6(c) and 13-9(b). Therefore, Plaintiff had until January 16, 2024, to respond. The January 16, 2024, deadline has passed, but to date Defendant has not received Plaintiff’s compliance with standard discovery. WHEREFORE pursuant to Practice Book Section 13-14, Defendant moves the court to set a date within fourteen (14) days of the ruling on this motion by which the Plaintiff must ORAL ARGUMENT IS NOT REQUESTED TESTIMONY IS NOT REQUIRED comply with Defendant’s Interrogatory and Production Requests or face sanctions including the preclusion of discovery not already disclosed. DEFENDANT, ANGELA MARIE LONTOC By — /s/437412 Ho KurtJ. Y oung, Jr., Esq. Ryan Ryan Deluca LLP 1000 Lafayette Blvd., Suite 800 Bridgeport, CT 06604 Juris No. 438500 Phone: 203-549-6650 EXHIBIT 1 ORDER 438580 DOCKET NO: NNHCV236132477S. SUPERIOR COURT MARTIN, TALKEYSHA JUDICIAL DISTRICT OF NEW HAVEN AT NEW HAVEN BROWN, DIO DAMIEN Et Al 11/14/2023 ORDER 10/12/2023 111.00 MOTION FOR SANCTIONS ~ PB SEC 13-4 (EXPERT) The foregoing, having been considered by the Court, is hereby ORDER: GRANTED Tie RR Nae SANE 6 SNY COEEY IR CTS COE SO 107.10 and 108.10. The court finds that the sanction of Practice Book Section 13-14 and proportional to the discovery lapses here. Therefore, efor the cour order that he plat evidenceor regarding medical records or bills that were not produced pnor to the date of this order, November 14, 2023. 438580 Judge: ELIZABETH JANE STEWART This document may be ot verified and has the same Sacanreee and stamas Becedires ondGeneral Statutes and C: Connecticut more information. see Section fechnical Standards (https./jud ct gow’ LE of the Stateof Section 4-4, pservcest sundurds rely schon $1-|-193¢ of the NNHCV236132477S = 11/14/2023 Page 1 of 1 CERTIFICATE OF SERVICE I certify that a copy of this document will immediately be mailed or delivered electronically on March 13, 2024, to all attorneys and self-represented parties of record and that written consent for electronic delivery was received from all attorneys and self-represented parties receiving electronic delivery. Name and address of each party and attomey receiving this document: Peter Baez, Esq. Ventura Law 2160 Main Street Suite 2B Bridgeport, CT 06606 Attorney for the plaintiff: pbaez@vrslaw.com; cheryl@venturalaw.com —---+! (s/437412 a KurtJ. Y oung, Jr., Esq.