Party Discovery: MAREK, JACK v. TOWN OF WILTON

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                DOCKET NO.: FBT-CV22-6118696-S                :               SUPERIOR COURT

JACK MAREK PPA CAROLYN MAREK :                                J. D. OF FAIRFIELD

V.                                            :               AT BRIDGEPORT

TOWN OF WILTON, ET AL                         :               APRIL 28, 2024


                            MOTION TO COMPEL DEPOSITION

       The plaintiff, Jack Marek PPA Carolyn Romeos, hereby respectfully requests an order

from the Court compelling the defendant, Town of Wilton to produce Nicole Querze, the

defendant’s, Dean of Students at Middlebrook School; Celia Quieros, the defendant’s, Campus

Supervisor at Middlebrook School and Nancy Flaherty, the defendant’s School Nurse at

Middlebrook School, on or before May 10, 2024.


       Trial in this matter is scheduled for July 9, 2024. The defendant’s depositions were

noticed for April 11, 2024. They were marked off by the defendant. Defendant’s counsel stated

that he was unavailable, and that the plaintiff’s deposition was noticed prior to that of the

defendants, and that the plaintiff’s deposition needed to be completed before the depositions of

the defendants could go forward. The plaintiff’s deposition was re-noticed by the defendant for

April 25, 2024. The plaintiff’s deposition was subsequently marked off by the defendant because

defense counsel was on trial. The plaintiff needs to depose the aforementioned employees of the

defendant in order to respond to the Defendant’s motion for summary judgment. There are

continuing discovery disputes, and production of documents outlined along with the depositions

of the defendants are essential for the plaintiff to have sufficient evidence to appropriately

oppose the pending motion for summary judgment. The plaintiff will likely need to request an

additional motion for extension of time to respond to the summary judgment as none the

depositions have gone forward to date, and the plaintiff’s deposition has not been re-noticed by
the defendant. The plaintiff has re-noticed the aforementioned defendant depositions for May 1,

2024.


        Wherefore, the plaintiff requests that the Court enter an order requiring the defendant to

produce Nicole Querze, the defendant’s, Dean of Students at Middlebrook School; Celia

Quieros, the defendant’s, Campus Supervisor at Middlebrook School and Nancy Flaherty, the

defendant’s School Nurse at Middlebrook School, on or before May 10, 2024.




                                              THE PLAINTIFF,
                                              JACK MAREK PPA CAROLYN ROMEO


                                                     421989
                                              Christopher J. Flood
                                              The Flood Law Firm, LLC
                                              190 Washington Street
                                              Middletown, CT 06457
                                              Phone: 860-346-2695
                                              Juris No.: 433718
                                       CERTIFICATION

       I certify that a copy of this document was or will immediately be mailed or
delivered electronically or non-electronically on April 28, 2024 to all attorneys and self-
represented parties of record and to all parties who have not appeared in this matter and
that written consent for electronic delivery was received from all attorneys and self-
represented parties receiving electronic delivery.

Joshua Aaron Yahwak, Esquire
Garraty Cynthia M. Law Offices
P.O. Box 2903
Hartford, CT 06104
E-mail: jyahwak@travelers.com

Marilyn Frances Davidson, Esquire
Law Offices of A. Richard Mason
157 Church Street 19th Floor
New Haven, CT 06510
E-mail: officect@usaa.com


                                                 421989
                                          Christopher J. Flood