Order: RICE, JAMIE v. GRISWOLD, JACQUELYN

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                                DOCKET NO: TTD-CV23-6026826-S                             : SUPERIOR COURT

 JAMIE RICE                                                : J.D. OF TOLLAND

 V.                                                        : AT ROCKVILLE

 JACQUELYN GRISWOLD                                        : APRIL 26, 2024


                               MOTION TO COMPEL DEPOSITION

       Pursuant to Connecticut Practice Book Section 13-14, the defendant, JACQUELYN

GRISWOLD, hereby moves for an order compelling the plaintiff, JAMIE RICE, to appear for

her deposition on May, 16, 2024 or within 15 days thereafter. In support of this motion the

defendant submits the following:

       The defendant has noticed the deposition of the plaintiff on seven occasions since July

25, 2023. Multiple depositions were marked off by the defendant because the plaintiff failed to

provide complete standard discovery. The last deposition was confirmed with the plaintiff and

then marked off by the plaintiff because of an emergency. There was no other explanation

provided. The deposition is needed to avoid any potential prejudice of the defense in regard to

preparation and evaluation of the plaintiff’s claims.

       Wherefore, the defendant moves the Court to compel the plaintiff to appear for her

deposition on May 16, 2024 or within 15 days thereafter. The defendant further requests that if

the plaintiff fails to appear for her deposition within this time frame that a nonsuit be granted

against the plaintiff upon notification to the court of plaintiff’s failure to appear and be deposed.




                                                Hanks, Olsen & Sheehan
               538 Preston Avenue, Suite 305, Meriden, Connecticut 06450  (203) 427-2160  (866) 540-7599
                                                   The Defendants,
                                                   JACQUELYN GRISWOLD


                                             By:
                                                   John Maher, Esq.
                                                   Hanks, Olsen & Sheehan
                                                   538 Preston Avenue, Suite 305
                                                   Meriden, CT 06450
                                                   Tel: (203) 427-2160
                                                   Juris No.: 419471




                                 Hanks, Olsen & Sheehan
538 Preston Avenue, Suite 305, Meriden, Connecticut 06450  (203) 427-2160  (866) 540-7599
                                              CERTIFICATION



       I certify that a copy of this document was or will immediately be mailed or delivered

electronically or non-electronically on April 26, 2024, 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 or will immediately be electronically served.

       Name and address of each party and attorney that copy was or will immediately be mailed

or delivered to:


Emanuele R. Cicchiello, Esq.
Cicchiello & Cicchiello, LLP
364 Franklin Avenue
Hartford, CT 06114


Via Facsimile
US Legal Court Reporter


                                                                 ____________________________________
                                                                 John Maher, Esq.




                                                Hanks, Olsen & Sheehan
               538 Preston Avenue, Suite 305, Meriden, Connecticut 06450  (203) 427-2160  (866) 540-7599