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DOCKET NUMBER: FBT-CV22-6119243-S SUPERIOR COURT
SOLEDAD NUNEZ JUDICIAL DISTRICT OF
BRIDGEPORT
VS. AT BRIDGEPORT
GWENDOLYN BROWN-WHITE, ET AL JUNE 10, 2024
NOTICE OF RESPONSES AND OBJECTIONS TO PLAINTIFF’S 5/16/24 REQUESTS FOR
ADMISSION
Pursuant to Connecticut Practice Book §13-23, the defendant, Gwendolyn Brown-
White, hereby objects and/or responds to the Plaintiff's 5/16/24 Requests for Admission
(attached hereto), as follows:
Objections as to # 1 through 6; 8 through 15; and 17
Denied as to #7 and 16.
DEFENDANT,
GWENDOLYN BROWN-WHITE
By /s/ Kristen S. Greene, Esq., Juris #413524
Kristen S. Greene, Esq., Juris #413524
kgreene@f lawct.com
Feldman, Perlstein & Greene, Esq.
10 Waterside Drive, Suite 303
Farmington, CT 06032
(860) 677-0551; (860) 677-1147 (fax)
Firm Juris No. 412715
Their Attorney
CERTIFICATION OF SERVICE
| hereby certify that a copy of the foregoing was mailed via first class mail, or
electronically delivered on June 10, 2024, to all counsel and pro se parties of record and that
written consent for electronic delivery was received from all counsel and pro se parties of
record who were electronically served:
Daniel Angelone, Esq.
daniel@angelonelaw.com
799 Silver Lane, 2"! Floor
Trumbull, CT 06611
/s/ Kristen S. Greene, Esq., Juris 413524
Kristen S. Greene, Esq.
\pgdct\FData (Feldman Data)\Common\WPDocs\CAU\Seaview Village - Soledad Nunez\Notice-responses and objections-RTA.wpd
No. FBT-CV22-6119243-S STATE OF CONNECTICUT
SUPERIOR COURT
SOLEDAD NUNEZ,
JUDICIAL DISTRICT OF FAIRFIELD
Plaintiff,
AT BRIDGEPORT
Vv.
GWENDOLYN BROWN-WHITE, et al., :
Defendants.
JUNE
10, 2024
DEFENDANT’S OBJECTIONS TO PLAINTIFF’S REQUEST FOR ADMISSIONS
Plaintiff, pursuant to Connecticut Practice Book §§ 13-22, 23, does hereby propound her
Request for Admissions upon the Defendant Gwendolyn Brown-White. Defendant (hereinafter
referred to from time to time as “you”) is requested and required to, within thirty (30) days from
the date of service, admit, deny or otherwise properly respond to the below Requests.
RE UESTS
1 Please admit that you wrote the emails identified in Paragraphs 24 through 26 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
2. Please admit that you wrote the emails identified in Paragraphs 30 through 32 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
3. Please admit that you wrote the email identified in Paragraphs 36 through 37 of the
Plaintiffs Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
4. Please admit that you wrote the email identified in Paragraphs 42 through 44 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
2
5. Please admit that you caused the public display and engaged in the acts as alleged in
Paragraphs 48 through 52 of Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
6. Please admit that you wrote the email identified in Paragraphs 57 through 58 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
7. Please admit that you created and published the Flyer which is attached to Plaintiff's
Operative Complain as Exhibit 1.
RESPONSE: Denied.
8 Please admit that you wrote the emails identified in Paragraphs 62 through 73 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
3
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
9. Please admit that you wrote the email identified in Paragraphs 77 through 78 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
10. Please admit that you wrote the emails identified in Paragraphs 83 through 86 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
11. Please admit that you wrote the email identified in Paragraphs 90 through 91 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. . . An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
12. Please admit that you wrote the email identified in Paragraphs 95 through 96 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
13. Please admit that you wrote the email identified in Paragraphs 100 through 101 of the
Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
5
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
14. Please admit that you wrote the email identified in Paragraphs 105 through 106 of
the Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
15. Please admit that you wrote the email identified in Paragraphs 110 through 111 of
the Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
16. Please admit that on July 30, 2022, you yelled at Plaintiff and charged at her as
described in Paragraph 115 of Plaintiff's Operative Complaint.
RESPONSE: Denied.
17. Please admit that you wrote the emails identified in Paragraphs 116 through 118 of
the Plaintiff's Operative Complaint.
RESPONSE: Objection. This request is vague and confusing; and seeks a response
to incomplete, alleged excerpts of documents, without attaching the true and
accurate document; and does not comply with the Connecticut Code of Evidence.
Section 10-1 of Code of Evidence provides: “To prove the content of a writing ...
the original writing ... must be admitted. ... An original of electronically stored
information includes evidence in the form of a printout...” Section 13-22 allows a
party to serve requests for admission, including admission of the genuineness of any
documents described in the request. Here, the plaintiff is referring to incomplete
portions of documents described in her complaint, but does not attach the actual
documents to her Complaint, or to these Requests for Admission. The Plaintiff
should be required to attach complete copies of documents to which she is referring
so that the plaintiff can admit or deny.
DEFENDANT,
GWENDOLYN BROWN-WHITE
By /s/ Kristen Schultze Greene, Esq. (413524)
Kristen Schultze Greene, Esq.
kristengreene@feldmanhickey.com
Feldman, Perlstein & Greene, LLC
10 Waterside Drive, Suite 303
Farmington, CT 06032
(860) 677-0551; (860) 677-1147 (fax)
Firm Juris No. 412715
Its Attorney
CERTIFICATION OF SERVICE
| hereby certify that a copy of the foregoing was mailed via first class mail, or
electronically delivered on June 10, 2024, to all counsel and pro se parties of record and
that written consent for electronic delivery was received from all counsel and pro se
parties of record who were electronically served:
Daniel Angelone, Esq.
daniel@angelonelaw.com
799 Silver Lane, 24 Floor
Trumbull, CT 06611
/s/ Kristen Schultze Greene, Esq. (413524)
Kristen Schultze Greene, Esq.
Related Content
in Fairfield County
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DOCKET NUMBER: FBT-CV22-6119243-S SUPERIOR COURT SOLEDAD NUNEZ JUDICIAL DISTRICT OF BRIDGEPORT VS. AT BRIDGEPORT GWENDOLYN BROWN-WHITE, ET AL JUNE 10, 2024 NOTICE OF RESPONSES AND OBJECTIONS TO PLAINTIFF’S 5/16/24 REQUESTS FOR ADMISSION Pursuant to Connecticut Practice Book §13-23, the defendant, Gwendolyn Brown- White, hereby objects and/or responds to the Plaintiff's 5/16/24 Requests for Admission (attached hereto), as follows: Objections as to # 1 through 6; 8 through 15; and 17 Denied as to #7 and 16. DEFENDANT, GWENDOLYN BROWN-WHITE By /s/ Kristen S. Greene, Esq., Juris #413524 Kristen S. Greene, Esq., Juris #413524 kgreene@f lawct.com Feldman, Perlstein & Greene, Esq. 10 Waterside Drive, Suite 303 Farmington, CT 06032 (860) 677-0551; (860) 677-1147 (fax) Firm Juris No. 412715 Their Attorney CERTIFICATION OF SERVICE | hereby certify that a copy of the foregoing was mailed via first class mail, or electronically delivered on June 10, 2024, to all counsel and pro se parties of record and that written consent for electronic delivery was received from all counsel and pro se parties of record who were electronically served: Daniel Angelone, Esq. daniel@angelonelaw.com 799 Silver Lane, 2"! Floor Trumbull, CT 06611 /s/ Kristen S. Greene, Esq., Juris 413524 Kristen S. Greene, Esq. \pgdct\FData (Feldman Data)\Common\WPDocs\CAU\Seaview Village - Soledad Nunez\Notice-responses and objections-RTA.wpd No. FBT-CV22-6119243-S STATE OF CONNECTICUT SUPERIOR COURT SOLEDAD NUNEZ, JUDICIAL DISTRICT OF FAIRFIELD Plaintiff, AT BRIDGEPORT Vv. GWENDOLYN BROWN-WHITE, et al., : Defendants. JUNE 10, 2024 DEFENDANT’S OBJECTIONS TO PLAINTIFF’S REQUEST FOR ADMISSIONS Plaintiff, pursuant to Connecticut Practice Book §§ 13-22, 23, does hereby propound her Request for Admissions upon the Defendant Gwendolyn Brown-White. Defendant (hereinafter referred to from time to time as “you”) is requested and required to, within thirty (30) days from the date of service, admit, deny or otherwise properly respond to the below Requests. RE UESTS 1 Please admit that you wrote the emails identified in Paragraphs 24 through 26 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 2. Please admit that you wrote the emails identified in Paragraphs 30 through 32 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 3. Please admit that you wrote the email identified in Paragraphs 36 through 37 of the Plaintiffs Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 4. Please admit that you wrote the email identified in Paragraphs 42 through 44 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 2 5. Please admit that you caused the public display and engaged in the acts as alleged in Paragraphs 48 through 52 of Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 6. Please admit that you wrote the email identified in Paragraphs 57 through 58 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 7. Please admit that you created and published the Flyer which is attached to Plaintiff's Operative Complain as Exhibit 1. RESPONSE: Denied. 8 Please admit that you wrote the emails identified in Paragraphs 62 through 73 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and 3 accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 9. Please admit that you wrote the email identified in Paragraphs 77 through 78 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 10. Please admit that you wrote the emails identified in Paragraphs 83 through 86 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 11. Please admit that you wrote the email identified in Paragraphs 90 through 91 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. . . An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 12. Please admit that you wrote the email identified in Paragraphs 95 through 96 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 13. Please admit that you wrote the email identified in Paragraphs 100 through 101 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a 5 party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 14. Please admit that you wrote the email identified in Paragraphs 105 through 106 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 15. Please admit that you wrote the email identified in Paragraphs 110 through 111 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. 16. Please admit that on July 30, 2022, you yelled at Plaintiff and charged at her as described in Paragraph 115 of Plaintiff's Operative Complaint. RESPONSE: Denied. 17. Please admit that you wrote the emails identified in Paragraphs 116 through 118 of the Plaintiff's Operative Complaint. RESPONSE: Objection. This request is vague and confusing; and seeks a response to incomplete, alleged excerpts of documents, without attaching the true and accurate document; and does not comply with the Connecticut Code of Evidence. Section 10-1 of Code of Evidence provides: “To prove the content of a writing ... the original writing ... must be admitted. ... An original of electronically stored information includes evidence in the form of a printout...” Section 13-22 allows a party to serve requests for admission, including admission of the genuineness of any documents described in the request. Here, the plaintiff is referring to incomplete portions of documents described in her complaint, but does not attach the actual documents to her Complaint, or to these Requests for Admission. The Plaintiff should be required to attach complete copies of documents to which she is referring so that the plaintiff can admit or deny. DEFENDANT, GWENDOLYN BROWN-WHITE By /s/ Kristen Schultze Greene, Esq. (413524) Kristen Schultze Greene, Esq. kristengreene@feldmanhickey.com Feldman, Perlstein & Greene, LLC 10 Waterside Drive, Suite 303 Farmington, CT 06032 (860) 677-0551; (860) 677-1147 (fax) Firm Juris No. 412715 Its Attorney CERTIFICATION OF SERVICE | hereby certify that a copy of the foregoing was mailed via first class mail, or electronically delivered on June 10, 2024, to all counsel and pro se parties of record and that written consent for electronic delivery was received from all counsel and pro se parties of record who were electronically served: Daniel Angelone, Esq. daniel@angelonelaw.com 799 Silver Lane, 24 Floor Trumbull, CT 06611 /s/ Kristen Schultze Greene, Esq. (413524) Kristen Schultze Greene, Esq.