On May 05, 2020 a
Party Discovery
was filed
involving a dispute between
Dominic Sansone,
and
J. B. Hunt Transport, Inc.,
Ralston G Lennon,
for V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
in the District Court of Hartford County.
Preview
DOCKET NO.: HHD-CV20-6127575-S SUPERIOR COURT
DOMINIC SANSONE J.D. OF HARTFORD
VS. AT HARTFORD
RALSTON G. LENNON AND J.B. HUNT FEBRUARY 8, 2021
TRANSPORT, INC.
SUPPLEMENTAL MOTION FOR PERMISSION TO FILE
ADDITIONAL INTERROGATORIES UPON THE DEFENDANT’S
ono
aa RALSTON G. LENNON AND J.B. HUNT TRANSPORT, INC.
Ro
os
an
ga The Plaintiff in the above-entitled matter, pursuant to Practice Book
2a
oa
Section 13-6(b) requests permission to serve an additional production request
ns 8
Bb upon the defendants. In the above matter, plaintiff claims injuries from an
as
Os
8 incident which occurred when his motor vehicle struck a driveshaft which had
fallen off of the defendant's vehicle. Standard motor vehicle discovery does not
Na
seek maintenance and repair records of a vehicle involved in an accident. In
light of the fact that plaintiff has claimed that the driveshaft fell of the defendant's
vehicle, it is important that plaintiff obtain the maintenance and repair records of
the truck involved in the incident. Counsel did notice the deposition of the
plaintiff with a production request for said records but defense objected stating
that said request was beyond standard discovery.
Said request for production will seek maintenance and repair records as to
the truck which is the subject of the litigation. The request should not be
burdensome to the defendants and the plaintiff request that the court grant
plaintiff the permission to file additional discovery upon the defendants as
attached.
THE PLAINTIFF:
— _— __
BY_/s/303136
Jeffrey D. Lynch
Heo
aa Perkins & Associates
Be 30 Lucy Street
os
Woodbridge, CT 06525
ga
£2 Tel. No: 203-380-1556
rg Juris No: 421154
Ns
ms
B65
as
Os CERTIFICATION
Q8
| hereby certify that on this 8" day of February 2021, a copy of the foregoing was
8
Na mailed, postage prepaid to:
Michael P. Del Sole, Esq.
DELSOLE & DELSOLE LLP
46 SOUTH WHITTLESEY AVE
WALLINGFORD, CT 06492
__ _—
_!s/303136,
Jeffrey D. Lynch
Commissioner of the Superior Court
DOCKET NO.: HHD-CV20-6127575-S SUPERIOR COURT
DOMINIC SANSONE J.D. OF HARTFORD
VS. AT HARTFORD
RALSTON G LENNON, ET AL FEBRUARY 8, 2021
REQUEST FOR PRODUCTION
Records of inspection or maintenance logs for the truck, with VIN
1JJV462W78L240470, which is the subject of this litigation for a period of six
Ho
~ 8
38 months preceding the incident date.
aS
oa
gs
gs Repair records for said truck, with VIN 1JJV462W78L240470, which is the
oa
£s subject of this litigation, for a period of six months preceding the incident date.
81g
ns
me
BS Safety inspection records for said truck, with VIN 1JJV462W78L240470, which
Os is the subject of this litigation, for a period of six months preceding the incident
O08
date.
3 List of all drivers for said truck, with VIN 1JJV462W78L240470, which is the
na subject of this litigation, for a period of six months preceding the incident date.
4?
Defendant Lennon’s truck log for October 10, 2018 and previous days he
drove the truck, with VIN 1JJV462W78L240470, which is the subject of this
litigation.
THE PLAINTIFF
/s/303136
By: Jeffrey D. Lynch
Perkins & Associates
30 Lucy Street
Woodbridge, CT 06525
a eer ee
Tel. No.: 397-1283
Juris No.: 421154
He
28
ga
eet
PS
Os
ea
Es
£a
1a
ns
ms
Bo
Se
Os
Q8
Na
Document Filed Date
February 08, 2021
Case Filing Date
May 05, 2020
Category
V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
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DOCKET NO.: HHD-CV20-6127575-S SUPERIOR COURT DOMINIC SANSONE J.D. OF HARTFORD VS. AT HARTFORD RALSTON G. LENNON AND J.B. HUNT FEBRUARY 8, 2021 TRANSPORT, INC. SUPPLEMENTAL MOTION FOR PERMISSION TO FILE ADDITIONAL INTERROGATORIES UPON THE DEFENDANT’S ono aa RALSTON G. LENNON AND J.B. HUNT TRANSPORT, INC. Ro os an ga The Plaintiff in the above-entitled matter, pursuant to Practice Book 2a oa Section 13-6(b) requests permission to serve an additional production request ns 8 Bb upon the defendants. In the above matter, plaintiff claims injuries from an as Os 8 incident which occurred when his motor vehicle struck a driveshaft which had fallen off of the defendant's vehicle. Standard motor vehicle discovery does not Na seek maintenance and repair records of a vehicle involved in an accident. In light of the fact that plaintiff has claimed that the driveshaft fell of the defendant's vehicle, it is important that plaintiff obtain the maintenance and repair records of the truck involved in the incident. Counsel did notice the deposition of the plaintiff with a production request for said records but defense objected stating that said request was beyond standard discovery. Said request for production will seek maintenance and repair records as to the truck which is the subject of the litigation. The request should not be burdensome to the defendants and the plaintiff request that the court grant plaintiff the permission to file additional discovery upon the defendants as attached. THE PLAINTIFF: — _— __ BY_/s/303136 Jeffrey D. Lynch Heo aa Perkins & Associates Be 30 Lucy Street os Woodbridge, CT 06525 ga £2 Tel. No: 203-380-1556 rg Juris No: 421154 Ns ms B65 as Os CERTIFICATION Q8 | hereby certify that on this 8" day of February 2021, a copy of the foregoing was 8 Na mailed, postage prepaid to: Michael P. Del Sole, Esq. DELSOLE & DELSOLE LLP 46 SOUTH WHITTLESEY AVE WALLINGFORD, CT 06492 __ _— _!s/303136, Jeffrey D. Lynch Commissioner of the Superior Court DOCKET NO.: HHD-CV20-6127575-S SUPERIOR COURT DOMINIC SANSONE J.D. OF HARTFORD VS. AT HARTFORD RALSTON G LENNON, ET AL FEBRUARY 8, 2021 REQUEST FOR PRODUCTION Records of inspection or maintenance logs for the truck, with VIN 1JJV462W78L240470, which is the subject of this litigation for a period of six Ho ~ 8 38 months preceding the incident date. aS oa gs gs Repair records for said truck, with VIN 1JJV462W78L240470, which is the oa £s subject of this litigation, for a period of six months preceding the incident date. 81g ns me BS Safety inspection records for said truck, with VIN 1JJV462W78L240470, which Os is the subject of this litigation, for a period of six months preceding the incident O08 date. 3 List of all drivers for said truck, with VIN 1JJV462W78L240470, which is the na subject of this litigation, for a period of six months preceding the incident date. 4? Defendant Lennon’s truck log for October 10, 2018 and previous days he drove the truck, with VIN 1JJV462W78L240470, which is the subject of this litigation. THE PLAINTIFF /s/303136 By: Jeffrey D. Lynch Perkins & Associates 30 Lucy Street Woodbridge, CT 06525 a eer ee Tel. No.: 397-1283 Juris No.: 421154 He 28 ga eet PS Os ea Es £a 1a ns ms Bo Se Os Q8 Na