On May 05, 2020 a
Motion-Secondary
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.
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DOCKET NO. HHD-CV-20-6127575-S: SUPERIOR COURT
DOMINIC SANSONE : J.D. OF HARTFORD
VS. : AT HARTFORD
RALSTON G. LENNON and
J.B. HUNT TRANSPORT, INC. : MAY 5, 2021
DEFENDANTS’ OBJECTION TO PLAINTIFF’S
SUPPLEMENTAL REQEUSTS FOR PRODUCTION
1. Records of inspection or maintenance logs for the truck,
with VIN 1JJV462W78L240470, which is the subject of this litigation
for a period of six months preceding the incident date.
OBJECTION: The defendant objects to this request because it is
overly broad in time. The vehicle in question is used on a daily
basis in the course of the defendant’s transportation business. It
is driven by any number of employees of the defendant. The defendant
is willing to produce records responsive to this request for the
month leading up to the date of this occurrence.
2. Repair records for said truck, with VIN 1JJV462W78L240470,
which is the subject of this litigation, for a period of six months
preceding the incident date.
OBJECTION: The defendant objects to this request because it is
overly broad in time. The vehicle in question is used on a daily
basis in the course of the defendant’s transportation business. It
is driven by any number of employees of the defendant. The defendant
is willing to produce records responsive to this request for the
month leading up to the date of this occurrence
3. Safety inspection records for said truck, with VIN
1JJV462W78L240470, which is the subject of this litigation, for a
period of six months preceding the incident date.
1
DEL SOLE & DEL SOLE, LLP - ATTORNEYS AT LAW
46 SOUTH WHITTLESEY AVENUE, WALLINGFORD, CT 06492-4102 - JURIS NO. 101674 - 203-785-8500
OBJECTION: The defendant objects to this request because it is
overly broad in time. The vehicle in question is used on a daily
basis in the course of the defendant’s transportation business. It
is driven by any number of employees of the defendant. The defendant
is willing to produce records responsive to this request for the
month leading up to the date of this occurrence
4. List of all drivers for said truck, with VIN
1JJV462W78L240470, which is the subject of this litigation, for a
period of six months preceding the incident date.
OBJECTION: This request is overbroad. The claim in this case is
that a driveshaft fell onto the roadway on the date of the incident.
The plaintiff is already requesting safety reports, inspection
repair and maintenance records. There is no legitimate need on the
part of the plaintiff to know who operated the vehicle at any time
during the six months preceding the occurrence.
5. Defendant Lennon’s truck log for October 10, 2018 and
previous days he drove the truck, with VIN 1JJV462W78L240470, which
is the subject this litigation.
OBJECTION: The defendant objects to this request as vague and
overbroad in time. The defendant has no objection to producing any
such records as may exist in the three week period preceding the
date of the accident.
THE DEFENDANTS,
RALSTON G. LENNON and
J.B. HUNT TRANSPORT, INC.
BY:__#102450_____________________
MICHAEL P. DEL SOLE
DEL SOLE & DEL SOLE, LLP
JURIS NO. 101674
2
DEL SOLE & DEL SOLE, LLP - ATTORNEYS AT LAW
46 SOUTH WHITTLESEY AVENUE, WALLINGFORD, CT 06492-4102 - JURIS NO. 101674 - 203-785-8500
CERTIFICATION
I hereby certify that this is a true and accurate copy of the
foregoing original which was transmitted via electronic filing to
the Clerk, Superior Court and mailed or electronically delivered on
May 5, 2021 to all counsel and pro se parties of record as follows:
Jeffrey Lynch, Esquire
Perkins & Associates
30 Lucy Street
Woodbridge, CT 06525
Louis A. Spadaccini, Esquire
Blackwell & Spadaccini, LLC
158 East Center Street
Manchester, CT 06040
__#102450________________________
Michael P. Del Sole
3
DEL SOLE & DEL SOLE, LLP - ATTORNEYS AT LAW
46 SOUTH WHITTLESEY AVENUE, WALLINGFORD, CT 06492-4102 - JURIS NO. 101674 - 203-785-8500
Document Filed Date
May 05, 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-CV-20-6127575-S: SUPERIOR COURT DOMINIC SANSONE : J.D. OF HARTFORD VS. : AT HARTFORD RALSTON G. LENNON and J.B. HUNT TRANSPORT, INC. : MAY 5, 2021 DEFENDANTS’ OBJECTION TO PLAINTIFF’S SUPPLEMENTAL REQEUSTS FOR PRODUCTION 1. Records of inspection or maintenance logs for the truck, with VIN 1JJV462W78L240470, which is the subject of this litigation for a period of six months preceding the incident date. OBJECTION: The defendant objects to this request because it is overly broad in time. The vehicle in question is used on a daily basis in the course of the defendant’s transportation business. It is driven by any number of employees of the defendant. The defendant is willing to produce records responsive to this request for the month leading up to the date of this occurrence. 2. Repair records for said truck, with VIN 1JJV462W78L240470, which is the subject of this litigation, for a period of six months preceding the incident date. OBJECTION: The defendant objects to this request because it is overly broad in time. The vehicle in question is used on a daily basis in the course of the defendant’s transportation business. It is driven by any number of employees of the defendant. The defendant is willing to produce records responsive to this request for the month leading up to the date of this occurrence 3. Safety inspection records for said truck, with VIN 1JJV462W78L240470, which is the subject of this litigation, for a period of six months preceding the incident date. 1 DEL SOLE & DEL SOLE, LLP - ATTORNEYS AT LAW 46 SOUTH WHITTLESEY AVENUE, WALLINGFORD, CT 06492-4102 - JURIS NO. 101674 - 203-785-8500 OBJECTION: The defendant objects to this request because it is overly broad in time. The vehicle in question is used on a daily basis in the course of the defendant’s transportation business. It is driven by any number of employees of the defendant. The defendant is willing to produce records responsive to this request for the month leading up to the date of this occurrence 4. List of all drivers for said truck, with VIN 1JJV462W78L240470, which is the subject of this litigation, for a period of six months preceding the incident date. OBJECTION: This request is overbroad. The claim in this case is that a driveshaft fell onto the roadway on the date of the incident. The plaintiff is already requesting safety reports, inspection repair and maintenance records. There is no legitimate need on the part of the plaintiff to know who operated the vehicle at any time during the six months preceding the occurrence. 5. Defendant Lennon’s truck log for October 10, 2018 and previous days he drove the truck, with VIN 1JJV462W78L240470, which is the subject this litigation. OBJECTION: The defendant objects to this request as vague and overbroad in time. The defendant has no objection to producing any such records as may exist in the three week period preceding the date of the accident. THE DEFENDANTS, RALSTON G. LENNON and J.B. HUNT TRANSPORT, INC. BY:__#102450_____________________ MICHAEL P. DEL SOLE DEL SOLE & DEL SOLE, LLP JURIS NO. 101674 2 DEL SOLE & DEL SOLE, LLP - ATTORNEYS AT LAW 46 SOUTH WHITTLESEY AVENUE, WALLINGFORD, CT 06492-4102 - JURIS NO. 101674 - 203-785-8500 CERTIFICATION I hereby certify that this is a true and accurate copy of the foregoing original which was transmitted via electronic filing to the Clerk, Superior Court and mailed or electronically delivered on May 5, 2021 to all counsel and pro se parties of record as follows: Jeffrey Lynch, Esquire Perkins & Associates 30 Lucy Street Woodbridge, CT 06525 Louis A. Spadaccini, Esquire Blackwell & Spadaccini, LLC 158 East Center Street Manchester, CT 06040 __#102450________________________ Michael P. Del Sole 3 DEL SOLE & DEL SOLE, LLP - ATTORNEYS AT LAW 46 SOUTH WHITTLESEY AVENUE, WALLINGFORD, CT 06492-4102 - JURIS NO. 101674 - 203-785-8500