On April 21, 2021 a
Exhibit,Appendix
was filed
involving a dispute between
Nancy Burton,
and
Bryan Hurlburt,Commissioner,Ct Dept Of Agriculture,
Building Department, Town Of Redding Ct,
Charles Dellarocco, Animal Control Officer,Ct Dept. Of Agriculture,
David Philip Mason,
Dennis Gibbon,
Department Of Agriculture,State Of Connecticut,
Elinore Carmody,
Health Department,Town Of Redding Ct Town Hall,Redding,
Julia Pemberton First Selectman,Town Or Redding,
Mark O'Donnell Chief Of Police,
Police Department,Town Of Redding Ct Town Hall,
Susan Winters,
Town Of Redding,Connecticut C O Town Clerk,
for M00 - Misc - Injunction
in the District Court of New Haven County.
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(X06) UWY-CV-21-5028294-S
NANCY BURTON SUPERIOR COURT
JUDICIAL DISTRICT
Vv. OF WATERBURY
DAVID PHILIP MASON
ET AL. JULY 15, 2021
PLAINTIFF’S “EXHIBITS” COVER SHEET
Plaintiff attaches hereto her cover sheet identifying each Exhibit attached to her
Memorandum of Law in Opposition to Special Motions to Dismiss dated July 12, 2021!
THE PLAINTIFF
147 Cross Highway
Redding CT 06896
Tel. 203-313-1510
NancyBurtonCT@aol.com
CERTIFICATION
This is to certify that a copy of the foregoing was delivered electronically
pursuant to Practice Book §10-13 on July 14, 2021 to the following counsel of
record:
James N. Tallberg, Esq.
Karsten & Tallberg, LLC
500 Enterprise Drive, Suite 4B
Rocky Hill CT 06067
JTallberg@ktawfirm.com
Jonathan Edward Harding, Esq.
Assistant Attorney General
165 Capitol Avenue
Hartford CT 06106
Jonathan. Harding@ct.go
Philip T. Newbury, Jr., Esq.
Howd & Ludorf, LLC
65 Wethersfield Ave.
Hartford CT 06114
pnewbury@hl-law.com
Robert Scott Hillson, Esq.
53 State Street
Boston MA 02109
rhillson@rubinrudman.com
Steve Stafstrom, Esq.
Pullman & Comley
850 Main Street
Bridgeport CT 06601
ssafstrom@pullcom.com
Fina
PLAINTIFF EXHIBITS IN SUPPORT OF PLAINTIFF’S MEMORANDUM OF LAW IN
OPPOSITION TO SPECIAL MOTIONS TO DISMISS
Part |
Exhibit A -Page One — Photograph of nine of plaintiff's goats crowded into a 10’ X 10’
stall at the Connecticut Department of Agriculture facility for large animals at Niantic,
Connecticut. The photograph was taken illicitly by a correctional officer at the York
Correctional Institute in March 2021, according to testimony by Department of
Agriculture witness Tanya Wescovich in State of Connecticut ex rel. Jeremiah Dunn v.'
65 Goats, HHD-CV-21-6139702-S on April 8, 2021. The animal facility is located at the
center of the prison “campus,” which lacks facilities for confined animals to graze and
engage in active recreation. This photograph and others were posted on a Facebook
page, “CT Goat Chat,” along with comments about disallowed “black market” adoptions
which do not comply with the requirements of Conn. Gen. Stat.§ 22-37a. Provisions of
water and hay do not appear available. The goats exhibit wariness, stress and fear and
are tightly grouped in a “herd” response to danger.
Exhibit B -Page Two — One-page undated report signed by Jeremiah Dunn, DOAG chief
animal control officer regarding the death of plaintiff's “Goat #6) while unattended during
the 17-hour period of April 7-8, 2021 when human staff members were absent. The goat
was found to be pregnant with three well-formed female kids when she died; they did
not survive.
Exhibit C -Pages Three-Eight — Cover description and five succeeding photographs
taken by plaintiff of defendants Mason, Carmody and Gibbons on April 30, 2021.
Part Il
Exhibit D - Pages Nine-Fifteen — Plaintiff's email to DOAG Commissioner Bryan Hurlburt
dated December 2, 2020 demanding an investigation of the attached complaint
conxcerning conduct of defendants Mason, Carmody and Gibbons.
Exhibit E - Pages Sixteen-Eighteen — Hartford Courant article dated March 28, 1999
titled “No Need to Bury Your Pet, Rules Say”
Exhibit F - Pages Nineteen-Twenty — Hartford Courant article dated September 21,
2004 titled “Officer Resigns as Girls’ Coach’
Page Twenty-One — One-page letter to plaintiff Nancy Burton from Redding Planning
Commission dated January 23, 2018 regarding her goat security fence. (This letter was
intended to be attached to the complaint plaintiff filed with DOAG Commissioner
Hurlburt (Exhibit D above) but was inadvertently attached in the wrong order hereto.
Document Filed Date
July 16, 2021
Case Filing Date
April 21, 2021
Category
M00 - Misc - Injunction
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in New Haven County
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(X06) UWY-CV-21-5028294-S NANCY BURTON SUPERIOR COURT JUDICIAL DISTRICT Vv. OF WATERBURY DAVID PHILIP MASON ET AL. JULY 15, 2021 PLAINTIFF’S “EXHIBITS” COVER SHEET Plaintiff attaches hereto her cover sheet identifying each Exhibit attached to her Memorandum of Law in Opposition to Special Motions to Dismiss dated July 12, 2021! THE PLAINTIFF 147 Cross Highway Redding CT 06896 Tel. 203-313-1510 NancyBurtonCT@aol.com CERTIFICATION This is to certify that a copy of the foregoing was delivered electronically pursuant to Practice Book §10-13 on July 14, 2021 to the following counsel of record: James N. Tallberg, Esq. Karsten & Tallberg, LLC 500 Enterprise Drive, Suite 4B Rocky Hill CT 06067 JTallberg@ktawfirm.com Jonathan Edward Harding, Esq. Assistant Attorney General 165 Capitol Avenue Hartford CT 06106 Jonathan. Harding@ct.go Philip T. Newbury, Jr., Esq. Howd & Ludorf, LLC 65 Wethersfield Ave. Hartford CT 06114 pnewbury@hl-law.com Robert Scott Hillson, Esq. 53 State Street Boston MA 02109 rhillson@rubinrudman.com Steve Stafstrom, Esq. Pullman & Comley 850 Main Street Bridgeport CT 06601 ssafstrom@pullcom.com Fina PLAINTIFF EXHIBITS IN SUPPORT OF PLAINTIFF’S MEMORANDUM OF LAW IN OPPOSITION TO SPECIAL MOTIONS TO DISMISS Part | Exhibit A -Page One — Photograph of nine of plaintiff's goats crowded into a 10’ X 10’ stall at the Connecticut Department of Agriculture facility for large animals at Niantic, Connecticut. The photograph was taken illicitly by a correctional officer at the York Correctional Institute in March 2021, according to testimony by Department of Agriculture witness Tanya Wescovich in State of Connecticut ex rel. Jeremiah Dunn v.' 65 Goats, HHD-CV-21-6139702-S on April 8, 2021. The animal facility is located at the center of the prison “campus,” which lacks facilities for confined animals to graze and engage in active recreation. This photograph and others were posted on a Facebook page, “CT Goat Chat,” along with comments about disallowed “black market” adoptions which do not comply with the requirements of Conn. Gen. Stat.§ 22-37a. Provisions of water and hay do not appear available. The goats exhibit wariness, stress and fear and are tightly grouped in a “herd” response to danger. Exhibit B -Page Two — One-page undated report signed by Jeremiah Dunn, DOAG chief animal control officer regarding the death of plaintiff's “Goat #6) while unattended during the 17-hour period of April 7-8, 2021 when human staff members were absent. The goat was found to be pregnant with three well-formed female kids when she died; they did not survive. Exhibit C -Pages Three-Eight — Cover description and five succeeding photographs taken by plaintiff of defendants Mason, Carmody and Gibbons on April 30, 2021. Part Il Exhibit D - Pages Nine-Fifteen — Plaintiff's email to DOAG Commissioner Bryan Hurlburt dated December 2, 2020 demanding an investigation of the attached complaint conxcerning conduct of defendants Mason, Carmody and Gibbons. Exhibit E - Pages Sixteen-Eighteen — Hartford Courant article dated March 28, 1999 titled “No Need to Bury Your Pet, Rules Say” Exhibit F - Pages Nineteen-Twenty — Hartford Courant article dated September 21, 2004 titled “Officer Resigns as Girls’ Coach’ Page Twenty-One — One-page letter to plaintiff Nancy Burton from Redding Planning Commission dated January 23, 2018 regarding her goat security fence. (This letter was intended to be attached to the complaint plaintiff filed with DOAG Commissioner Hurlburt (Exhibit D above) but was inadvertently attached in the wrong order hereto.