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.
Preview
EXHIBITS
IN SUPPORT OF CORRECTED SUPERSEDING
MEMORANDUM OF LAW
IN OPPOSITION TO SPECIAL MOTIONS TO DISMISS
BY DEFENDANTS MASON, CARMODY AND GIBBONS
Investigation Report — June 15, 2018 - Mary Jane Lis, Doctor of
Veterinary Medicine, State Veterinarian
Letter from Defendant Elinor Carmody to Laura Brundage, Civil
Caseflow Coordinator, Danbury Superior Court (August 25, 2020)
Email Reply by Laura Brundage to Elinore Carmody (August 25,
2020)
Elinore Carmody Email to Laura Brundage (August 25, 2020)
Email exchange from Jeremiah Dunn to Defendant Elinore Carmody
July 27, 2020 and Carmody Reply of same date
“Guest Editorial’ by Elinore Carmody posted on “Hello Redding”
social media site (September 27, 2020)
Memorandum of Decision, Excerpts pages 1 and 15, Nancy Burton v.
Julia Pemberton et al, DBD-19-5015276 S (October 2, 2020)
Email exchange regarding “injured” goat between Traci Hertzberg,
Deputy Assistant State’s Attorney, and Nancy Burton (November 4,
2020)
9. Nancy Burton Complaint to Redding Police Chief Mark O’Donnell with
Attachments “A” (Nancy Burton Complaint dated August 26, 2020)
and “B” (Nancy Burton Complaint dated September 30, 2020)
10. Nancy Burton email to Charles DellaRocco dated December
11, 2020
11. Charles DellaRocco email to Nancy Burton dated December
14, 2020
12. Nancy Burton email to Bryan Hurlburt, Charles DellaRocco and
Dr. Mary Jane Lis dated December 27, 2020
13. Fragmet of email to “Will’ from Elinore Carmody (undated);
June 3, 2020 Email from “Will” to Elinore Carmody
14. Nancy Burton Email Demand to DOAG Commissioner Bryan
Hurlburt investigation of her complaint (December 2, 2020)
15. Confirmation Email from Carole Briggs, DOAG staff attorney,
acknowledging that Ms. Burton’s Complaint to Commissioner Hurlburt
earlier on December 2, 2020 had been received and stating: “The
department takes seriously all allegations of animal cruelty.”
16. Department of Agriculture Investigation Report stating the
“investigation” of Ms. Burton’s December 2, 2020 complaint had been
“closed.” December 10, 2020, eight days after being filed.
17. Elinore Carmody email to DOAG Commissioner Bryan Hurlburt
March 12, 2020 at 4:11 PM
18. Bryan Hurlburt email to Elinore Carmody March 12, 2020 at
4:43 PM
19. Elinore Carmody email to DOAG Commissioner Bryan Hurlburt
July 24, 2020
20. Elinore Carmody email to Connecticut State Senator Will
Haskell (October 9, 2021)
21. Elinore Carmody email to Connecticut State Senator Will
Haskell (May 29, 2020)
22. Email from Connecticut State Senator Will Haskell to Elinore
Carmody (June 3, 2020); detached and missing email reply to Mr.
Haskell from Elinore Carmody (June 3, 2020)
23. Elinore Carmody email to Connecticut State Senator Will
Haskell (August 20, 2020)
24. Letter from Connecticut State Senator Will Haskell to DOAG
Commissioner Bryan Hurlburt (January 25, 2021)
25. Email from Elinore Carmody to DOAG animal control officer
Barbara Godejohn (undated); Reply email from Barbara Godejohn
dated October 21, 2020; Elinore Carmody email to perhaps Barbara’
Godejohn with the phrase “[Quoted text hidden]” (October 21, 2020)
26. Undated email from Barbara Godejohn followed by Elinore
Carmody email to Barbara Godejohn (October 21, 2020)
27. Fragment of undated email from Elinore Carmody; Email to
Barbara [presumably Godejohn] (October 21, 2020)
28. Emailed inaccessible image emailed by Elinore Carmody to
unknown recipient (October 16, 2020); Email from Elinore Carmody
to Barbara Godejohn (October 21, 2020)
29. Email from Elinore Carmody to Barbara Godejohn with
inaccessible image and no text (October 16, 2020)
30. Email from Elinore Carmody to Barbara Godejohn with
inaccessible image (October 21, 2020)
31. Email from Connecticut State Senator Will Haskell to Elinore
Carmody (undated)
32. Nancy Burton Letter Dated October 5, 2021 as e-mailed with
two attachments (Exhibits #2” and “7”) to Laura Brundage, Assistant
Clerk, Danbury Superior Court.
33. Email exchange between Elinore Carmody January 27, 2021
and Connecticut State Senator Will Haskell January 27, 2021.
34. Correspondence by Nancy Burton on March 11, 2021 emailed
to Steven Stafstrom, Redding Town Counsel, and the three Redding
Selectmen and Mr. Stafstrom’s reply of the same date.
35. Defendant Susan Winters’ article titled “Goats: Followup”
posted on “Hello Redding” social media site on August 9, 2020.
36. (A) Elinore Carmody email titled “Nancy Burton Is My Next Door
Neighbor’ undated but apparently circulated by her on or about July
24, 2020 to Bryan Hurlburt (DOAG Commissioner), State Senator Will
Haskell and Julia Pemberton, Redding First Selectman; (B) with reply
dated July 24, 2020 by Julia Pemberton and (C) circulated by DOAG
Commissioner Bryan Hurlburtto Jeremiah Dunn, DOAG chief animal
control officer, and other DOAG personnel including Bruce Sherman,
Carole Briggs, Wayne Kasacek and Rebecca Eddy
37. Elinor Carmody email dated July 31, 2020 to DOAG
Commissioner Bryan Hurlburt, with copies to Redding First
Selectman, State Senator Will Haskell and Jeremiah Dunn
38. Elinore Carmody email dated July 27, 2020 to Jeremiah Dunn
with copies to DOAG Commisioner Hurlburt, Redding First Selectman
Julia Pemberton and State Senator Will Haskell
39. “Goats: an ongoing issue” by Susan Winters posted on July 22,
2020 on social media
40. Nancy Burton request to Ms. Carmody’s attorney to provide
inaccessible attachments/images; No reply has to date been
received.
41. The case of Nancy Burton v. Julia Pemberton et al., UWY-CV-
19-5027713-S, “[a]t the request of the Civil Presiding Judge (Hon.
Robin Pavia),” designated as a “complex litigation case” and
transferred to the Complex Litigation Docket for the Judicial District of
Waterbury.
42. Unilateral Withdrawal of Counterclaim, Nancy Burton v. Julia
Pemberton et al., UWY-CV-19-5027713-S, by Redding Town
Counsel Steven Stafstrom on March 15, 2021.
43. In Nancy Burton v. Julia Pemberton et al., UWY-CV-19-
5027713-S, Order issued on March 3, 2021 by Hon. Barbara N. Bellis
(‘An on the record telephone status conference in this matter is
scheduled for Wednesday, March 10, 2021 at 9:00 a.m... .”)
44. Biography of Steven J. Stafstrom, Jr. as posted on October 7,
2021 on Pullman & Comley website,
https://www.pullcom.com/people-stevenstafstrom
Related Content
in New Haven County
Preview
EXHIBITS IN SUPPORT OF CORRECTED SUPERSEDING MEMORANDUM OF LAW IN OPPOSITION TO SPECIAL MOTIONS TO DISMISS BY DEFENDANTS MASON, CARMODY AND GIBBONS Investigation Report — June 15, 2018 - Mary Jane Lis, Doctor of Veterinary Medicine, State Veterinarian Letter from Defendant Elinor Carmody to Laura Brundage, Civil Caseflow Coordinator, Danbury Superior Court (August 25, 2020) Email Reply by Laura Brundage to Elinore Carmody (August 25, 2020) Elinore Carmody Email to Laura Brundage (August 25, 2020) Email exchange from Jeremiah Dunn to Defendant Elinore Carmody July 27, 2020 and Carmody Reply of same date “Guest Editorial’ by Elinore Carmody posted on “Hello Redding” social media site (September 27, 2020) Memorandum of Decision, Excerpts pages 1 and 15, Nancy Burton v. Julia Pemberton et al, DBD-19-5015276 S (October 2, 2020) Email exchange regarding “injured” goat between Traci Hertzberg, Deputy Assistant State’s Attorney, and Nancy Burton (November 4, 2020) 9. Nancy Burton Complaint to Redding Police Chief Mark O’Donnell with Attachments “A” (Nancy Burton Complaint dated August 26, 2020) and “B” (Nancy Burton Complaint dated September 30, 2020) 10. Nancy Burton email to Charles DellaRocco dated December 11, 2020 11. Charles DellaRocco email to Nancy Burton dated December 14, 2020 12. Nancy Burton email to Bryan Hurlburt, Charles DellaRocco and Dr. Mary Jane Lis dated December 27, 2020 13. Fragmet of email to “Will’ from Elinore Carmody (undated); June 3, 2020 Email from “Will” to Elinore Carmody 14. Nancy Burton Email Demand to DOAG Commissioner Bryan Hurlburt investigation of her complaint (December 2, 2020) 15. Confirmation Email from Carole Briggs, DOAG staff attorney, acknowledging that Ms. Burton’s Complaint to Commissioner Hurlburt earlier on December 2, 2020 had been received and stating: “The department takes seriously all allegations of animal cruelty.” 16. Department of Agriculture Investigation Report stating the “investigation” of Ms. Burton’s December 2, 2020 complaint had been “closed.” December 10, 2020, eight days after being filed. 17. Elinore Carmody email to DOAG Commissioner Bryan Hurlburt March 12, 2020 at 4:11 PM 18. Bryan Hurlburt email to Elinore Carmody March 12, 2020 at 4:43 PM 19. Elinore Carmody email to DOAG Commissioner Bryan Hurlburt July 24, 2020 20. Elinore Carmody email to Connecticut State Senator Will Haskell (October 9, 2021) 21. Elinore Carmody email to Connecticut State Senator Will Haskell (May 29, 2020) 22. Email from Connecticut State Senator Will Haskell to Elinore Carmody (June 3, 2020); detached and missing email reply to Mr. Haskell from Elinore Carmody (June 3, 2020) 23. Elinore Carmody email to Connecticut State Senator Will Haskell (August 20, 2020) 24. Letter from Connecticut State Senator Will Haskell to DOAG Commissioner Bryan Hurlburt (January 25, 2021) 25. Email from Elinore Carmody to DOAG animal control officer Barbara Godejohn (undated); Reply email from Barbara Godejohn dated October 21, 2020; Elinore Carmody email to perhaps Barbara’ Godejohn with the phrase “[Quoted text hidden]” (October 21, 2020) 26. Undated email from Barbara Godejohn followed by Elinore Carmody email to Barbara Godejohn (October 21, 2020) 27. Fragment of undated email from Elinore Carmody; Email to Barbara [presumably Godejohn] (October 21, 2020) 28. Emailed inaccessible image emailed by Elinore Carmody to unknown recipient (October 16, 2020); Email from Elinore Carmody to Barbara Godejohn (October 21, 2020) 29. Email from Elinore Carmody to Barbara Godejohn with inaccessible image and no text (October 16, 2020) 30. Email from Elinore Carmody to Barbara Godejohn with inaccessible image (October 21, 2020) 31. Email from Connecticut State Senator Will Haskell to Elinore Carmody (undated) 32. Nancy Burton Letter Dated October 5, 2021 as e-mailed with two attachments (Exhibits #2” and “7”) to Laura Brundage, Assistant Clerk, Danbury Superior Court. 33. Email exchange between Elinore Carmody January 27, 2021 and Connecticut State Senator Will Haskell January 27, 2021. 34. Correspondence by Nancy Burton on March 11, 2021 emailed to Steven Stafstrom, Redding Town Counsel, and the three Redding Selectmen and Mr. Stafstrom’s reply of the same date. 35. Defendant Susan Winters’ article titled “Goats: Followup” posted on “Hello Redding” social media site on August 9, 2020. 36. (A) Elinore Carmody email titled “Nancy Burton Is My Next Door Neighbor’ undated but apparently circulated by her on or about July 24, 2020 to Bryan Hurlburt (DOAG Commissioner), State Senator Will Haskell and Julia Pemberton, Redding First Selectman; (B) with reply dated July 24, 2020 by Julia Pemberton and (C) circulated by DOAG Commissioner Bryan Hurlburtto Jeremiah Dunn, DOAG chief animal control officer, and other DOAG personnel including Bruce Sherman, Carole Briggs, Wayne Kasacek and Rebecca Eddy 37. Elinor Carmody email dated July 31, 2020 to DOAG Commissioner Bryan Hurlburt, with copies to Redding First Selectman, State Senator Will Haskell and Jeremiah Dunn 38. Elinore Carmody email dated July 27, 2020 to Jeremiah Dunn with copies to DOAG Commisioner Hurlburt, Redding First Selectman Julia Pemberton and State Senator Will Haskell 39. “Goats: an ongoing issue” by Susan Winters posted on July 22, 2020 on social media 40. Nancy Burton request to Ms. Carmody’s attorney to provide inaccessible attachments/images; No reply has to date been received. 41. The case of Nancy Burton v. Julia Pemberton et al., UWY-CV- 19-5027713-S, “[a]t the request of the Civil Presiding Judge (Hon. Robin Pavia),” designated as a “complex litigation case” and transferred to the Complex Litigation Docket for the Judicial District of Waterbury. 42. Unilateral Withdrawal of Counterclaim, Nancy Burton v. Julia Pemberton et al., UWY-CV-19-5027713-S, by Redding Town Counsel Steven Stafstrom on March 15, 2021. 43. In Nancy Burton v. Julia Pemberton et al., UWY-CV-19- 5027713-S, Order issued on March 3, 2021 by Hon. Barbara N. Bellis (‘An on the record telephone status conference in this matter is scheduled for Wednesday, March 10, 2021 at 9:00 a.m... .”) 44. Biography of Steven J. Stafstrom, Jr. as posted on October 7, 2021 on Pullman & Comley website, https://www.pullcom.com/people-stevenstafstrom