Preview
DOCKET NO. FBT-CV19-6085010-S : SUPERIOR COURT
:
JANELLE POMPEA : J. D. OF FAIRFIELD
:
VS. : AT BRIDGEPORT
:
SEASIDE WINE AND LIQUOR, LLC, ET. AL. : NOVEMBER 7, 2019
GIUSEPPE SAVERINO’S OBJECTIONS TO
PLAINTIFF’S REQUEST FOR INTERROGATORIES, PRODUCTION, INSPECTION AND
EXAMINATION DIRECTED TO GIUSEPPE SAVERINO – FIRST SET
The defendant, Giuseppe Saverino, hereby OBJECTS to the plaintiff’s Interrogatories and
Requests for Production, dated August 21, 2019, to Interrogatory Nos. 5, 6, 7, 11, 12, 13 and
Request for Production No. 14, as follows:
5. State whether you, your attorney, or any other representative(s) have knowledge of
any statement or statement(s), as defined in Practice Book Section 13-1, signed or otherwise in
writing adopted or approved by the person making it, or any stenographic, mechanical, electrical or
other recording or a transcription thereof, made by a party or non-party declarant regarding the subject
matter of this case or of the consolidated cases, or concerning the actions of any party or witness therein
except statements made by a party to his/her attorney(s), including but not limited to:
(a) statement(s) to the police;
(b) statement(s) to an insurance company representative;
(c) statement(s) to an investigator;
(d) statement(s) to the liquor control commission.
OBJECTION:
Mr. Saverino objects on the grounds that the standard discovery concept of producing
“statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim
involving the complex background found here, or to complex cases involving multiple consolidated
actions, parallel business litigation, and criminal investigations.
Specifically, the “subject matter of this case or of the consolidated cases” is not defined or
otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted
to allow for potentially unlimited inquiry into the background of the parties and subject business,
investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated
cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the
associated criminal investigations, some of which documents and information are publicly
accessible, to the extent such materials may meet the already broad definition of “statement”. All
materials from the business litigation and criminal investigations that may qualify as “statements” on
the extremely broad topic the “subject matter of this case or of the consolidated cases” is not
reasonably calculated to lead to the discovery of admissible evidence in the instant case.
Similarly, “party or non-party declarant” and “concerning the actions of any party or witness
therein” are overly broad given the number of parties involved in the ten consolidated actions and the
business litigation, and the number of witnesses involved in each case and in the circumstances giving rise
to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and
includes potentially unlimited inquiry into conduct, utterances, communications, and investigations
in the business litigation or criminal investigations. Even if material from the business litigation and
criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter
of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead
to the discovery of admissible evidence in the instant case.
Objection is further made to the extent that certain pleadings, motions, and discovery in the
business litigation are not reasonably calculated to lead to the discovery of admissible evidence in
this personal injury litigation.
2
6. For each statement identified in Interrogatory #5, above, state:
(a) the date on which the statement or statements were taken;
(b) the names and addresses of the person or persons who took such statement or
statements;
(c) the names and addresses of any person or persons present when such statement
or statements were taken;
(d) whether such statement or statements were written, made by recording device or
taken by court reporter or stenographer;
(e) the names and addresses of any person or persons having custody or a copy or
copies or such statement or statements.
OBJECTION:
Mr. Saverino objects on the grounds that the standard discovery concept of producing
“statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim
involving the complex background found here, or to complex cases involving multiple consolidated
actions, parallel business litigation, and criminal investigations.
Specifically, the “subject matter of this case or of the consolidated cases” is not defined or
otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted
to allow for potentially unlimited inquiry into the background of the parties and subject business,
investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated
cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the
associated criminal investigations, some of which documents and information are publicly
accessible, to the extent such materials may meet the already broad definition of “statement”. All
materials from the business litigation and criminal investigations that may qualify as “statements” on
3
the extremely broad topic the “subject matter of this case or of the consolidated cases” is not
reasonably calculated to lead to the discovery of admissible evidence in the instant case.
Similarly, “party or non-party declarant” and “concerning the actions of any party or witness
therein” are overly broad given the number of parties involved in the ten consolidated actions and the
business litigation, and the number of witnesses involved in each case and in the circumstances giving rise
to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and
includes potentially unlimited inquiry into conduct, utterances, communications, and investigations
in the business litigation or criminal investigations. Even if material from the business litigation and
criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter
of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead
to the discovery of admissible evidence in the instant case.
Objection is further made to the extent that certain pleadings, motions, and discovery in the
business litigation are not reasonably calculated to lead to the discovery of admissible evidence in
this personal injury litigation. Objection is further made to the extent that materials obtained through
the efforts of Mr. Saverino or his counsel during the pendency of this case or the business litigation
qualify for work product protection, protection as materials prepared or obtained in anticipation of
litigation, and/or materials obtained or prepared at the direction of counsel.
7. State name(s), address(es) and present location of any person or persons who have
custody at this time of any materials referred to in Interrogatory #5, above, and indicate the name(s)
and address(es) and job title(s) or capacity of the person or persons who obtained such material from
the declarant.
OBJECTION:
4
Mr. Saverino objects on the grounds that the standard discovery concept of producing
“statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim
involving the complex background found here, or to complex cases involving multiple consolidated
actions, parallel business litigation, and criminal investigations.
Specifically, the “subject matter of this case or of the consolidated cases” is not defined or
otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted
to allow for potentially unlimited inquiry into the background of the parties and subject business,
investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated
cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the
associated criminal investigations, some of which documents and information are publicly
accessible, to the extent such materials may meet the already broad definition of “statement”. All
materials from the business litigation and criminal investigations that may qualify as “statements” on
the extremely broad topic the “subject matter of this case or of the consolidated cases” is not
reasonably calculated to lead to the discovery of admissible evidence in the instant case.
Similarly, “party or non-party declarant” and “concerning the actions of any party or witness
therein” are overly broad given the number of parties involved in the ten consolidated actions and the
business litigation, and the number of witnesses involved in each case and in the circumstances giving rise
to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and
includes potentially unlimited inquiry into conduct, utterances, communications, and investigations
in the business litigation or criminal investigations. Even if material from the business litigation and
criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter
of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead
to the discovery of admissible evidence in the instant case.
5
Objection is further made to the extent that certain pleadings, motions, and discovery in the
business litigation are not reasonably calculated to lead to the discovery of admissible evidence in
this personal injury litigation. Objection is further made to the extent that materials obtained through
the efforts of Mr. Saverino or his counsel during the pendency of this case or the business litigation
qualify for work product protection, protection as materials prepared or obtained in anticipation of
litigation, and/or materials obtained or prepared at the direction of counsel.
11. State the name(s) and address(es) of all doctors and hospitals, and any other source,
from whom you have obtained medical reports, medical correspondence, records, or other
information concerning the Plaintiff, other than information that was furnished to you by the
Plaintiff's attorney.
OBJECTION:
Objection is made to the extent that any materials obtained by the efforts of counsel after
commencement of this lawsuit may qualify for work product protection and/or protection as
material prepared or obtained in anticipation of litigation. Subject to and without waiving this
objection, none.
12. Have you made any statements, as defined in Practice Book Section 13-1 to any
person regarding any of the incidents alleged in the Complaint? Comment: This interrogatory is
intended to include party statements made to a representative of an insurance company prior to
involvement of counsel.
OBJECTION:
6
Mr. Saverino objects on the grounds that the standard discovery concept of producing
“statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim
involving the complex background found here, or to complex cases involving multiple consolidated
actions, parallel business litigation, and criminal investigations.
Specifically, the “subject matter of this case or of the consolidated cases” is not defined or
otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted
to allow for potentially unlimited inquiry into the background of the parties and subject business,
investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated
cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the
associated criminal investigations, some of which documents and information are publicly
accessible, to the extent such materials may meet the already broad definition of “statement”. All
materials from the business litigation and criminal investigations that may qualify as “statements” on
the extremely broad topic the “subject matter of this case or of the consolidated cases” is not
reasonably calculated to lead to the discovery of admissible evidence in the instant case.
Similarly, “party or non-party declarant” and “concerning the actions of any party or witness
therein” are overly broad given the number of parties involved in the ten consolidated actions and the
business litigation, and the number of witnesses involved in each case and in the circumstances giving rise
to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and
includes potentially unlimited inquiry into conduct, utterances, communications, and investigations
in the business litigation or criminal investigations. Even if material from the business litigation and
criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter
of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead
to the discovery of admissible evidence in the instant case.
7
Objection is further made to the extent that certain pleadings, motions, and discovery in the
business litigation are not reasonably calculated to lead to the discovery of admissible evidence in
this personal injury litigation. Objection is further made to the extent that materials obtained through
the efforts of Mr. Saverino or his counsel during the pendency of this case or the business litigation
qualify for work product protection, protection as materials prepared or obtained in anticipation of
litigation, and/or materials obtained or prepared at the direction of counsel.
13. If the answer to Interrogatory 12 is affirmative, state:
a. the name and address of the person or persons to whom such statements were
made:
b. the date on which such statements were made;
c. the form of the statement (i.e. whether written, made by recording device or
recorded by a stenographer, etc.);
OBJECTION:
Mr. Saverino objects on the grounds that the standard discovery concept of producing
“statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim
involving the complex background found here, or to complex cases involving multiple consolidated
actions, parallel business litigation, and criminal investigations.
Specifically, the “subject matter of this case or of the consolidated cases” is not defined or
otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted
to allow for potentially unlimited inquiry into the background of the parties and subject business,
investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated
cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the
8
associated criminal investigations, some of which documents and information are publicly
accessible, to the extent such materials may meet the already broad definition of “statement”. All
materials from the business litigation and criminal investigations that may qualify as “statements” on
the extremely broad topic the “subject matter of this case or of the consolidated cases” is not
reasonably calculated to lead to the discovery of admissible evidence in the instant case.
Similarly, “party or non-party declarant” and “concerning the actions of any party or witness
therein” are overly broad given the number of parties involved in the ten consolidated actions and the
business litigation, and the number of witnesses involved in each case and in the circumstances giving rise
to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and
includes potentially unlimited inquiry into conduct, utterances, communications, and investigations
in the business litigation or criminal investigations. Even if material from the business litigation and
criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter
of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead
to the discovery of admissible evidence in the instant case.
Objection is further made to the extent that certain pleadings, motions, and discovery in the
business litigation are not reasonably calculated to lead to the discovery of admissible evidence in
this personal injury litigation. Objection is further made to the extent that materials obtained through
the efforts of Mr. Saverino or his counsel during the pendency of this case or the business litigation
qualify for work product protection, protection as materials prepared or obtained in anticipation of
litigation, and/or materials obtained or prepared at the direction of counsel.
9
REQUESTS FOR PRODUCTION
14. All documents pertaining to interactions with, or investigations by, the State of
Connecticut Liquor Commission, from the period of time between January 1, 2015 to the present
including, without limitation:
a) all documents or other material given by defendant to the State of Connecticut
Liquor Control Commission.
b) all documents received from the State of Connecticut Liquor Control
Commission.
OBJECTION:
Mr. Saverino objects on the grounds that this request is overly broad and unduly burdensome,
and not reasonably calculated to lead to the discovery of admissible evidence. Objection is also made
on the grounds that Mr. Saverino is not an owner, manager, member, employee, or otherwise in
control of Seaside Wine and Liquor.
DEFENDANT,
GIUSEPPE SAVERINO
By: /s/ Joseph J. Blyskal (429001)
Joseph J. Blyskal
Kelcie B. Reid
Gordon & Rees Scully Mansukhani LLP
95 Glastonbury Boulevard, Suite 206
Glastonbury, CT 06033
Phone: (860) 494-7555
Fax: (860) 560-0185
Email: jblyskal@grsm.com
Email: kreid@grsm.com
10
CERTIFICATION
I certify that a copy of the above was or will immediately be mailed or delivered
electronically or non-electronically on the date hereof, to all attorneys and self-represented parties of
record and to all parties who have not appeared in this matter and that written consent for electronic
delivery was received from all counsel and self-represented parties receiving electronic delivery.
Etan Hirsch, Esq.
Adelman Hirsch & Connors, LLP
1000 Lafayette Boulevard
Bridgeport, CT 06604
EH@ahctriallaw.com
Attorney for Plaintiff
Sergio C. Deganis, Esq.
Ouellette Deganis Gallagher & Grippe LLC
143 Main Street
Cheshire, CT 06410
info@odglaw.com
Attorney for Seaside Liquors LLC & Robert Pambianchi
Maureen E. Burns, Esq.
Mulvey Oliver Gould & Crotta
2911 Dixwell Avenue, 4th Floor
Hamden, CT 06518
burns@moglaw.com
Attorney for Allison Loder
Adam J. Tusia, Esq.
Milano & Wanat
471 East Main Street
Branford, CT 06405
atusia@mwllc.us
Attorney for Allison Loder
Richard A. Roberts, Esq.
Nuzzo & Roberts LLC
One Town Center
P.O. Box 747
Cheshire, CT 06410
recep@nuzzo-roberts.com
Attorney for Seaside Wine and Liquor LLC
& Yesika Saverino
/s/ Joseph J. Blyskal
Joseph J. Blyskal
Preview
DOCKET NO. FBT-CV19-6085010-S : SUPERIOR COURT : JANELLE POMPEA : J. D. OF FAIRFIELD : VS. : AT BRIDGEPORT : SEASIDE WINE AND LIQUOR, LLC, ET. AL. : NOVEMBER 7, 2019 GIUSEPPE SAVERINO’S OBJECTIONS TO PLAINTIFF’S REQUEST FOR INTERROGATORIES, PRODUCTION, INSPECTION AND EXAMINATION DIRECTED TO GIUSEPPE SAVERINO – FIRST SET The defendant, Giuseppe Saverino, hereby OBJECTS to the plaintiff’s Interrogatories and Requests for Production, dated August 21, 2019, to Interrogatory Nos. 5, 6, 7, 11, 12, 13 and Request for Production No. 14, as follows: 5. State whether you, your attorney, or any other representative(s) have knowledge of any statement or statement(s), as defined in Practice Book Section 13-1, signed or otherwise in writing adopted or approved by the person making it, or any stenographic, mechanical, electrical or other recording or a transcription thereof, made by a party or non-party declarant regarding the subject matter of this case or of the consolidated cases, or concerning the actions of any party or witness therein except statements made by a party to his/her attorney(s), including but not limited to: (a) statement(s) to the police; (b) statement(s) to an insurance company representative; (c) statement(s) to an investigator; (d) statement(s) to the liquor control commission. OBJECTION: Mr. Saverino objects on the grounds that the standard discovery concept of producing “statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim involving the complex background found here, or to complex cases involving multiple consolidated actions, parallel business litigation, and criminal investigations. Specifically, the “subject matter of this case or of the consolidated cases” is not defined or otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted to allow for potentially unlimited inquiry into the background of the parties and subject business, investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the associated criminal investigations, some of which documents and information are publicly accessible, to the extent such materials may meet the already broad definition of “statement”. All materials from the business litigation and criminal investigations that may qualify as “statements” on the extremely broad topic the “subject matter of this case or of the consolidated cases” is not reasonably calculated to lead to the discovery of admissible evidence in the instant case. Similarly, “party or non-party declarant” and “concerning the actions of any party or witness therein” are overly broad given the number of parties involved in the ten consolidated actions and the business litigation, and the number of witnesses involved in each case and in the circumstances giving rise to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and includes potentially unlimited inquiry into conduct, utterances, communications, and investigations in the business litigation or criminal investigations. Even if material from the business litigation and criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead to the discovery of admissible evidence in the instant case. Objection is further made to the extent that certain pleadings, motions, and discovery in the business litigation are not reasonably calculated to lead to the discovery of admissible evidence in this personal injury litigation. 2 6. For each statement identified in Interrogatory #5, above, state: (a) the date on which the statement or statements were taken; (b) the names and addresses of the person or persons who took such statement or statements; (c) the names and addresses of any person or persons present when such statement or statements were taken; (d) whether such statement or statements were written, made by recording device or taken by court reporter or stenographer; (e) the names and addresses of any person or persons having custody or a copy or copies or such statement or statements. OBJECTION: Mr. Saverino objects on the grounds that the standard discovery concept of producing “statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim involving the complex background found here, or to complex cases involving multiple consolidated actions, parallel business litigation, and criminal investigations. Specifically, the “subject matter of this case or of the consolidated cases” is not defined or otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted to allow for potentially unlimited inquiry into the background of the parties and subject business, investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the associated criminal investigations, some of which documents and information are publicly accessible, to the extent such materials may meet the already broad definition of “statement”. All materials from the business litigation and criminal investigations that may qualify as “statements” on 3 the extremely broad topic the “subject matter of this case or of the consolidated cases” is not reasonably calculated to lead to the discovery of admissible evidence in the instant case. Similarly, “party or non-party declarant” and “concerning the actions of any party or witness therein” are overly broad given the number of parties involved in the ten consolidated actions and the business litigation, and the number of witnesses involved in each case and in the circumstances giving rise to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and includes potentially unlimited inquiry into conduct, utterances, communications, and investigations in the business litigation or criminal investigations. Even if material from the business litigation and criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead to the discovery of admissible evidence in the instant case. Objection is further made to the extent that certain pleadings, motions, and discovery in the business litigation are not reasonably calculated to lead to the discovery of admissible evidence in this personal injury litigation. Objection is further made to the extent that materials obtained through the efforts of Mr. Saverino or his counsel during the pendency of this case or the business litigation qualify for work product protection, protection as materials prepared or obtained in anticipation of litigation, and/or materials obtained or prepared at the direction of counsel. 7. State name(s), address(es) and present location of any person or persons who have custody at this time of any materials referred to in Interrogatory #5, above, and indicate the name(s) and address(es) and job title(s) or capacity of the person or persons who obtained such material from the declarant. OBJECTION: 4 Mr. Saverino objects on the grounds that the standard discovery concept of producing “statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim involving the complex background found here, or to complex cases involving multiple consolidated actions, parallel business litigation, and criminal investigations. Specifically, the “subject matter of this case or of the consolidated cases” is not defined or otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted to allow for potentially unlimited inquiry into the background of the parties and subject business, investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the associated criminal investigations, some of which documents and information are publicly accessible, to the extent such materials may meet the already broad definition of “statement”. All materials from the business litigation and criminal investigations that may qualify as “statements” on the extremely broad topic the “subject matter of this case or of the consolidated cases” is not reasonably calculated to lead to the discovery of admissible evidence in the instant case. Similarly, “party or non-party declarant” and “concerning the actions of any party or witness therein” are overly broad given the number of parties involved in the ten consolidated actions and the business litigation, and the number of witnesses involved in each case and in the circumstances giving rise to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and includes potentially unlimited inquiry into conduct, utterances, communications, and investigations in the business litigation or criminal investigations. Even if material from the business litigation and criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead to the discovery of admissible evidence in the instant case. 5 Objection is further made to the extent that certain pleadings, motions, and discovery in the business litigation are not reasonably calculated to lead to the discovery of admissible evidence in this personal injury litigation. Objection is further made to the extent that materials obtained through the efforts of Mr. Saverino or his counsel during the pendency of this case or the business litigation qualify for work product protection, protection as materials prepared or obtained in anticipation of litigation, and/or materials obtained or prepared at the direction of counsel. 11. State the name(s) and address(es) of all doctors and hospitals, and any other source, from whom you have obtained medical reports, medical correspondence, records, or other information concerning the Plaintiff, other than information that was furnished to you by the Plaintiff's attorney. OBJECTION: Objection is made to the extent that any materials obtained by the efforts of counsel after commencement of this lawsuit may qualify for work product protection and/or protection as material prepared or obtained in anticipation of litigation. Subject to and without waiving this objection, none. 12. Have you made any statements, as defined in Practice Book Section 13-1 to any person regarding any of the incidents alleged in the Complaint? Comment: This interrogatory is intended to include party statements made to a representative of an insurance company prior to involvement of counsel. OBJECTION: 6 Mr. Saverino objects on the grounds that the standard discovery concept of producing “statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim involving the complex background found here, or to complex cases involving multiple consolidated actions, parallel business litigation, and criminal investigations. Specifically, the “subject matter of this case or of the consolidated cases” is not defined or otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted to allow for potentially unlimited inquiry into the background of the parties and subject business, investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the associated criminal investigations, some of which documents and information are publicly accessible, to the extent such materials may meet the already broad definition of “statement”. All materials from the business litigation and criminal investigations that may qualify as “statements” on the extremely broad topic the “subject matter of this case or of the consolidated cases” is not reasonably calculated to lead to the discovery of admissible evidence in the instant case. Similarly, “party or non-party declarant” and “concerning the actions of any party or witness therein” are overly broad given the number of parties involved in the ten consolidated actions and the business litigation, and the number of witnesses involved in each case and in the circumstances giving rise to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and includes potentially unlimited inquiry into conduct, utterances, communications, and investigations in the business litigation or criminal investigations. Even if material from the business litigation and criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead to the discovery of admissible evidence in the instant case. 7 Objection is further made to the extent that certain pleadings, motions, and discovery in the business litigation are not reasonably calculated to lead to the discovery of admissible evidence in this personal injury litigation. Objection is further made to the extent that materials obtained through the efforts of Mr. Saverino or his counsel during the pendency of this case or the business litigation qualify for work product protection, protection as materials prepared or obtained in anticipation of litigation, and/or materials obtained or prepared at the direction of counsel. 13. If the answer to Interrogatory 12 is affirmative, state: a. the name and address of the person or persons to whom such statements were made: b. the date on which such statements were made; c. the form of the statement (i.e. whether written, made by recording device or recorded by a stenographer, etc.); OBJECTION: Mr. Saverino objects on the grounds that the standard discovery concept of producing “statements” regarding the “subject matter” of litigation is not well-suited to a personal injury claim involving the complex background found here, or to complex cases involving multiple consolidated actions, parallel business litigation, and criminal investigations. Specifically, the “subject matter of this case or of the consolidated cases” is not defined or otherwise limited in scope or time, and is overly broad, vague, ambiguous, and could be interpreted to allow for potentially unlimited inquiry into the background of the parties and subject business, investigations, communications, pleadings, motions, and/or discovery regarding the ten consolidated cases, the business litigation titled Robert Pambianchi v. Giuseppe Saverino, et. al., and the 8 associated criminal investigations, some of which documents and information are publicly accessible, to the extent such materials may meet the already broad definition of “statement”. All materials from the business litigation and criminal investigations that may qualify as “statements” on the extremely broad topic the “subject matter of this case or of the consolidated cases” is not reasonably calculated to lead to the discovery of admissible evidence in the instant case. Similarly, “party or non-party declarant” and “concerning the actions of any party or witness therein” are overly broad given the number of parties involved in the ten consolidated actions and the business litigation, and the number of witnesses involved in each case and in the circumstances giving rise to each case. Further, the term “actions” is not defined and is overly broad, vague, ambiguous, and includes potentially unlimited inquiry into conduct, utterances, communications, and investigations in the business litigation or criminal investigations. Even if material from the business litigation and criminal investigations may qualify as “statements” on the extremely broad topic the “subject matter of this case or of the consolidated cases”, the “statements” may not be reasonably calculated to lead to the discovery of admissible evidence in the instant case. Objection is further made to the extent that certain pleadings, motions, and discovery in the business litigation are not reasonably calculated to lead to the discovery of admissible evidence in this personal injury litigation. Objection is further made to the extent that materials obtained through the efforts of Mr. Saverino or his counsel during the pendency of this case or the business litigation qualify for work product protection, protection as materials prepared or obtained in anticipation of litigation, and/or materials obtained or prepared at the direction of counsel. 9 REQUESTS FOR PRODUCTION 14. All documents pertaining to interactions with, or investigations by, the State of Connecticut Liquor Commission, from the period of time between January 1, 2015 to the present including, without limitation: a) all documents or other material given by defendant to the State of Connecticut Liquor Control Commission. b) all documents received from the State of Connecticut Liquor Control Commission. OBJECTION: Mr. Saverino objects on the grounds that this request is overly broad and unduly burdensome, and not reasonably calculated to lead to the discovery of admissible evidence. Objection is also made on the grounds that Mr. Saverino is not an owner, manager, member, employee, or otherwise in control of Seaside Wine and Liquor. DEFENDANT, GIUSEPPE SAVERINO By: /s/ Joseph J. Blyskal (429001) Joseph J. Blyskal Kelcie B. Reid Gordon & Rees Scully Mansukhani LLP 95 Glastonbury Boulevard, Suite 206 Glastonbury, CT 06033 Phone: (860) 494-7555 Fax: (860) 560-0185 Email: jblyskal@grsm.com Email: kreid@grsm.com 10 CERTIFICATION I certify that a copy of the above was or will immediately be mailed or delivered electronically or non-electronically on the date hereof, to all attorneys and self-represented parties of record and to all parties who have not appeared in this matter and that written consent for electronic delivery was received from all counsel and self-represented parties receiving electronic delivery. Etan Hirsch, Esq. Adelman Hirsch & Connors, LLP 1000 Lafayette Boulevard Bridgeport, CT 06604 EH@ahctriallaw.com Attorney for Plaintiff Sergio C. Deganis, Esq. Ouellette Deganis Gallagher & Grippe LLC 143 Main Street Cheshire, CT 06410 info@odglaw.com Attorney for Seaside Liquors LLC & Robert Pambianchi Maureen E. Burns, Esq. Mulvey Oliver Gould & Crotta 2911 Dixwell Avenue, 4th Floor Hamden, CT 06518 burns@moglaw.com Attorney for Allison Loder Adam J. Tusia, Esq. Milano & Wanat 471 East Main Street Branford, CT 06405 atusia@mwllc.us Attorney for Allison Loder Richard A. Roberts, Esq. Nuzzo & Roberts LLC One Town Center P.O. Box 747 Cheshire, CT 06410 recep@nuzzo-roberts.com Attorney for Seaside Wine and Liquor LLC & Yesika Saverino /s/ Joseph J. Blyskal Joseph J. Blyskal