Motion for Compliance or Status in FORD,HONOR v. MASON,MALCOLM Et Al| Trellis.Law

On May 12, 2017 a Order was filed involving a dispute between Honor Ford, and Malcolm Mason, Toni Boyle, for T50 - Torts - Defamation in the District Court of New Haven County.

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UWY-CV-17-5018769-s
Ford v. Mason

Honor A. Ford Judicial District of Waterbury
Superior Court
Vv. at Waterbury

Malcolm E. Mason & Toni Boyle July 9, 2018

ORDER FOR COMPLIANCE

In pursuant the Connecticut Practice Book, §.13-2. Scope of Discovery; In General, §.13-6.

interrogatories; In General, §. 13-7. Answers to Interrogatories, §. 13-14. Order for Compliance;

Failure to Answer or Comply with Order and §. 13-15. Continuing Duty to Disclose, I Honor

Ford, hereby request the judicial authority of the Superior Court of Waterbury in the District of

Waterbury to make such Order of Compliance, as the ends of justice require for each defendants

of this civil suit to abide by the Order for Compliance that:

Interrogatories dated October 18, 2017, the matters regarding this case discovery was sought.

See Connecticut PB §. 13-2. Scope of Discovery. On May 7, 2018, Production was sought for

unanswered interrogatory inquiry. See Connecticut PB §. 13-7. Answers to Interrogatories. Also

see, §. 13-14. Order for Compliance; Failure to Answer or Comply with Order and §. 13-15.

Continuing Duty to Disclose. Information received by the Plaintiff on or about January

Interrogatories were standard demographic questions tailored. to specific information sol ught
cs
oS
and designed; to get information early, to fill information gap, to identify sources of & co
ce
o &
electronically stored information (ESD), to compel. parties to answer beyond personakkfio
fowl edge
a co
2
and to use as evidence. Other designated facts shall be taken to be established for HE purposes
war 3
of the action in accordance with the claim of the party obtaining the order; the fuilureiBomply
aA Ww
as described in this section may not be excused on the ground that the discovery: is objectionafe;

3
UWY-CV-17-5018769-s
Ford v. Mason
If, subsequent to compliance with any request or order for discovery, including partial

compliance subject to an objection or made notwithstanding an objection, and prior to or during

trial, a party discovers additional or new material or information previously requested and

ordered subject to discovery or inspection or discovers that the prior compliance was totally or

partially incorrect or, though correct when made, is no longer true and the circumstances are

such that a failure to amend the compliance is in substance a knowing concealment, that party

shall promptly notify the other party. Both defendants was given the opportunity to hold the

courts previous order valid but has not fully complied. See Connecticut Practice Book, §. 13-14

and §. 13-15. Also see order 428420 of 03/06/2018 106.00 MOTION TO DISMISS PB 10-30.

The Plaintiff have made an effort to collect information for litigation by means of a letter of

production tequest to the Defendants on May 7, 2018. Defendants has not provided answers to

interrogatories subsequent to the order 106.00 and the due process of this civil case. Defendants’ °

failure to provide answers to interrogatories and letter of production resulted in this motion for

order. Defendants remain arbitrary, capricious incomplete and dishonest in their statements

without provision of answers to interrogatories. In addition to the non-discloser, defendants has

not provided on going updated information to the Plaintiff regarding inquiries of this case.

THE PLAINT:

HONO)

B Pro Se

61 Kendall Circle
Waterbury CT 06708
(203)756-2897
UWY-CV-17-5018769-s
Ford v. Mason

CERTIFICATION:

¥, Honor Ford, certify that a copy of this document was or will immediately be mailed or
delivered electronically or non-electronically on July 9, 2018 to all attorneys and self-
represented parties of record in this:matter and that written consent for electronic delivery was
received from all attorneys and self-represented parties receiving electronic delivery.
Name and address of each party and attorney that copy was or will immediately be mailed or
delivered to:

Malcolm E. Mason & Toni Boyle of 227 Chestnut Hill Avenue Waterbury, Connecticut 06704

Honor Ford July9, 2018
Signed (Signatt of, Print or type name of person signing Date Signed

61 Kendall Circle Waterbury, CT 06708 (203)756-897
Mailing address (Number, street, town, state and zip code) Telephone number

(P.B. 1978-1997, Sec. 231.) (Amended June 20, 2011, to take effect Jan. 1, 2012.) P.B. 1978-1997, Sec. 232.) (Amended June 23,
2017, to take effect Jan. 1, 2018.).
No. CV- UWY-CV-17-5018769-s : SUPERIOR COURT

Ford, Honor : JUDICIAL DISTRICT

VS. OF WATERBURY

Mason, Malcolm AT WATERBURY, CONNECTICUT

: OCTOBER 18, 2017

PLAINTIFF’S FIRST SET OF INTERROGATORIES

The undersigned Plaintiff, Honor Ford, hereby propounds the following interrogatories.
to

be answered or information to be provided by the Defendant, Malcolm E. Mason, within set days

of the filing hereof in compliance with Practice Book Section 13-2 unless otherwise directed by

the Honorable Judge Barbara Brazzel-Mossaro.

For the purpose of these Interrogatories only, Plaintiff has used the definitions. set forth below.

Definition:

1 “You? shall nieari the Defendant to whom these interrogatories are directed.

a. ‘‘you”’ shall also refer to the Defendant of this interrogatory process.

b: “your” shall also refer to the Defendant of this interrogatory process in his or her

possession or pertaining to him or her own.

"Agreement" means a contract, arrangement, or understanding, formal or informal, oral

or written, between two or more persons.

"Any" means to refer to one-or more of a person, place or thing or number of, no matter

how much or many, means‘one or more.
Fe

a
UWY-CV-17-5018769-s
Ford v. Mason

4 "Communication" means any disclosure, transfer, or exchange of information or opinion,

however made.

“Violation” shall mean the action of violating someone or something, include but not be

limited to the; Bill of Rights and its amended components as they pertain to the citizens

of the United States, the Judiciary, Legislative and the Executive Branch of the law.

“Breach” shall mean an act of breaking or failing to observe a law, agreement, or code of

conduct.

“Humiliation” means indignity.

“Mental Anguish" translates to certain types of suffering that may include distress,

anxiety, fright, depression, grief, or trauma.

In answering these interrogatories, the Defendant is required to provide all information within his

or herknowledge, possession or power. If an interrogatory has subparts, answer each subpart

separately and in full and do not limit the answer to the interrogatory as a whole. If any

interrogatories cannot be answered in full, answer to the extent possible. If extra space is needed

utilize a clean sheet of paper.

(1) State the following:
1

(a) Your full name and any other name(s), including nick names by which you have been

known and/or acknowledged and/or referred to yourself. “4 MANS TS)
1 Unlealm <. M&san

Page 2 of 15
UWY-CV-17-5018769-s
Ford v. Mason

8
Ma Dave cS Bc,
(b) your date of birth; FlWhisce
() your physical home addresses and time frame for 2006 to 2017;

1 Gi Kewoall Csacl= tots Cr 2eag — Hepx Lama 2a
2 BITE Sylva Ave carBy CT 2eo1a- 2983

3 229 Chestrour rm BvS SNBy CT 221 B-Presenh

1G 4 2 Missr addvesr.
ANS 3 inclodir eas lasted on
6
4OnAree Repo BF Wi2 -cQ005 2ES ¢
dS Checks ¢ :
7

(e) your mailing addresses or any address other than your physical addresses for 2006 to

2017;

8 A
1 TD heus pe abe maclng dress
GR)
Oddresees mesing Soe
2

3
GO Mal
4
week & laguen | Pursomol.
5
Kh your business or work addresses from 2006 to 2017;

ew ae
s Kin ert Chek, Ne mljoeao CV SS Fiat
Wee - Zac?
Oly 2
O:sm Rs
AY
q
“1S L
a
Ny
My
B+
carer
Plas 32
Basnoss
has had
Address
PBech
fee
we SMHS
wo Releuane

oO we Past 3 of 15 Aelten

Pe whee bellers to my plece SP empleyment
UWY-CV-17-5018769-s
Ford v. Mason

\ ph iL (g) your electronic mail addresses form 2006 to 2017 including social media and sexual

Vi A‘explicit sites;

1 AS Ddmss o InN Previa yy ss > flash Be
ts de het Ne Cantact Oo Seno Theres xe wa, \
2 od Oro kino da mE, DS MY |-mead Qddey
3 hes Re C@lev ance ~
3
aa —_—— —
4

(2) Have you made any statements; as defined in State of Connecticut Practice Book Section 13-

1, to any person(s) regarding any of the incidents alleged in the Complaint?

COMMENT: TL hews walk mADe Ary BSaksmovts eagseliag dhe
cS
This interro;gatory 13 intended to Include party statements made to any person(s)whether public

or within private confinement and/or workplace prior to complaint and/or the involvement of

defense counsel.

(3) If the answer to Interrogatory #2 is affirmative, state:

Page 4 of 15
UWY-CV-17-5018769-s
Ford v. Mason

(a) The; date on which such statements were made, name and address of the person(s) to

whom such statements were made:

(b) The form of communication(s) the statements were made.

© The; name and ears of each person having custody, or a copy or copies of each statements.
swaks camPlmale Se
1 Any, at Paetes | Jaws \neo

owns os AK Kmivk && , ge Ble Knoas Whe dy
ERs sao hes be Contact them. oc Do wef Kass
Arey fF Han Pee ly

Page 5 of 15
—_—___-__

UWY-CV-17-5018769-s
Ford v. Mason

(d) What statements were made regarding Plaintiff motherly conduct and what was implied

regarding her ability to perform as a mother?

(4) How many times total did you vacate the shared residence of you and the Plaintiff whether by

force or will while you were married? 1 ches »nek cecal) ea dosay HF StressF
nae See
ey OF Ste
So
a. you were out of the house 24 hours the total of. mes

b. you were out of the house 2 days the total of times

¢. you were out of the house a week the total of times

d. you were out of the house a few weeks the total of times

you were out of the house a months the totalof__—— times (75039 ©
e.
— BPeciPre? cS dike
feFo2@
Nee
By sSace
OCS a

Page 6 of 15
UWY-CV-17-5018769-s
Ford v. Mason

f. you were out of the house a few months the total of. times

g. you were out of the house several months the total of times

(5)How well do you know the Plaintiff? TL Neos Em Qn She

Plawrs3h eq oer Ze Yraes, kewe hor:
Goel,

(6) Have you ever, during the acquaintance with the Plaintiff physicallystroke or by any means

cause injury, humiliation, or mental anguish to the Plaintiff? <7 | d= wet Boca// TOT
Such Ic ands ith te FR nade ,

COMMENT:

(7) If question # six is affirmative, state:

a) When, listing any and all date and time.

1 Ns Stasno TL hase no Becle chan sk ae
ec pends
Page 7 of 15
UWY-CV-17-5018769-s
Ford v. Mason

b) List what preceded the incident and all causation of bodily injuries to the Plaintiff.
\X

c) Who, list witness (es).

Page 8 of 15

a
pow
UWY-CV-17-5018769-s
Ford v. Mason

q) What was subsequent to the incident.

e) List the method of action (i. e. kick, punch/slap, choke, heaved to the floor, pushed into

house fixtures, hit while sitting on top of Plaintiff, etc.) you performed that cause injury

to the Plaintiff during the years of acquaintance and/or knowledge of existence.
Bass mdyeres bo
17 O10 was fuse AY
9 Plankés. She nes ae eden Sue lacs kor =f
Bak Geelens Dune dn beh yees %S & un,
LEN 2 RN,

Page 9 of 15
UWY-CV-17-5018769-s
Ford v. Mason

(7) Have you ever, by means of action or inaction, disobeyed an order of the legislative or

Judicial Branch of the law or rules set by organizations?
_* TF have ahi
(8) if # seven is affirmed then list means and dates to your fullest capacity:

a)
b)
c)
qd)
e)
i
8)
h)
9). Are you aware of any photographs and/or documents depicting incident alleged in the

Complaint of this lawsuit and/or injuries?
0 ee
favs ve Kale d ob any Pras
thieg tet
he’
£ Dacre He
10) List dates of visitation agreehnent!
Nat si S& h- Wl Do TL
ent/arrangement andiot responsibilities ordered by the Judicial >» ay
Smd Jans
Branch from 2009 to August 2, 2012 regarding any minor children.

a) fro SS hes thes iwisacho wm as dhe ors paah ue

18)How many times have you submitted proof to the Courts of the Plaintiffs erratic action

towards minors that resulted in injuries to minor and subsequent healthcare visits?

list dates below.

a) Planner dd has & Recaro S Srargth. Sabbou tsp bg
He cart Be Ske LdAD CA 1ANCloea Gert od~
Page 12 of 15 BU Dates hen Ske chose de shou ape
UWY-CV-17-5018769-s
" Ford v. Mason
b)

°)
d)
8)
f)
8)

h)
19) According to the Constitution, what are the rights of an individual child? x Q= Sor

Kae Ede re cones hukas SANS Aa Mus,

K his Geek Keg me celevanca, cep db Ke
oe,

Cam placast Sle s 8g 5 wish thes, oe lenoani.
ee.
i .
~ —

20) Have you, by manner of action or inaction; affirm breach of any of these individual rights in

any way while any minor was under your care? _ ajc

21) Have communication by any means been initiated from any minor under your care to the

Plaintiff at least once a week since August 2, 2012? fy

22) Has initiation of communication been advised against by the Courts in any way? (lawhSS. ox,
Casspec ey Cea} acne F SuowcseD Yrs \
23)At any point were you ordered to write a release of information to the Board of Education and

all healthcare givers regarding Plaintiff rights of information regarding any minor child? 425

Page 13 of 15
UWY-CV-17-5018769-s
Ford v. Mason

24) Were you aware of the letter sent with your signature through Toni Boyle’s email-regarding

the Complaint in the lawsuit to individuals that you do not know? NZD

25) Is there anyone in your household deserving of and receiving assistance and/or therapy for

mental ill health or issues?_ WO

PLAINTIFF

op
Honor Ford (self-representative)

LLP tesa hereby certify that I have reviewed the above
interrogatories and responses thereto and that they are true and accurate to the best of my

knowledge and belief.
CHA.
Subscribed and sworn to before me this . _—___$day of 2 Trasataiy
2013.

Notary Public/ . Maman & Ponahie
Commissioner of the Superior Court

SHANNON B. DONAHUE
Noiary Public
My Commission Expies August 31, 2021

Page 14 of 15
No. CV- : UWY-CV-17-5018769-s SUPERIOR
: COURT

Ford, Honor : JUDICIAL DISTRICT

VS. OF WATERBURY
Mason, Malcolm : AT WATERBURY, CONNECTICUT

: MAY 7, 2018

RE: § 13-2 Scope of Discovery; In General,
§13-6 Interrogatories; In General
§13-7 Answers te Interrogatories;
§13-9 Requests for Production, Inspection and Examination;
§13-15 Continuing Duty to Disclose.

To Defendant
M. Mason,

Enclosed is the answers to the interrogatories that you had previously submitted to me. Please
forgive the lateness of these answers. My sincere apologies for the inconvenience.

Kindly forwar the answers
d to all inquiries of October 18, 2017. Please be advised that the most
recent orders by the Superior Court of Waterbury proclaims that each question in to be answered
in full. Furthermore, all information are public within-these civil proceedings. Therefore, all
answered that were skipped or deemed irrelevant to the case, that were not in fact irrelevant to
said case, are hereby requested to be answered with factual and true answers. As directed by the
Honorable Judge Barbara Brazzel-Mossaro answers to interrogatory questions are to be
forwarded to Plaintiff's address by the allotted date as ordéied by the Superior Court of
Waterbury on April 23, 2018. This letter of request complies with Practice Book: § 13-2 Scope
of Discovery; In General, §13-6 Interrogatories; In General §13-7 Answers to Interrogatories;
§13-9 Requests for Production, Inspecti ion andExamination; §13-15 Continuing Duty to
Disclose.

Self-Representing Patty,

Honor Ford
61 Kendall Cir.
Waterbury Connecticut 06708
No. CV-: UWY-CV-17-5018769-s SUPERIOR COURT

Ford, Honor JUDICIAL DISTRICT OF WATERBURY

Vs AT WATERBURY, CT

Mason, Malcolm MAY 16, 2018

To Plaintiff H. Ford,

This defendant (Malcolm Mason) has received your letter of request to forward responses to all
inquiries dated October 18, 2017 sent to this defendant by you (the Plaintiff).

Please be advised that all responses to Plaintiff’s interrogatories dated October 18, 2017 were
responded to and mailed back as of January 6, 2018 per the original scheduling order issued on
September 21, 2017 (order #428420) by the court. Any questions that were not answered, the plaintiff
already has access to.

Thank for your time.

Self Representing Party,

Malcolm Mason
5LE
227 Chestnut Hill Avenue
Waterbury, CT 06704
TSU EO scat soi idiot es
No. CV-: UWY-CV-17-5018769-s + SUPERIOR. COURT

Ford, Honor : JUDICIAL DISTRICT

VS. OF WATERBURY

Boyle, Toni : AT WATERBURY, CONNECTICUT

: OCFOBER 18, 2017

éi
PLAINTIFE’S FIRST SET OF INTERROGATORIES

The undersigned Plaintiff, Honor Ford, hereby propounds the following interrogatories to.

be answered or information to be provided. by the Defendant, Toni Boyle, within set days. of the.

filing hereof in compliance with Practice Book Section 13-2 unless otherwise directed by.the

Honorable Judge Barbara Brazzel-Mossaro:

For the purpose of these Interrogatories only, Plaintiff:has used the definitions set forth below.

Definition:

1. ‘*You”’ shall mean the Defendant to whom these interrogatories are directed.

a. ‘‘you’’ shall also:refer to the Defendant of this-interrogatory process:

b. “your” shall also-refer to the Defendant of this interrogatory process-in his.or her

possession or pertaining to him or her own.

"Agreement" means.a contract, arrangement, or understanding, formal or informal, oral.

or written, between two or more persons.

"Any" means to-refer to one or more of a person, place or thing or number of, no.matter

how much or many, Means one or more.
UWY-CV-17-5018769-s
Ford v. Boyle

4, "Communication" means any disclosure, transfer, or exchange of information or opinion,

however made.

“Violate” shall mean the.action-of violating someone or something, include but not be

limited to the; Bill of Rights. and its.amended. components-as they pertain to the citizens

of the United: States, the Judiciary, Legislative and the Executive Branch of the law.

“Breach” shall mean an act of breaking or failing to observe a law, agreement, or code of

conduct.

“Humiliatio: means indignity.

“Mental Anguish" translates to certain types of suffering that may include distress,

anxiety, fright, depression, grief, or trauma.

In answe
these interrogatorie
ring s, the Defendant is: required-to provide all-information within his

or her knowledge, possession or power. If an interrogatory has subparts, answer each subpart

separately and. in full-and.do-not limit the answer to the interrogatory as a whole: If any

interrogatories cannot be answered in full, answer to the extent possible. If extra space is needed

utilize a clean sheet of paper.

(1) State the following:

(a) Your full name and any other name(s), including nick names by which you have been

known and/or acknowledged and/or referred-to yourself.

My rome ts “tom Boybe
2 IY common melname iS “Tuek.
3

Page 2 of 10
UWY-CV-17-5018769-s
Ford v. Boyle

(b) your date of birth; My Chote of birth 1s Jue 20, 1980
(d) your physical home addresses and time frame for 2006 to 2017;

1 Home address is 907 Chestrot Hill Ave
2 Pranous Nome addfess tas TQS Geldstream Dave
3

(e) yourmailing addresses orany address other than your physical addresses for 2006 to

2017;

* 1a ha no ote, mali Y nN4 gddéesses
Stirked above Gor Prams time period.
other than pope

x
your business or work addresses and time frame of employment from 2006 to 2017;

1M buspness worl addtesses roche No rekevance, or

Reconabke tatermaton Regarding the alle 5 Comgla at
x
opted the wh EF A] wad kad “te
A ConClosion th ths marke.
# A have been eile Ny ye a fl L time with the City
Of Bnstol Kom ob ~ 297,

Page 3 of 10

a ~
UWY-CV-17-5018769-s
Ford v. Boyle

(g) your electronic mail addresses form 2006 to 2017 including social media and sexual

explicit sites;

i My ehectroni ‘email address S mass O yahos com
:
2

(2) Have you made any statements, as defined in State of Connecticut Practice Book Section 13-

1, to any person(s) regarding any of the incidents alleged in the Complaint in this lawsuit?

‘
“IS do not Fecal) makin Ctakenments Feqa vain this
COMMENT: allege Complaint / (awsvit. This. dete wt did co-auther an Xvnai
Fan y
This interrogatory is intended to include party She fement ts made the lainbCls
to any person(s)
iste
wheths
ovy fights .
0]

public or within private confinement and/or workplace prior to complaint and/or the involvement

of defense counsel.

(3) If the answer to Interrogatory #2 is affirmative, state:

@) { date o which such statements were made, name and address of the person(s) or

organization to which such statements were made,

1 As Stoked in Interroaactoty #8, this ABedant only -has
‘K a inal ReGavding the. Plaintifls \isctahon

*
3 rans “to thinor child. Any ate Requesked infie maton by
x Ulaininte, the Plante has in hee session oF tnulrdge
4 there vf,

Page 4 of 10

~
UWY-CV-17-5018769-s
Ford v. Boyle

(b) The form of communication(s) the statements were made.

1 Ps Steed pheviasly this deBerdant has had communicator
wail woes the Plantiffs Visrietion rights to her
?
Fo Vi
x bine ‘.
3

* 1 Ths defendant
GN Wai) Regacdin
iminor child and
has Yo Khowh
the PlantiCes
Stakemets ater then

Plante {us this Fe
visitation fights vith

af
veched titer mation
in hee sion» Gnd knowhedge TE wot be Undohy burdensome.
An this deendant oF infwrmanon, thar the Plainkete alteady hos.

(d) What statements were made regarding Plaintiff motherly conduct and/or capabilities and/or

what was implied regarding her ability to perform as a mother:

a Tree wore no Fnawn Stakements by this deRendet
tn Reqavds to the any E tsthrechy Copabline. x
2

Page 5 of 10
UWY-CV-17-5018769-s
Ford-v. Boyle

3
4

(4) How well do you know the Plaintiff? Edo not know the Plante HCY well.

(5) How many times total did you visit the past-shared residence of the Malcolm Mason and the

Paintsre TF don Fecall goer visiting the past shared resichenee of Plaintitt.
6) How many of those times have you visited the resident of the Plaintiff to pick up minors for

children. before, I
visitation? have fode with chfendark #1
do Wet Peal a Sprerfic number of tes
te pel
ond wt We WE Victhedk the hav
(7) Have you ever, during the time of acquaintance and/or the knowledge that the Plaintiff exist

physically stroke and/or by any means violate Plaintiff's rights and/or cause injury, humiliation,
XE do ast Real) hen 6 Gw \ e yea) Coract with Hre
or mental anguish to the Plaintiff?” _Piainkif® and ts my k nowt dgx haw not vileked any
nN ~
8) How many times by method of your action or inaction (i.e. grab minor by his or her neck in

front of Plaintiff and push him or her inside your home and/or Malcolm Mason’s home and/or

grab minor by wrist and force them away from Plaintiff during walk in public and/or ignore

minor plea to see and/or call Plaintiff and/or tell minors they are not to touch any food in

Malcolm Mason’s home unless you give it to them and/or ignore weight loss of minors or

persons under your care and/or ignore any need for medical treatment and/or have a non-

professional individual glue wig on minor’s head then remove with steaming water) was witness:

by Plaintiff and/or the results of these inaction and/or action deliberately done to cause pain

and/or suffering to minor and/or Plaintife? his aehedant has not had an attroy
inaction dome Aelibrrate to a minor or the Planee
Page 6 of 10
trying to Cause. any pan, harm, etc.
UWY-CV-17-5018769-s
Ford v. Boyle

(9) Have you ever, by means of action or inaction, disobeyed an order of the legislative and/or

Judicial Branch of the law or rules set by organizations? To my Knowhed io do not belive ;
ave disshapeo l any ardes or Pubes staked ab
:

ah
10). Are you aware of any photographs or documents d ting incident alleged in the Complaint
iS GwUeShoh Seems ty owe of Seo
of this lawsuit and/or interrogatories regarding injuries? of wy auked and am wstte of wh
alkeqed incident Platité is PeFerving to in rc Comp nih
11). List dates of visitation agreement/arrangement and/or responsibilities ordered by the Judicial

Branch from 2009 to August 2, 2012 regarding any minor children and/or to present minor child.
Te Kk vested b +e Plame is within her Kaotalede
a)“Thi intormahon
‘4
f
SSeS] ON, Oi £ Powel and owt of ne Scope OF this defendant's compe
pose £ agteement die to the lisked time Lame. Any tiformetie
B Knookdee
LF covi ronda Wold be Com YA park) wherea the PlaintiCe
% chold have all the oboke dacumentatisn of at est Knowledge
ao tere ar.

12) How many text messages have you received from Plaintiff regarding visitation and/or
“Toth. st oF WW Y kn Ke and Recolkection this ch andavy
communication
to minor? has feed. No more than n Ue
ia
exh Messages Craven elaa ne
D2 Gar \asrtation.
13) How many were forward to (8) in fall 19q No mreseng wood have been Fyrvardvol
xe miner Childfern ac the CourT ov A cawtact only Via defendant.
14) How many were minor(s) allowed and/or enco’ uraged to "pe
Contact allowed ints ta be Sypernsed Ghd Wa
15) Have you ever ;
dete ?ndant.
mi As staked peeviens h, the oa

a)intercepted and/or read any letters intended for the shared child (ren) between Plaintiff

and Malcolm Mason? Na_beHecs have been Inker pte"Pg d {
ke cd
bt gis defend anh awd tet
Winer Ch Ren were ob sulvtehy ve to Com
b) intercepted and/or read any letters intended for the Plaintiff? No_kewe have vi Inikgicapt
Gnd = dy not Weall Rading any ovtgeing lens unless ce ayested hy,
c) intercepted and/or read any letters intended for the Malcolm Mason?
3 RS halve n tintecephed and I hare toad res addressed tt fa

f i
16) Are any of the shared child (ren) or adult under our care in need of special mental
Mt Cannot Tove he AN ANEo! MGTIO arding other adottc
assistance? pee Sonal [¢ onProlenh ah weed G\ it ermation. Tis defendant wy OF NO frinoe
Childen iy weed OF Speciglzed assistance under My care.

oesfh
17) How many adults live at 227 Chestnut hill Road? —— This defendant hes no Knay My
caryore Who Ket: S at gaq Che
Page 7 of 10
“This detmdont's add 5S, 3s 23 Cheshiet Hilt reno
and wiltigle, adolis. esi Resided. Rey
UWY-CV-17-5018769-s
Ford-v. Boyle

18) How many adults work outside of home for monet benefits living at 227 Chestnut hill
Stated in interragahry #IT, ths lant has no Knowkeda@e ef adults
Road? Urfeemation at aq] hestnut Hill Ra Bt this cheger ndants 4 SS OF ART
Chresiiut Hil Bye, three ate moth lots Who ake Xinfloyed-
19). List behaviors along with dates, locations, towards any minor child (ren) that you have

witness committed by the Plaintiff that caused harm to minor and list medical treatment

subsequently: given to-child (ren)?

t
2) To the best af this defadani’s Knosledg I have on witnessed
e,
Uawinked wieractions dunn treme ~Crame gf ala - aperoxim
Y ois
otad
.
belo OSL Plawti€E and hee miner childfen. Ths incldes tye
PlanaeGé Showing Up v mannomeed at Schorl basses and ths deCend ants
a plce of fesidenee- I have not witnessed ain ater iekecach ons
F between the Plaintiff and her childeen er a physcal basis aS she,
Vos Refused to Fallon the covrt avdeted yisttation process.
)
8)

h)
20) State the date; location and how you meet the Defendant Malcolm Mason?

TX do not eal any specific dake of locaton;
Yowerer IC do know at ib Was at Some pont during
the Spring oF Svinmer af 2607 T believe.

21) Are you aware of the records of arrest and corrective action that were enforced by the State

of Connecticut pertaining to Malcolm. Mason? |his deFendan+- has No knoubedge of
alkged information ac it Velakes te this Complaint.
Page 8 of 10
UWY-CV-17-5018769-s
Ford v. Boyle

22)Have you ever, by means of action or inaction, di beyed an order of the legi:slative and/or
is a answere dns “Taker oqatory
Judicial Branch of the law or rules set by organizations? Paice’ gs itis & duplicake of #9.
23) Were you and/or your immediate family (i.e. Mother, etc.) ever the recipient of state

assistance of any kind while any minor children and/or child and Malcolm Mason were living
sSeee aed LT cannot
with you and/or you living with them? ‘Spe Ic 6€ any others’ ceiving Such aisistance.
24) Have you ever been pregnant and/or gave birth to a child and/or children? fs + does not Relate +
Complaint by the Plaint-Ce; this debadants pesénalltredical information is confidential.
25) Have you, by manner of action and/or inaction; affirm breach of any of the individual rights,

as set forth in the Constitution of the United States and all its amended components, of any minor

child or children in any way while any minor child or children was under your care?
Within the Se € ts Gefeadonts kKnawked ge GE the Consttetion,£
Yar not beached amy indindval rights.

PLAINTIFF

woh§ Kon,
Honor Ford(self-representative)

, TEL sans ty ther ep
responses thereto and that they are true and accurate to the best of my knowledge and belief.

Subscribed and swom to before me this__S dh day of _

gov ort.

Notary Public) ,§ Abja men 2, Daakie
Commissioner of the Superior

SHANNON B. DONANUE,
Page 9 of 10 Notary Public
‘My Commission Expires August 31, 2021
No. CV- : UWY-CV-17-5018769-s : SUPERIOR COURT

Ford, Honor : JUDICIAL DISTRICT

VS. OF WATERBURY

Boyle, Toni : AT WATERBURY, CONNECTICUT

: MAY 7, 2018

RE: § 13-2 Scope of Discovery; In General,
§13-6 Interrogatories; In General
§13-7 Answers to Interrogatories;
§13-9 Requests for Production, Inspection and Examination;
§13-15 Continuing Duty to Disclose.

To Defendant T. Boyle,

Enclosed is the answers to the interrogatories that you had previously submitted to me. Please
forgive the lateness of these answers. My sincere apologies for the inconvenience.

Kindly forward the answers to all inquiries of October 18, 2017. Please be advised that the most
recent orders by the Superior Court of Waterbury proclaims that each question in to be answered
in full. Furthermore, all information are public within these civil proceedings. Therefore, all
answered that were skipped or deemed irrelevant to the case, that were not in fact irrelevant to
said case, are hereby requested to be answered with factual and true answers. As directed by the
Honorable Judge Barbara Brazzel-Mossaro answers to interrogatory questions are to be
forwarded to Plaintiff's address by the allotted date as ordered by the Superior Court of
Waterbury on April 23, 2018. This letter of request complies with Practice Book: § 13-2 Scope
of Discovery; In General, §13-6 Interrogatories; In General §13-7 Answers to Interrogatories;
§13-9 Requests for Production, Inspection and Ex:amination; §13-15 Continuing Duty to
Disclose.

Self-Representing Party,

Honor Ford
61 Kendall Cir.
Waterbury Connecticut 06708
No. CV-: UWY-CV-17-5

Case Info

Judge

ALICE BRUNO Track Judge’s New Case

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Document Filed Date

July 09, 2018

Case Filing Date

May 12, 2017

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Order: FORD,HONOR v. MASON,MALCOLM Et Al

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