MOTION FOR ORDER Motion to Stay Discovery

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                          DOCKET NO.: HHD-CV-20-6121431-S B SUPERIOR COURT

BETH RODRIGUEZ J.D. OF HARTFORD
v. AT HARTFORD

PROPERTY AND CASUALTY INSURANCE

COMPANY OF HARTFORD B JUNE 19, 2020

MOTION TO STAY DISCOVERY

 

Pursuant to Connecticut Practice Book §§ 13-5, et seq. the defendant, Property
and Casualty Insurance Company of Hartford (“The Hartford”), hereby respectfully moves
to stay any bad faith and extracontractual discovery pending a ruling on The Hartford's
Motion to Strike, dated April 15, 2020. [Dkt. # 103.00]. In this respect, reference is made
to the Plaintiffs Interrogatories and Requests for Production dated April 20, 2020,
attached hereto as Exhibit A (hereinafter referred to as “subject discovery requests’). ?

As articulated more fully in The Hartford's memorandum of law in support of its
Motion to Strike [Dkt. # 104.00], the plaintiff's allegations of bad faith insurance practices
and ailegations of violations of the Connecticut Unfair Trade Practices Act are legally
insufficient. Disc…