On July 27, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Roman Borysiuk,
and
Michele Masini,
Ryan Meagher,
for V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
in the District Court of New Haven County.
Preview
DOCKET NO. NNH-CV20-6106346-S : SUPERIOR COURT
ROMAN BORYSIUK : J.D. OF NEW HAVEN
V. : AT NEW HAVEN
MICHELE MASINI Et Al : JANUARY 24, 2022
06107• 203.399-0000
Connecticut 06901 • 203.913.4179
OBJECTION TO MOTION FOR ORDER OF COMPLIANCE
The plaintiff respectfully objects to the defendants’ Motion for Order of Compliance
dated January 24, 2022.
WEST HARTFORD, CONNECTICUT
First and foremost, the plaintiff has fully complied with discovery. As has been
communicated via emails on November 5, 2021; December 3, 2021; again on December 3,
#
LLC
Juris
# 438704
2021, along with the unrelated records; January 12, 2022; and again on January 12, 2022, there
Law Grouppsc
Esq.
Stamford,
TJC•ESQ,
are simply no treatment records with Dr. Aruna Seneviratne related to this collision of August
Goff,
263 Tresser Boulevard, 9th Floor •Juris
21, 2018. The plaintiff cannot produce something that does not exist.
A.
Goff
Brooke
Second, the defendants are bringing this claim of non-compliance when they themselves
have not complied with their discovery obligations for more than fourteen months. Trial is only
75 BRACE ROAD,
two weeks away, and the plaintiff is yet to receive discovery compliance. Such non-compliance
has been extremely prejudicial to the plaintiff as he was unable to confirm policy limits of the
defendants and timely file an offer of compromise. Despite the same, plaintiff has trusted in the
professionalism and representations of counsel and has not involved the Court. This is all to say
that that plaintiff has prosecuted his case in good faith, and more than complied with his
discovery obligations, even in the face of non-compliance by the defendants.
For all these reasons, the plaintiff respectfully requests the court deny the defendants’
motion for order of compliance.
Goff Law Group
TJC•ESQ, psc LLC
75 BRACE ROAD, WESTBrooke A. Goff, Esq.
HARTFORD, Juris #
CONNECTICUT 06107 • 203.399-0000
263 Tresser Boulevard, 9th Floor • Stamford, Connecticut
Juris # 438704 06901 • 203.913.4179
BY
-2 -
Juris # 438704
75 Brace Road
THE PLAINTIFF,
Tel: 203-399-0000
Fax: 203-295-3666
Hartford, CT 06107
Goff Law Group LLC
Elisabeth M. Swanson, Esq.
CERTIFICATION
I hereby certify that a copy of the above was electronically delivered on the above
referenced date to all counsel and self-represented parties of record and that written consent for
electronic delivery was received from all counsel and self-represented parties of record who were
electronically served.
Daniel Sanchez, Esq.
06107 • 203.399-0000
Mazza and Welch
• 203.913.4179
1375 Kings Highway East
Fairfield, Connecticut 06824
dsanchez@geico.com
06901
CONNECTICUT
Connecticut
By ______________________
LLC
Juris #
Elisabeth M Swanson, Esq.
Juris # 438704
Law Group
GOFF LAW GROUP, LLC
psc
A. Goff, Esq.
263 Tresser Boulevard, 9th Floor • Stamford,
TJC•ESQ,
HARTFORD,
Goff
75 BRACE ROAD, WESTBrooke
-3 -
Document Filed Date
January 24, 2022
Case Filing Date
July 27, 2020
Category
V01 - Vehicular - Motor Vehicles - Driver and/or Passenger(s) vs. Driver(s)
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DOCKET NO. NNH-CV20-6106346-S : SUPERIOR COURT ROMAN BORYSIUK : J.D. OF NEW HAVEN V. : AT NEW HAVEN MICHELE MASINI Et Al : JANUARY 24, 2022 06107• 203.399-0000 Connecticut 06901 • 203.913.4179 OBJECTION TO MOTION FOR ORDER OF COMPLIANCE The plaintiff respectfully objects to the defendants’ Motion for Order of Compliance dated January 24, 2022. WEST HARTFORD, CONNECTICUT First and foremost, the plaintiff has fully complied with discovery. As has been communicated via emails on November 5, 2021; December 3, 2021; again on December 3, # LLC Juris # 438704 2021, along with the unrelated records; January 12, 2022; and again on January 12, 2022, there Law Grouppsc Esq. Stamford, TJC•ESQ, are simply no treatment records with Dr. Aruna Seneviratne related to this collision of August Goff, 263 Tresser Boulevard, 9th Floor •Juris 21, 2018. The plaintiff cannot produce something that does not exist. A. Goff Brooke Second, the defendants are bringing this claim of non-compliance when they themselves have not complied with their discovery obligations for more than fourteen months. Trial is only 75 BRACE ROAD, two weeks away, and the plaintiff is yet to receive discovery compliance. Such non-compliance has been extremely prejudicial to the plaintiff as he was unable to confirm policy limits of the defendants and timely file an offer of compromise. Despite the same, plaintiff has trusted in the professionalism and representations of counsel and has not involved the Court. This is all to say that that plaintiff has prosecuted his case in good faith, and more than complied with his discovery obligations, even in the face of non-compliance by the defendants. For all these reasons, the plaintiff respectfully requests the court deny the defendants’ motion for order of compliance. Goff Law Group TJC•ESQ, psc LLC 75 BRACE ROAD, WESTBrooke A. Goff, Esq. HARTFORD, Juris # CONNECTICUT 06107 • 203.399-0000 263 Tresser Boulevard, 9th Floor • Stamford, Connecticut Juris # 438704 06901 • 203.913.4179 BY -2 - Juris # 438704 75 Brace Road THE PLAINTIFF, Tel: 203-399-0000 Fax: 203-295-3666 Hartford, CT 06107 Goff Law Group LLC Elisabeth M. Swanson, Esq. CERTIFICATION I hereby certify that a copy of the above was electronically delivered on the above referenced date to all counsel and self-represented parties of record and that written consent for electronic delivery was received from all counsel and self-represented parties of record who were electronically served. Daniel Sanchez, Esq. 06107 • 203.399-0000 Mazza and Welch • 203.913.4179 1375 Kings Highway East Fairfield, Connecticut 06824 dsanchez@geico.com 06901 CONNECTICUT Connecticut By ______________________ LLC Juris # Elisabeth M Swanson, Esq. Juris # 438704 Law Group GOFF LAW GROUP, LLC psc A. Goff, Esq. 263 Tresser Boulevard, 9th Floor • Stamford, TJC•ESQ, HARTFORD, Goff 75 BRACE ROAD, WESTBrooke -3 -