Party Notice: BURTON,NANCY v. MASON,DAVID PHILIP

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                UWY-CV-21-5028294-S
NANCY BURTON                                               SUPERIOR COURT
                                                           JUDICIAL DISTRICT
               Vv.                                         OF WATERBURY

DAVID PHILIP MASON
 ETAL.                                                     AUGUST 285, 2021


                PLAINTIFF’S PROPOSED SPECIAL INTERROGATORIES
                     DIRECTED TO DEFENDANT DAVID PHILIP MASON




    Plaintiff Nancy    Burton hereby propounds the following Proposed Special
Interrogatories, all    as addressed to Paragraph 21 of the Affidavit attached to the Special
Motion to Dismiss      filed by Defendant David Philip Mason, and to be answered by
Defendant Mason,        under oath, within such time period as shall be set by the Court:


   1. With regard to the issues, facts and circumstances set forth in the complaint, as
      amended, in this action, please identify in detail by date, location, manner and
      method of exercise (whether orally or in writing) and method of communication of
      such exercise (whether orally, by mail, by email, by social media, to the news
      media or any other method of communication) all instances and occasions when
      you have exercised your “right to petition the government” as the phrase “right to
      petition the government” is used in your Special Motion to Dismiss dated June
      10, 2021, and the names, positions and addresses of the individuals and entities
        and agents of governmental entities and all others to whom such communications
        were directed.




   2.   With regard to the issues, facts and circumstances set forth in the complaint, as
        amended, in this action, please identify in detail by date, location, manner and
        method of exercise (whether orally or in writing) and method of communication of
such exercise (whether orally, by mail, by email, by social media, to the news
     media or any other method of communication) all instances and occasions when
     you have exercised your “right of association” as the phrase “right of association”
     is used in your Special Motion to Dismiss dated June 10, 2021, and the names,
     positions and addresses of the individuals and entities and agents of
     governmental entities and all others to whom such communications were
     directed.




      With regard to the issues, facts and circumstances set forth in the complaint, as
     amended, in this action, please disclose the exact words, language and verbiage
     used in each and every such communication as identified above in paragraphs 1
     and 2.




     Please provide the facts which lead you to conclude that the instant suit is based
     on your alleged exercise of your “right to petition the government” and/or your
     “right of association.”




5.   Do you claim that the instant suit is based in part on your exercise of your “right
     to free speech’ and if so please provide the facts which lead you to formulate
     such a claim.
6.   Please identify all occasions by date and manner and method of communication
     (oral or written) during which you have initiated communications with plaintiff
     Nancy Burton and state the substance of each such communication.




7.   Please identify all activities and communications you have engaged in with others
     regarding farm equipment, motor vehicles and other issues concerning plaintiff's
     property located at 147 Cross Highway, Redding, Connecticut, from October
     2010 to the present.




     Please set forth in detail your account of events and your personal observations!
     of such events of April 30, 2021 during which you claim in your Special Motion to
     Dismiss and attached Affidavit, both dated June 10, 2010, that, according to your
     Affidavit, “one of the Plaintiff's goats ran onto Cross Highway and was struck by a
     vehicle and seriously injured”; whether you personally observed one of plaintiff's
     goats running onto Cross Highway and being struck by a vehicle and seriously
     injured; and if you did not personally observe such activity please identify how
you “learned? of the alleged goat injury, as set forth in Paragraph 15 of your
     Affidavit.




9.   Please set forth in detail all communications, including dates of such
     communications and the substance of such communications, you have had with
     plaintiff with regard to your claims that plaintiff's goats entered upon your property
     and all other communications you have had with plaintiff.




10. Please identify by date and time and substance all communications you have had
     with Charles DellaRocco, Connecticut Department of Agriculture ("DOAG”)
     animal control officer regarding yourself, your property, events of April 30, 2020
     involving plaintiff and her goats, the complaint plaintiff filed with DOAG
     Commissioner Bryan Hurlburt concerning the said events of April 30, 2020 and
     the outcome of the complaint.
11. Please provide dates of all written and oral communications between yourself
    and defendant Gibbons and Charles DellaRocco, Jeremiah Dunn, Bryan Hurlburt
   and DOAG    staff, other state government officeholders in the executive, legislative
   and judicial branches and their staffs and the substance of each such
   communication and any response (s) received.




12. Please state whether you participated in a social media campaign and the dates
    whereof to encourage members of the public to contact members of the judiciary
    of the State of Connecticut to communicate negative remarks about plaintiff and
    her goats and the substance and method of delivery — by mail, email, social
   media, telephone, text, or in-person communication or any other means - of each
   such communication.
QATH




                                                David Philip Mason
STATE OF CONNECTICUT


COUNTY OF FAIRFIELD
Sworn to and subscribed before me this    day of     , 2021,



        Notary Public
THE PLAINTIFF



                                   Nancy      ion
                                   147 Cross Highway
                                   Redding CT 06896
                                   Tel. 203-313-1510
                                   NancyBurtonCT@aol.com




                                     CERTIFICATION
This is to certify that a copy of the foregoing was electronically delivered on August 25,
2021 to all counsel of record.



                                         Fe