On April 24, 2023 a
Order
was filed
involving a dispute between
Patrick Goodale,
and
The Renaissance Collaborative, Inc.,
Y-D Trailer Court, Llc,
for T03 - Torts - Defective Premises - Private - Other
in the District Court of New Haven County.
Preview
NNH-CV-23-6132118-S : SUPERIOR COURT
PATRICK GOODALE : J.D. OF NEW HAVEN
VS. : AT NEW HAVEN
Y-D TRAILER COURT, LLC, ET AL : APRIL 10, 2024
MOTION FOR DEFAULT/SANCTIONS
FOR FAILURE TO COMPLY WITH COURT ORDER
Pursuant to CT Practice Book, Section 13-14, the Plaintiff, PATRICK GOODALE, hereby
respectfully requests for an order that a default and sanctions enter against the defendants, Y-D
TRAILER COURT, LLC and THE RENAISSANCE COLLABORATIVE, INC. for their failure
to respond to plaintiff’s written Interrogatories and Request for Production dated May 4, 2023.
As of this date, the plaintiff has not received compliance from the defendants.
The plaintiff served Interrogatories and Request for Production on May 4, 2023. On
June 30, 2023, defendants filed a Motion for Extension of Time until August 3, 2023. On
December 1, 2023, plaintiff filed a Motion for Order of Compliance and on March 18, 2024,
honorable Judge Stewart granted that request and noted in her order that compliance is ordered
on or before April 8, 2024. Judge Stewart also noted in her order that “If the moving party does
not receive compliance by that date, the moving party may file a motion for sanctions pursuant
ORAL ARGUMENT NOT REQUESTED
TESTIMONY NOT REQUIRED
1
to Practice Book Section 13-14 that refers to this order. Absent proof of compliance on file
before the motion appears on this short calendar or a finding by this court of good cause for any
non-compliance, sanctions will be ordered. (See Entry 113.10).
As of this date, April 10, 2024, plaintiff still has not received Interrogatory responses sent
on May 4, 2023. The plaintiff now moves this court for an order of default and sanctions
against the defendants. The plaintiff needs discovery to prosecute his case, take the deposition
of the defendants and for additional discovery/interrogatories.
WHEREFORE, the plaintiff respectfully requests:
1) An order for default, and;
2) An order awarding the plaintiff of the cost on this motion, including a reasonable
attorney’s fee.
THE PLAINTIFF
PATRICK GOODALE
BY________/s/101233____________
GEORGE H. CHARLESWORTH, JR.
47 LAWRENCE STREET
NEW HAVEN, CT 06511
NO#: (203) 624-5928
HIS ATTORNEY
2
ORDER
The foregoing motion having been heard, this Motion for Default/Sanctions, is hereby -
ORDERED: GRANTED / DENIED
BY THE COURT
________________________________
JUDGE / CLERK
3
CERTIFICATION
I hereby certify that a copy of the foregoing was emailed this 10th day of August, 2023 to
the following:
Law Offices of Christopher M. Connelly
95 Glastonbury Blvd.
Suite 400
Glastonbury, CT 06033
Atty. Christopher Connelly
cconnelly@hanover.com
avalonis@hanover.com
__________/s/101233_______________
GEORGE H. CHARLESWORTH, JR.
4
Document Filed Date
April 10, 2024
Case Filing Date
April 24, 2023
Category
T03 - Torts - Defective Premises - Private - Other
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NNH-CV-23-6132118-S : SUPERIOR COURT PATRICK GOODALE : J.D. OF NEW HAVEN VS. : AT NEW HAVEN Y-D TRAILER COURT, LLC, ET AL : APRIL 10, 2024 MOTION FOR DEFAULT/SANCTIONS FOR FAILURE TO COMPLY WITH COURT ORDER Pursuant to CT Practice Book, Section 13-14, the Plaintiff, PATRICK GOODALE, hereby respectfully requests for an order that a default and sanctions enter against the defendants, Y-D TRAILER COURT, LLC and THE RENAISSANCE COLLABORATIVE, INC. for their failure to respond to plaintiff’s written Interrogatories and Request for Production dated May 4, 2023. As of this date, the plaintiff has not received compliance from the defendants. The plaintiff served Interrogatories and Request for Production on May 4, 2023. On June 30, 2023, defendants filed a Motion for Extension of Time until August 3, 2023. On December 1, 2023, plaintiff filed a Motion for Order of Compliance and on March 18, 2024, honorable Judge Stewart granted that request and noted in her order that compliance is ordered on or before April 8, 2024. Judge Stewart also noted in her order that “If the moving party does not receive compliance by that date, the moving party may file a motion for sanctions pursuant ORAL ARGUMENT NOT REQUESTED TESTIMONY NOT REQUIRED 1 to Practice Book Section 13-14 that refers to this order. Absent proof of compliance on file before the motion appears on this short calendar or a finding by this court of good cause for any non-compliance, sanctions will be ordered. (See Entry 113.10). As of this date, April 10, 2024, plaintiff still has not received Interrogatory responses sent on May 4, 2023. The plaintiff now moves this court for an order of default and sanctions against the defendants. The plaintiff needs discovery to prosecute his case, take the deposition of the defendants and for additional discovery/interrogatories. WHEREFORE, the plaintiff respectfully requests: 1) An order for default, and; 2) An order awarding the plaintiff of the cost on this motion, including a reasonable attorney’s fee. THE PLAINTIFF PATRICK GOODALE BY________/s/101233____________ GEORGE H. CHARLESWORTH, JR. 47 LAWRENCE STREET NEW HAVEN, CT 06511 NO#: (203) 624-5928 HIS ATTORNEY 2 ORDER The foregoing motion having been heard, this Motion for Default/Sanctions, is hereby - ORDERED: GRANTED / DENIED BY THE COURT ________________________________ JUDGE / CLERK 3 CERTIFICATION I hereby certify that a copy of the foregoing was emailed this 10th day of August, 2023 to the following: Law Offices of Christopher M. Connelly 95 Glastonbury Blvd. Suite 400 Glastonbury, CT 06033 Atty. Christopher Connelly cconnelly@hanover.com avalonis@hanover.com __________/s/101233_______________ GEORGE H. CHARLESWORTH, JR. 4