On June 15, 2022 a case was filed
by
Joseph M. Kardok,
represented by
Matthew Julian Forrest,
against
Objection To Subpoena, and
Vera Signorelli,
represented by
Hassett & Donnelly Pc,
Ryan Ryan Deluca Llp, and
Sarah B Christie,
in the jurisdiction of New Haven County.
Judge ROBERT D ANDREA presiding.
Preview
DOCKET NO. UWY-CV22-6066037-S : SUPERIOR COURT
JOSEPH KARDOK : J.D. OF WATERBURY
V. : AT WATERBURY
VERA SIGNORELLI : APRIL 26, 2024
PLAINTIFF’S REPLY TO PROGRESSIVE DIRECT INSURANCE
COMPANY’S OBJECTION TO PLAINTIFF’S MOTION FOR ORDER
AND/OR MOTION TO PRECLUDE
The Plaintiff respectfully submits this reply to Progressive Direct Insurance Company’s
(“Progressive”) Objection (Entry No. 139.00) to Plaintiff’s Motion for Order and/or Motion to
Preclude (Entry No. 132.00). For the reasons below, in addition to those set forth in Plaintiff’s
motion, the objection must be overruled.
I. LAW AND ARGUMENT
A. Progressive’s Objection Must Be Overruled Because the Items Sought By the
Plaintiff Are Reasonably Calculate…
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