Motion to Compel Defendant Raymond J. Milot, Jr.
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| DOCKET NO: LLI-CV-21-5014019-S | : | SUPERIOR COURT |
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| JON A GOODWIN | : | J.D. OF LITCHFIELD |
| : | AT TORRINGTON | |
| V. | : | |
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| RAYMOND J. MILOT, JUNIOR, ET AL | : | November 6, 2023 |
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MOTION TO COMPEL
The plaintiff moves that the defendant Milot be compelled to answer each and every one of his attached discovery requests. In support of this motion, he represents as follows:
- Said discovery requests were served upon defense counsel on August 31, 2023.
- The defendant has not objected to any of the said requests.
- The defendant has not answered any of the said requests.
- On or about November 1, 2023, the undersigned emailed defense counsel inquiring when the defendant would respond to the said requests, but defense counsel has not responded.
- Good faith efforts to obtain voluntary compliance from the defendant having failed, the plaintiff respectfully requests court intervention.
CERTIFICATION OF SERVICE
THE PLAINTIFF
BY: /s/ (#067962)
51 Elm Street
JOHN R. WILLIAMS (#67962)
203-562-9931
New Haven, CT 06510
Fax: 203-776-9494
[redacted]@johnnwiliams.com
On the above date, a copy hereof was sent to: Rebecca Mayo Goodrich, Esq., Conti Levy Salerno &Antonio, LLC, P. O. Box 239, Torrington, CT 06790, rgoodrich@contilevylaw.com
/s/ (#067962)
JOHN R. WILLIAMS