Reply to Defendant's Motion for Protective Order

Plaintiff Jon Goodwin herewith replies to Defendants' Motion for Protective Order (Dkt. 124), filed September 20, 2023, as follows:

Introduction

This case springs from ex-convict and substance abuser Defendant Heather Walsh and her husband Defendant Eric Walsh's terrorizing and waging a broad defamation campaign against their immediate neighbors, Plaintiffs Jon Goodwin and Christine Jowdy, in an extortionate effort to cause them to discontinue inhabiting the property where they reside and causing them to pay for a professional arborist to trim and remove trees overhanging their property that defendants are responsible for maintaining.

Defendants Heather Walsh and Eric Walsh are foreign substance addled, delusional, nut-jobs who constantly express irrational paranoia. They have threatened Mr. Goodwin and Ms. Jowdy, on multiple occasions, and have caused third parties to threaten Mr. Goodwin. In the past, the Walsh's anti-social conduct was so bad, their parents requested the Connecticut Department of Children and Families ("DCF") intervene to protect their grandchildren.

Mr. Goodwin and Ms. Jowdy are not the Walsh's only victims. Defendant Heather Walsh has bullied and waged "war" with other of her neighbors, a construction worker and at least one business located in North Canaan where they live. Despite Plaintiffs applying for a temporary injunction to cause Defendant Heather Walsh and Defendant Eric Walsh to discontinue their video recording of them, shining bright lights on their property, etc. (Dkt. No. 101), to this day, Defendants continue their pattern of harassing conduct. The Walshes continuing conduct has caused Mr. Goodwin and Ms. Jowdy significant injuries, including economic injuries. Their harassment and video surveillance of Plaintiffs on their property has been continuous, causing Ms. Jowdy and Mr. Goodwin not to use their pool this year. So fearful is Ms. Jowdy of the Walshes, she refuses to be in her home without Mr. Goodwin there and has lived away from her property much of the spring summer awaiting this Court to take action to provide relief from the Walsh's terroristic conduct.

Background

Defendant Heather Walsh and Defendant Eric Walsh are represented in this action by Steven "Lying" Levy, a despicable lawyer who has repeatedly made: "false statements of material fact," "asserted fabrications" and disrespected the rights of third parties. See Gina Bunch, Complainant vs. Steven Levy, Respondent; Grievance Complaint #04-0871, which is a decision of the Connecticut Statewide Grievance Committee reprimanding Steven Levy for violating Rules of Professional Conduct 4.1(1) and 4.4 (). This Court can take judicial notice of Levy's past pattern of making false statements, asserting fabrications, and disrespecting the rights of third parties.

Plaintiff Goodwin is sixty (60) years old. Unlike Defendant Heather Walsh and Defendant Eric Walsh, Mr. Goodwin has never been arrested as an adult. And, unlike Heather Walsh, Mr. Goodwin ever been convicted of a misdemeanor or felony.

During a deposition of a non-party witness, at the office of Mr. Goodwin's and Ms. Jowdy's counsel on August 22, 2023, Lying Lawyer Levy acted threateningly and provocatively toward Mr. Goodwin. When Mr. Goodwin informed Lying Levy he was aware that he had been reprimanded by the Statewide Grievance Committee, Levy mockingly replied "oh, you can read," then called Mr. Goodwin a "creep."

Cognizant of the accusation that Lying Lawyer Levy burned an opposing party with a cigarette, and because of Levy's attempt to instigate an altercation, prior to the start of the deposition, Mr. Goodwin requested Levy keep his hands in a place where Mr. Goodwin could see them. Approximately one-half hour after Mr. Goodwin requested Levy's cooperation, Levy placed a briefcase on his lap, opened it, moved his hands inside and fumbled with something in a manner which was clearly orchestrated to cause Mr. Goodwin to suspect Levy was loading a gun. When Mr. Goodwin did not react to Levy's theatrics, Levy contorted his face at Mr. Goodwin multiple times, then falsely stated to everyone in the room that Mr. Goodwin was acting creepily toward him.

Plaintiff's Notice to Take the Deposition of Heather Walsh at TORRINGTON CITY HALL

Because of Lying Lawyer Levy's past transgressions, his provocative conduct as well as his client's pattern of bullying and threatening their adversaries, Mr. Goodwin designated the location of the deposition of Defendant Heather Walsh as "140 Main Street, Room 215," in Torrington which is TORRINGTON CITY HALL. See Exhibit A, of the RENOTICE OF DEPOSITION appended to Defendants' Motion for Protective Order.

Plaintiff settled on Torrington City Hall after attempting arrange for a room at the Litchfield Judicial District Courthouse at 50 Field Street in Torrington and being informed by the Civil Clerk's Office that the Court does not provide such facilities.

Defendants' Motion for Protective Order

Prior to filing the Motion for Protective Order, Lying Lawyer Levy made no effort to contact Plaintiff to discuss his intent to cause this Court to delay Plaintiff taking his loutish client's depositions or to arrange a date and time suitable to his and, Plaintiff's and Plaintiff's counsel's schedule. Instead, Lying Levy filed his motion, then emailed it to Plaintiff stating: "Please see the Motion for Protective Order attached. Pursuant to case law, the deposition cannot proceed until the court rules on the motion, or if we reach an agreement concerning the terms of the motion. Therefore, my client and I will not be attending the deposition as noted."

Had Lying Levy attempted to communicate with Plaintiff prior to filing the motion for protective order, he would have known the Litchfield Judicial District Courthouse does not provide such services. And, Plaintiff would have rearranged the date and time of the deposition to accommodate his schedule. But Levy did not do that, instead he filed the "Motion for Protective Order" to indefinitely prolong discovery and proceedings on which such discovery relies and using that opportunity to fraudulently cast aspersions on Plaintiff.

Lying Levy bases his request for a protective order on the allegation that Mr. Goodwin "behaved in a strange and bizarre manner that concerns [him]." His allegation lacks specificity and is in substance an attempt to assert fabrications. Because Levy cites no specific conduct by Plaintiff Goodwin toward him or his irrationally paranoid, ex-convict client and her trollish husband that would constitute a threat or even a "concern" by a rational person, this Court must reject his and his clients' demand for a "protective order."

Lying Levy provides no examples of a secure facility with a "metal detector" in Litchfield County other than "the courthouse" that, as described above does not provide rooms to the public for Plaintiff to take his clients' depositions and Plaintiff knows of no such facility. Consequently, this Court granting defendants' motion for protective order would indefinitely prolong Plaintiff taking their depositions. Delaying legal process is one of Levy's and his boorish client's aims and Plaintiff respectfully requests this Court reject his attempts and deny the motion.

Levy's Ulterior Motivation

Upon information and belief, it's not Mr. Goodwin who Lying Levy is actually concerned about, rather, it's his ex-convict, client's, ex-convict father, ex-convict brother and their associates who have presumably figured out that Lying Levy has a conflict of interest and that Levy and his associates are using Heather Walsh and Eric Walsh as pawns to further a scheme involving another client of his law firm who has corrupted the of morals of children and is neglecting their interests to perpetrate frauds on a court in this judicial district and Plaintiffs. Levy's problems with the management of his greed over his clients' interests should not be allowed to interfere with Plaintiff's prosecution of this case.

Lying Levy's behavior is that of a shallow man, making a parasitic living harming children while soiling the image of the legal system and good people who work tirelessly to uphold its integrity. Plaintiff will be forwarding this reply to the Statewide Grievance Committee with a request that they investigate the matters cited herein. Levy's motion is not tendered in good faith, rather, it is clearly being asserted to delay discovery in this case and proceedings for which such discovery is required. Accordingly, Plaintiff respectfully requests this Court sanction Levy $5,000 to compensate Plaintiff for: his time to reply to this motion, his time to cancel arrangements made to take Defendant Heather Walsh's deposition, for costs to serve the RENOTICE OF DEPOSITION on Levy's clients, for costs to file this reply and for such other relief as this Court deems just and proper.

JON GOODWIN

By:_ /s/ Jon Goodwin

Plaintiff in Pro Se

CERTIFICATION OF SERVICE

I certify that a copy of this document was mailed or delivered electronically or non-electronically on October 22, 2023 to all attorneys and self-represented parties of record and to all parties who have not appeared in this matter and that written consent for electronic delivery was received from all attorneys and self-represented parties receiving electronic delivery.

Steven "Lying" Levy, Esquire
Conti Levy Salerno & Antonio, LLC
P.O. Box 239
Torrington, CT 06790
slevy@contilevylaw.com

Rob Serafinowicz, Esq.
Counsel to: Jon Goodwin and Christine Jowdy
520 South Main St.
Naugatuck CT 06770

Christine Jowdy

By: /s/ Jon Goodwin
Plaintiff in Pro Se