DOCKETNO.: FST-CV19-6043034-S
`
`CHRISTOPHER SELKE
`
`V.
`
`BURLINGTON COAT FACTORY
`WAREHOUSEOF STAMFORD,INC. ET AL
`
`;
`
`;
`
`:
`
`:
`
`SUPERIOR COURT
`
`J.D. OF STAMFORD/NORWALK
`
`AT STAMFORD
`
`JULY 14, 2022
`
`REQUEST FOR LEAVE TO AMEND ANSWER AND SPECIAL DEFENSES
`
`Pursuant to Practice Book § 10-60(a)(3), the Defendant, Bedford West Holdings, LLC
`
`hereby requests leave to amend its Answer and Special Defenses in accordance with the proposed
`
`Amended Answerand Special Defenses attached hereto as Exhibit A.
`
`In accordance with § 10-
`
`60(b), an additional documentillustrating the changes proposed by the Defendant is attached
`
`hereto as Exhibit B.
`
`The Defendant requests leave to amend its Answer and Special Defenses in order to admit
`
`additional pleadings alleged in the Plaintiff's Complaint dated July 12, 2019 and Amended
`
`Complaint dated January 22, 2020. The Defendantis filing the attached in furtherance ofjudicial
`
`efficiency to further tailor and reduce the issues in dispute at the upcomingtrial. Therefore, no
`
`prejudice will result from the allowance of this Request for Leave to Amend.
`
`WHEREFORE,the Defendant, Bedford West Holdings, LLC, respectfully requests leave
`
`to amend its Answer and Special Defenses in accordance with the proposed Amended Answerand
`
`Special Defenses attached hereto as Exhibit A.
`
`{B1445184.1}
`
`
`
`CHRISTOPHER SELKE
`
`V.
`
`BURLINGTON COAT FACTORY
`WAREHOUSEOF STAMFORD,INC. ET AL
`
`;
`
`;
`
`:
`
`:
`
`SUPERIOR COURT
`
`J.D. OF STAMFORD/NORWALK
`
`AT STAMFORD
`
`JULY 14, 2022
`
`REQUEST FOR LEAVE TO AMEND ANSWER AND SPECIAL DEFENSES
`
`Pursuant to Practice Book § 10-60(a)(3), the Defendant, Bedford West Holdings, LLC
`
`hereby requests leave to amend its Answer and Special Defenses in accordance with the proposed
`
`Amended Answerand Special Defenses attached hereto as Exhibit A.
`
`In accordance with § 10-
`
`60(b), an additional documentillustrating the changes proposed by the Defendant is attached
`
`hereto as Exhibit B.
`
`The Defendant requests leave to amend its Answer and Special Defenses in order to admit
`
`additional pleadings alleged in the Plaintiff's Complaint dated July 12, 2019 and Amended
`
`Complaint dated January 22, 2020. The Defendantis filing the attached in furtherance ofjudicial
`
`efficiency to further tailor and reduce the issues in dispute at the upcomingtrial. Therefore, no
`
`prejudice will result from the allowance of this Request for Leave to Amend.
`
`WHEREFORE,the Defendant, Bedford West Holdings, LLC, respectfully requests leave
`
`to amend its Answer and Special Defenses in accordance with the proposed Amended Answerand
`
`Special Defenses attached hereto as Exhibit A.
`
`{B1445184.1}
`
`
`
`RESPECTFULLY SUBMITTED
`THE DEFENDANT
`BEDFORD WEST HOLDINGS, LLC
`BY ITS ATTORNEYS
`
`/s/443209
`
`Timothy R. Scannell, Esq.
`tscannell@boyleshaughnessy.com
`Ashley A Noel, Esq.
`anoel(@boyleshaughnessy.com
`Christina S. Cassidy, Esq.
`ccassidy@boyleshaughnessy.com
`Boyle | Shaughnessy Law,P.C.
`280 Trumbull Street, 23Floor
`Hartford, CT 06103
`Phone: (860) 952-9800
`Fax: (860) 278-7757
`
`{B1445184.1}
`
`
`
`EXHIBIT A
`
`
`
`DOCKETNO.: FST-CV19-6043034-S
`
`CHRISTOPHER SELKE
`
`V.
`
`BURLINGTON COAT FACTORY
`WAREHOUSEOF STAMFORD,INC. ET AL
`
`:
`
`:
`
`:
`
`:
`
`SUPERIOR COURT
`
`J.D. OF STAMFORD/NORWALK
`
`AT STAMFORD
`
`JULY 14, 2022
`
`AMENDED ANSWERAND SPECIAL DEFENSES
`
`The undersigned Defendant, Bedford West Holdings, LLC., hereby answers the Plaintiff's
`
`Amended Complaint, dated January 24, 2020, and Amends its Answerto the Plaintiffs original
`
`Complaint, dated July 12, 2019, as follows:
`
`FIRST COUNT: (Selke v. Ferguson Library of Stamford aka the Ferguson Library)
`
`The defendant, Bedford West Holdings LLC (hereinafter “Bedford West”), does not
`
`respond to this countasit is not directedto it.
`
`SECOND COUNT: (Selke v. Burlington Coat Factory Warehouse of Stamford, Inc.
`
`The defendant, Bedford West, does not respond to this count asit is not directed toit.
`
`THIRD COUNT: (Selke v. GBR Broad and SummerLimited Liability Company)
`
`The defendant, Bedford West, does not respond to this count asit is not directedto it.
`
`FOURTH COUNT: (Selke v. Gibraltar Management Co., Inc.)
`
`The defendant, Bedford West, does not respond to this count asit is not directed toit.
`
`FIFTH COUNT: (Selke v. LSR Stamford Holdings Limited Partnership)
`
`The defendant, Bedford West, does not respond to this count asit is not directedto it.
`
`SIXTH COUNT: (Selke v. Rubford, LLC)
`
`The defendant, Bedford West, does not respond to this count asit is not directedto it.
`
`SEVENTH COUNT:(Selke v. Bedford West Holdings, LLC)
`
`{B1445142.1}
`
`1
`
`
`
`1. The defendant, Bedford West, denies paragraph 1.
`
`2. The defendant, Bedford West, admits that it owned, controlled and/or maintained the
`
`property located at 94, 112, 120 Bedford Street in Stamford, CT, including the chain
`
`partition.
`
`3-4. As to paragraphs 3 and 4, the defendant, Bedford West, has insufficient knowledge or
`
`information upon whichto basea belief and, therefore, leavesthe plaintiff to his burden of
`
`proof.
`
`6.
`
`[sic.] As to paragraph 6, the defendant, Bedford West, has insufficient knowledge or
`
`information upon whichto basea belief and, therefore, leaves the plaintiff to his burden of
`
`proof.
`
`7.
`
`[sic.] As to paragraph 7, the defendant, Bedford West, has insufficient knowledge or
`
`information upon whichto base a belief and, therefore, leaves the plaintiff to his burden of
`
`proof.
`
`8.
`
`[sic.] The defendant, Bedford West, denies paragraph 8,
`
`including each of its
`
`subparagraphs.
`
`SPECIAL DEFENSE
`
`Atthe time andplacecited in the plaintiff's complaint,the plaintiff, Christopher Selke,
`
`was negligent and careless and such negligence and carelessness on his part caused or was a
`
`substantial factor in bringing about any injury or damages claimed by him. Theplaintiff was
`
`negligent and careless in one or more of the following ways:
`
`a.
`
`In that he failed to make properuse of his senses and faculties;
`
`b.
`
`In that he failed to watch where he wasstepping;
`
`c.
`
`In that he failed to keep a proper lookout;
`
`{B1445142 1}
`
`2
`
`
`
`d.
`
`In that he failed to take an alternate route.
`
`Respectfully Submitted,
`The Defendant,
`BEDFORD WEST HOLDINGS, LLC
`ByIts Attorneys,
`
`/s/443209
`
`Timothy R. Scannell, Esq.
`
`tscannell(@boyleshaughnessy.com
`Ashley A Noel, Esq.
`anoel@boyleshaughnessy.com
`Christina S. Cassidy, Esq.
`ceassidy(@boyleshaughnessy.com
`Boyle | Shaughnessy Law,P.C.
`280 Trumbull Street, 23" Floor
`Hartford, CT 06103
`Phone: (860) 952-9800
`Fax: (860) 278-7757
`
`{B1445142.1}
`
`
`
`EXHIBIT B
`
`
`
`DOCKETNO.: FST-CV19-6043034-S
`
`CHRISTOPHER SELKE
`
`V.
`
`BURLINGTON COAT FACTORY
`WAREHOUSE OF STAMFORD,INC. ET AL
`
`:
`
`’
`
`;
`
`:
`
`SUPERIOR COURT
`
`J.D, OF STAMFORD/NORWALK
`
`AT STAMFORD
`
`JULY 14, 2022
`
`AMENDED ANSWER AND SPECIAL DEFENSES
`
`The undersigned Defendant, Bedford West Holdings, LLC., hereby answers the Plaintiffs
`
`Amended Complaint, dated January 24, 2020, and Amends its Answerto the Plaintiff's original
`
`Complaint, dated July 12, 2019, as follows:
`
`FIRST COUNT: (Selke v. Ferguson Library
`
`of Stamford aka the Ferguson Libra
`
`The defendant, Bedford West Holdings LLC (hereinafter “Bedford West”), does not
`
`respondto this count asit is not directedto it.
`
`SECOND COUNT: (Selke v. Burlington Coat Factory Warehouse of Stamford, Inc.
`
`The defendant, Bedford West, does not respond to this count asit is not directed toit.
`
`THIRD COUNT:
`
`(Selke v. GBR Broad and SummerLimited Liability Compan
`
`The defendant, Bedford West, does not respond to this count asit is not directed toit.
`
`FOURTH COUNT: (Selke v. Gibraltar Management Co., Inc.)
`
`The defendant, Bedford West, does not respond to this count asit is not directed to it.
`
`FIFTH COUNT: (Selke v. LSR Stamford Holdings Limited Partnershi
`
`The defendant, Bedford West, does not respond to this count asit is not directed to it.
`
`SIXTH COUNT:(Selke v. Rubford, LLC)
`
`The defendant, Bedford West, does not respond to this countas it is not directed toit.
`
`(B1445167.1}
`
`1
`
`
`
`SEVENTH COUNT: (Selke v. Bedford West Holdings, LLC
`
`
`1. The defendant, Bedford West, denies paragraph1.
`
`
`
`2. The defendant, Bedford West, admits that it owned, controlled and/or maintained the
`
`property located at_94, 112, 120 Bedford Street in Stamford, CT, including the chain
`
`partition.
`
`3-4. As to paragraphs 3 and 4, the defendant, Bedford West, has insufficient knowledge or
`
`information upon whichto base a belief and, therefore, leaves the plaintiff to his burden of
`
`proof.
`
`6. [sic.] As to paragraph 6, the defendant, Bedford West, has insufficient knowledge or
`
`information upon whichto base a belief and, therefore, leaves the plaintiff to his burden of
`
`proof.
`
`7.
`
`[sic.] As to paragraph 7, the defendant, Bedford West, has insufficient knowledge or
`
`information upon whichto basea belief and, therefore, leaves the plaintiff to his burden of
`
`proof.
`
`8.
`
`[sic.] The defendant, Bedford West, denies paragraph 8,
`
`including each of its
`
`subparagraphs.
`
`SPECIAL DEFENSE
`
`At the time andplace cited in the plaintiff's complaint, the plaintiff, Christopher Selke,
`
`wasnegligent and careless and such negligence and carelessness on his part caused or was a
`
`substantial factor in bringing about any injury or damagesclaimed by him. Theplaintiff was
`
`negligent and careless in one or more of the following ways:
`
`a.
`
`In that he failed to make properuse of his senses and faculties;
`
`{B1445167.1)
`
`2
`
`
`
`b.
`
`In that he failed to watch where he wasstepping;
`
`c.
`
`In that he failed to keep a proper lookout;
`
`d.
`
`In that he failed to take an alternate route.
`
`Respectfully Submitted,
`The Defendant,
`BEDFORD WEST HOLDINGS, LLC
`ByIts Attorneys,
`
`/s/443209
`
`
`Timothy R. Scannell, Esq.
`tscannell@boyleshaughnessy.com
`Ashley A Noel, Esq.
`
`anoel@boyleshaughnessy.com
`Christina S. Cassidy, Esq.
`ccassidy(@boyleshaughnessy.com
`Boyle | Shaughnessy Law,P.C.
`280 Trumbull Street, 23" Floor
`Hartford, CT 06103
`Phone: (860) 952-9800
`Fax: (860) 278-7757
`
`(B1445167.1}
`
`
`
`CERTIFICATION
`
`This is to certify that a copy of the foregoing was or will immediately be mailed or
`delivered electronically or non-electronically on July 14, 2022 to all counsel and self-represented
`parties of record and that written consent for electronic delivery was received from all counsel and
`self-represented parties of record who wereor will immediately be electronically served.
`
`Karess Cannon — via email: kcannon@hl-law.com
`Howd & Ludorf, LLC
`65 Wethersfield Avenue
`Hartford, CT 06114
`
`ThomasP. Mullaney,III- via email: Imlawet(@libertymutual.com
`Meehan, Roberts, Turret & Rosenbaum
`108 Leigus Road, 1st floor
`Wallingford, CT 06492
`
`Olivia Tawa- via fax 860-760-8401
`Gfeller Laurie LLP
`977 Farmington Avenue, STE 200
`West Hartford, CT 06107
`
`Johnpatrick O’Brien — via email: jobrien@cohenandwolf.com
`Cohen and Wolf, P.C.
`1115 Broad Street
`Bridgeport, CT 06604
`
`/s/443209
`
`Christina S. Cassidy, Esq.
`
`(B1445167.1)
`
`4
`
`
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