`
`J.D. OF STAMFORD NORWALK
`
`AT STAMFORD
`
`MAY 9, 2022
`
`*
`*
`
`**
`
`**
`
` FST-CV-21-6054451
`
`VINCENT P. LAROBINA
`
`V.
`
`ALTICE MEDIA SOLUTIONS, LLC
`DBA. OPTIMUM
`
`*
`
`**
`
`**********************************************
`
`MOTION FOR PROTECTIVE ORDER
`
`On May 3, 2022, the defendant, Altice Media Solutions LLC d/b/a Optimum
`(“Altice”), filed a notice of deposition upon the plaintiff, Vincent P. Larobina, scheduled for
`May 10, 2022.
`The instant declaratory action is primarily an issue of law and all the material facts
`are before the Court (Hon. Povodator, J.). After consideration, the plaintiff cannot discern
`any information that he might have that could aid the defendant in formulating its defense.
`Additionally, all communications between Altice and Larobina were conducted by
`telephone or online. Altice records all telephone calls. Therefore, all relevant facts are in
`the defendant’s possession.
`Accordingly, the plaintiff believes the deposition constitutes annoyance and
`oppression. Wherefore, pursuant to P.B. §13-5, the plaintiff respectfully requests that the
`Court enter a protective order.
`Alternatively, if the Court allows the deposition to go forward, the plaintiff respectfully
`requests that the Court issue an order that the deposition be taken remotely. The plaintiff
`is within an age group that potentially suffers adversely from Covid. The plaintiff cannot see
`any prejudice to the defendant in conducting a virtual deposition.
`
`1
`
`
`
`Respectfully Submitted,
` /s/Vincent Larobina
`
`CERTIFICATION
`The plaintiff certifies that he has sent a copy of this pleading to the Defendant’s
`Counsel by electronic mail contemporaneous with the filing of the pleading.
`
`/s/ Vincent Larobina
`
`2
`
`
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