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`DOCKET NO.: NNH-CV-22-6120225S
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`DANIELLE ARRUCCI-MIGLIACCI
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`VS.
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`GINWAY LIN, 9 EAST CORPORATION
`d/b/a 9 EAST HIBACHI, ASIAN KITCH
`PABLO ARENAS, ET AL
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`: SUPERIOR COURT
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`J.D. OF NEW HAVEN
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`: AT NEW HAVEN
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`: SEPTEMBER 13, 2023
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`MOTION TO COMPEL
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`The Plaintiff, Danielle Arrucci-Migliacci, moves the Court for an order compelling the
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`Defendants’, DC Rentals LLC and DC Painting LLC, fully comply with the Plaintiff’s
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`Interrogatories and Requests for Production. With trial scheduled to begin on January
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`23, 2024, the following discovery are outstanding to date:
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`INTERROGATORY NO. 7:
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`If, at the time of the incident alleged in the Complaint, you were covered by an insurance
`policy under which an insurer may be liable to satisfy part or all of a judgment or reimburse
`you for payments to satisfy part or all of a judgment, state the following:
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`(a) the name(s) and addresses of the insured(s);
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`(b) the amount of coverage under each insurance policy; [and]
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`(c) the name(s) and addresses of said insurer(s).
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`INTERROGATORY NO. 8:
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`If at the time of the incident[,] which is the subject of this lawsuit[,] you were protected against
`the type of risk[,] which is the subject of this lawsuit[,] by excess umbrella insurance, or any
`other insurance, state:
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`(a) the name(s) and addresses of the named insured;
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`(b) the amount of coverage effective at this time; [and]
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`(c) the name(s) and addresses of said insurer(s).
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`REQUEST FOR PRODUCTION NO. 2:
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` A
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` [unredacted] copy of declaration page(s) of each insurance policy identified in response
`to Interrogatory #7 and/or #8.
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`WHEREFORE, the Plaintiff requests this Court to respectfully enter an order
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`requiring the Defendants’, DC Rentals LLC and DC Painting LLC to adequately respond to
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`said requests within fourteen (14) days of the court order.
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`THE PLAINTIFF:
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` /s/432904
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`By: Jessica Ayala, Esq.
`Carter Mario Law Firm
`100 Plains Road
`Milford, CT 06461
`(203) 876-2711
`Juris No: 106160
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`CERTIFICATION
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`I hereby certify that a copy of the above was or will immediately be mailed or
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`delivered electronically or non-electronically on September 13, 2023 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 were or will
`immediately be electronically served:
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` /s/432904
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`Jessica Ayala, Esq.
`Commissioner of the Superior Court
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`Michael J. Smith, Esq.
`Kiernan Trebach, LLP
`40 Court Street, 3rd Floor
`Boston, MA 02108
`SENT VIA EMAIL AT: msmith@kiernantrebach.com
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