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DOCKET NO.: NNH-CV-22-6120225-S
`
`DANIELLE ARRUCCI-MIGLIACCI
`
`
`
`VS.
`
`
`
`GINWAY LIN, ET AL.
`
`
`
`
`
`
`MOTION TO COMPEL
`Pursuant to Practice Book § 13-14, the Defendants, Pablo Arenas, DC Painting, LLC, and
`
` DECEMBER 12, 2023
`
`DC Rentals, LLC, hereby move for an Order compelling Defendant Jason Migliacci to appear for
`
`a deposition by a date certain. Defendant Migliacci’s deposition was noticed on April 19, 2023,
`
`May 18, 2023, and August 22, 2023. On each occasion, the deposition was cancelled. Efforts to
`
`reschedule Defendant Migliacci’s deposition have been difficult to coordinate among the four
`
`attorneys involved in the case.
`
`The parties are currently scheduled for mediation on Monday January 8, 2024. Should the
`
`matter fail to resolve at mediation, there is a Trial Management Conference scheduled for January
`
`9, 2024, with jury selection commencing on January 23, 2024. Taking and completing the
`
`deposition of Defendant Jason Migliacci is critical to the defense of this matter.
`
`WHEREFORE, the Defendants respectfully request that the Court compel the Defendant,
`
`Jason Migliacci, to appear for his deposition on Wednesday January 3, 2024, in accordance with
`
`the attached Notice of Deposition or by a date certain prior to the Trial Management Conference.
`
`Respectfully Submitted,
`The Defendants,
`
`/s/414544
`
`________________________
`Robert J. Dunne
`RDunne@kiernantrebach.com
`Kiernan Trebach LLP
`40 Court Street, 3rd Floor
`Boston, MA 02108
`T - (617) 426-3900
`
`: SUPERIOR COURT
`
` :
`
` J.D. OF NEW HAVEN
`
`AT NEW HAVEN
`
`:
`
` :
`
`

`

`CERTIFICATE OF SERVICE
`
`I certify that a copy of the above was or will immediately be mailed or delivered
`
`electronically or nonelectronically on December 12, 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.
`
`Via Email Transmittal Only to: jayala@cartermario.com; lpellegrini@cartermario.com
`Jessica Ayala, Esq.
`Carter Mario Law Firm
`100 Plains Road
`Milford, CT 06461
`Attorney(s) for the Plaintiff(s)
`
`Via Email Transmittal Only to: JYAHWAK@travelers.com
`Joshua A. Yahwak, Esq.
`Law Offices of Cynthia M. Garraty
`P.O. Box 2903
`Hartford, CT 06104
`Attorney(s) for the Defendant(s) Ginway Lin and 9 East Corporation d/b/a 9 East Hibachi &
`Asian Kitchen
`
`Via Email Transmittal Only to: ConnecticutHC@Progressive.com;
`JOSEPH_L_VELEZ@progressive.com
`Joseph L. Velez, Esq.
`Hanks Olsen & Sheehan
`538 Preston Ave., Suite 305
`Meriden, CT 06450
`Attorney(s) for the Defendant(s) Jason Migliacci
`
`
`
`
`
`
`
`
`
`/s/414544
`
`
`
`
`Robert J. Dunne
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`
`
`
`:
`
`:
`
`:
`
`
`
`
`
`
`
` SUPERIOR COURT
`
`J.D. OF NEW HAVEN
`
`AT NEW HAVEN
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`DOCKET NO.: NNH-CV-22-6120225-S
`
`DANIELLE ARRUCCI-MIGLIACCI
`
`VS.
`
`GINWAY LIN, ET AL
`
`
`
`FOURTH RE-NOTICE OF REMOTE DEPOSITION OF
`JASON MIGLIACCI
`
`
`
`
`
`
`
`:
`
`DECEMBER 12, 2023
`
`
`
`TO: All Counsel of Record
`
`
`
`PLEASE TAKE NOTICE that pursuant to Connecticut Practice Book Section 13-26 et
`
`seq., counsel for the undersigned Defendants, will take the deposition of the Defendant, Jason
`
`Migliacci, concerning the subject matter of the above captioned action. The deposition shall take
`
`place on Wednesday, January 3, 2024, at 2:00 p.m., virtually, and shall continue thereafter
`
`from day to day or as otherwise mutually agreed until completed.
`
`The deposition will be taken before a notary public or other person duly authorized to
`
`administer oaths and shall be recorded by stenographic means. You are invited to attend the
`
`deposition and participate as provided in the Connecticut Practice Book.
`
`
`
`
`
`

`

`Respectfully Submitted,
`The Defendants,
`PABLO ARENAS,
`DC PAINTING, LLC, and
`DE RENTALS, LLC,
`By their Attorney(s)
`
`
`/s/ 414544
`________________________
`Robert J. Dunne
`RDunne@kiernantrebach.com
`Kiernan Trebach LLP
`40 Court Street, 3rd Floor
`Boston, MA 02108
`T - (617) 426-3900
`F - (617) 426-0380
`
`
`
`2
`
`
`
`
`
`

`

`CERTIFICATE OF SERVICE
`
`I certify that a copy of this document was or will immediately be mailed or delivered
`
`electronically or non-electronically on December 12, 2023, to all attorneys and self-represented
`parties of record and that written consent for electronic delivery was received from all attorneys
`and self- represented parties of record who were or will immediately be receiving electronic
`delivery.
`
`Via Email Transmittal Only to: jayala@cartermario.com; lpellegrini@cartermario.com
`Jessica Ayala, Esq.
`Carter Mario Law Firm
`100 Plains Road
`Milford, CT 06461
`Attorney(s) for the Plaintiff(s)
`
`Via Email Transmittal Only to: JYAHWAK@travelers.com
`Joshua A. Yahwak, Esq.
`Law Offices of Cynthia M. Garraty
`P.O. Box 2903
`Hartford, CT 06104
`One Hamden Center
`2319 Whitney Avenue, Suite 4C
`Hamden, CT 06518-06473
`Attorney(s) for the Defendant(s) Ginway Lin and 9 East Corporation d/b/a 9 East Hibachi & Asian
`Kitchen
`
`Via Email Transmittal Only to: ConnecticutHC@Progressive.com;
`JOSEPH_L_VELEZ@progressive.com
`Joseph L. Velez, Esq.
`Hanks Olsen & Sheehan
`538 Preston Ave., Suite 305
`Meriden, CT 06450
`Attorney(s) for the Defendant(s) Jason Migliacci
`
`Via Email Transmittal Only to: scheduling@magnaLS.com
`Magna Legal Services
`
`
`/s/ 414544
`
`
`
`Robert J. Dunne
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

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