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`AVA SCAGNELLI PPA
`BETHANY SCAGNELLI et al.
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`VS.
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`KIDS TOWN, LLC, et al.
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`SUPERIOR COURT
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`JUDICIAL DISTRICT
`OF WATERBURY
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`AT WATERBURY
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`JUNE 28, 2019
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`DEFENDANT CITY OF WATERBURY’S OBJECTION TO PLAINTIFFS’ MOTION TO
`SERVE ADDITIONAL DISCOVERY
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`The Defendant, the City of Waterbury (the City”), respectfully submits this
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`Objection to the Plaintiffs’ motion for permission to serve additional discovery requests.
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`See Doc. 134.00. The Plaintiffs seek copies of any contracts between the City and any
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`of its co-Defendants, as well as any addenda to said contracts. Such documents have
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`no bearing on any claim asserted by the Plaintiff in this personal injury case, especially
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`because the requests are not limited to the contract that forms the basis for the City’s
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`claims of contractual indemnification and breach of contract against co-Defendant Kids
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`Town, LLC.
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`The Plaintiffs make the summary assertion that “[a]ny such contracts would
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`certainly be material and relevant as to the plaintiff’s negligence and recklessness
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`claims against the defendant, City of Waterbury.” See id. The City submits, to the
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`contrary, that any such contracts are relevant, if at all, only to the City’s cross-claims
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`against co-Defendant Kids Town, LLC, and not to any claim asserted by the Plaintiffs.
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`In the absence of any explanation for why such documents would be reasonably
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`calculated to lead to the discovery of evidence relevant to any of the Plaintiffs’ claims,
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`the City submits that the Plaintiffs’ requests to serve additional discovery should be
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`denied.
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`1
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`WHEREFORE, the City respectfully requests that the Plaintiffs’ motion be
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`denied.
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`Respectfully submitted,
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`THE DEFENDANT
`CITY OF WATERBURY
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`By: /s/420707____________________
`Daniel J. Foster
`Office of the Corporation Counsel
`235 Grand Street, 3rd Floor
`Waterbury, CT 06702
`P: (203) 574-6731
`F: (203) 574-8340
`Juris No. 066300
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`A copy of the foregoing has been mailed, postage prepaid on the day and year
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`CERTIFICATION
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`first above-written, to all counsel or record:
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`Matthew A. Lucarelli, Esq.
`Mancini & Lucarelli
`777 Echo Lake Road, Suite G
`Watertown, CT 06795
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`Rene G. Martineau, Esq.
`Law Office of John P. Calabrese
`500 Enterprise Drive 2C
`Rocky Hill, CT 06067
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`/s/420707____________________
`Daniel J. Foster
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`F:\New Electronic Filing System\FILE MANAGEMENT\Litigation\Personal Injury\Scagnelli, Ava, ppa Scagnelli,
`Bethany v. Kids Town, et al L18-021\PLEADINGS\COW's obj to additional discovery.docx
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`2
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