Quintino Ciafaglione v. Key Human Services, Inc. et al. (2013)

MEMORANDUM OF DECISION ON PLAINTIFF'S REQUEST FOR NON STANDARD INTERROGATORIES AND PRODUCTIONS

1. Request for names and depositions of residents denied because of privacy consideration and relevance to complaint;

2. Request for names and depositions of employees denied except for name of present manager or chief supervisor and depositions;  following deposition, further requests may be considered;

3. Record of complaints to defendant relative to plaintiff's allegations is limited to written complaints filed within eighteen months prior to filing of action.

Wagner, J.T.R.

Wagner, Jerry, J.T.R.