In a letter from the plaintiff’s lawyer Daniel E. Casagrande of the law firm Cramer & Anderson LLP, to the Hon. Marshal Berger, dated August 25, 2016, he states that an agreement was made by counsel of all parties to stagger the trials of the above mentioned administrative appeals.
Report by Paula Antolini
August 25, 2016 5:25PM EDT
Photo above: Bethel Advocate file photo of one of the 2015 meetings of the Planning & Zoning Commission during the crematorium hearings.
Breaking News: Bethel Crematorium Battle Still Ongoing, Heading to Appeals Trials
The latest update in the crematorium issue in Clarke Business Park in Bethel CT just came out today in the case of MCLOUGHLIN, B. SHAWN v. PLANNING & ZONING COMMISSION OF THE TOWN OF BETHEL Et Al, docket numbers HHD-CV15-6063334-S, HHD-CV15-6063335-S, HHD-CV15-6063336-S.
In a letter from the plaintiff’s lawyer Daniel E. Casagrande of the law firm Cramer & Anderson LLP, to the Hon. Marshal Berger, dated August 25, 2016, he states that an agreement was made by counsel of all parties to stagger the trials of the above mentioned administrative appeals.
Casagrande states, “The parties have agreed, as suggested by the Court, to try the appeals from the decisions of the special permit and crematorium applications (Dkt. No. HHD-CV15-6063334-S) (the “Special Permit Appeal”) first. After the Court issues its decision on this zoning amendment (Dkt. Nos. HHD-CV15-6063335-S and HHD-CV15-6063336-S) (the “Text Amendment Appeals”) or to withdraw such appeals. In the alternative, should Plaintiffs seek appellate review of this Court’s decision on the Special Permit Appeal, the trial of the Text Amendment Appeals shall be stayed pending the outcome of the appellate process. Plaintiffs may elect to withdraw the Tecxt Amendment Appeals, or the parties may agree to a judgement in such appeals in Plaintiff’s favor.”
Casagrande continues, “Notwithstanding the above the parties have agreed that they shall have the rights to use the entire record from all the hearings and meetings in briefing the Special Permit Appeal. We note in this regard that all of the records were incorporated by the Commission in each subsequent record. In the event the Court grants any motion(s) by Plantiffs to conduct one or more depositions before trial of the Special Permit Appeals. Plaintiffs shall be allowed to ask questions in such depositions that relate to the entire record.”
For those who don’t know, depositions are written statements of witnesses that are taken during the questioning of a witness. They can reveal previously unknown information that can be valuable to the whole process. The professionals at Remote Legal can make the depositions easier to carry out but it’s a long but important part of any case like this.
Casagrande states, “The parties also have agreed to the entry of the following scheduling order regarding the Special Permit Appeals:
• September 1, 2016 – Designations of Contents of the Record (in all appeals);
• November 1, 2016 – Filing of Transcripts (in all appeals);
• January 15, 2017 – Motions for depositions of Planning & Zoning Commission Chair and One Additional Member (objections to be files within two weeks thereafter);
• April 15, 2017 – Additional motions for depositions and/or to supplement record (objections to be files within two weeks thereafter);
• July 15, 2017 – Plaintiffs’ Brief;
• September 1, 2017 – Defendant’s/Intervenor Briefs;
• October 1, 2017 – Plaintiffs’ Reply Brief.”
He further states, “Should Your Honor have any questions n the above agreement and proposed order, I would be pleased to set up a conference call with all counsel and Your Honor.”
Copies of this letter were sent to B. Shawn McLoughlin (Plaintiff), Peter Olsen, Esq. (attorney for Plaintiff), Charles Andres, Esq. (attorney for P&Z), and Neil Marcus, Esq. (attorney for Connecticut Coining / Gregory Marciano, company next door to the proposed crematorium property).
We will update this story as more information is released.
CLICK ON LETTER to read in full, page one and two, below:
*****
Recap: This crematorium battle has been ongoing for several years.
CLICK HERE to read some of the articles.
CLICK HERE to sign petition and read updates. (Petition also has signatures on paper, bringing the total signature count to over 400, that was submitted to the Planning & Zoning Commission, signed mostly by Bethel citizens opposing the crematorium, and signatures from other surrounding CT town’s people.)
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