OF THE AGENCY
GW: OH IT'S MCCULLOUGH INSURANCE IT'S IN KILLINGTON
AD: OKAY, AND WHERE YOU DID YOU HAVE AUTO INSURANCE ON THE VEHICLE THE FORD EXPLORER PRIOR TO OBTAINING PROGRESSIVE
GW: YES
AD: WHO WHERE YOU INSURED WITH
GW: SAFECO
AD: AND WHO WAS YOUR AGENT ON THAT POLICY DO YOU KNOW
GW: NO I DON'T
AD: WAS THAT A CONNECTICUT POLICY OR VERMONT POLICY
GW: IT WAS CONNECTICUT WHEN I SWITCHED TO VERMONT I SWITCHED TO PROGRESSIVE BECAUSE MY BROTHER HAS *1187 THIS AGENT SO I USED MY BROTHERS
AD: HOW LONG WERE YOU INSURED WITH SAFECO DO YOU REMEMBER
GW: A COUPLE OF YEARS, WHY DOES THAT MATTER
AD: AND
GW: WHY, WHY DOES THAT MATTER
AD: JUST TRYING TO VERIFY WHO YOUR PRIOR INSURANCE WAS SAME REASON WHY ASKED YOU WHERE YOU LIVED PRIOR TO KILLINGTON THE MOUNTAIN GREEN APARTMENT EXCUSE ME YOU INTERRUPTED ME SO I LOST MY TRAIN OF THOUGHT
GW: YES
AD: DO YOU KNOW WHEN YOUR REGISTRATION EXPIRES ON THE EXPLORER
GW: IT'S NOT AN EXPLORER
AD: THE FORD RANGER
GW: YES IT EXPIRES SOMETIME IN JULY
AD: ARE YOU GOING TO BE REGISTERING THAT VEHICLE IN VERMONT
GW: YES
AD: AND HOW LONG HAVE YOU HAD A VERMONT DRIVER'S LICENSE
GW: SINCE THE SAME TIME I GOT INSURANCE SINCE JUST BEFORE I WAS GOING TO MOVE TO VERMONT
AD: WHEN DID YOU KNOW YOU WERE GOING TO MOVE TO I KNOW THAT YOU MOVED IN SEPTEMBER 2000
GW: IN LATE AUGUST I KNEW I WAS GOING TO MOVE
AD: AND WHAT DID YOU DO WENT UP THERE AND APPLIED FOR A LICENSE OR WENT THROUGH THE NORMAL COURSE OF EVENTS THAT YOU HAVE TO
GW: YES
AD: WHEN DOES YOUR DRIVER'S LICENSE EXPIRE DO YOU KNOW
GW: I HAVE TO GET IT I JUST HAD IT I DON'T KNOW WHERE I PUT IT OH IT EXPIRES IN 2003
AD: WHAT MONTH
GW: 11/1/2003
AD: OKAY, AND JUST YOU AND YOUR BROTHER ARE IN THE APARTMENT CORRECT
GW: CORRECT
AD: ALL RIGHT, ARE YOU ALSO IN SCHOOL IN VERMONT OR IN CONNECTICUT
GW: NO
AD: OKAY, I THINK I HAVE EVERYTHING THAT I NEED THANKS VERY MUCH FOR YOUR HELP AND AS I SAID IF YOU HEAR ANYTHING FROM THE NAUGATUCK POLICE DEPARTMENT LET ME KNOW AND IN THE MEAN TIME IF I HAVE YOUR PERMISSION I WILL TURN OFF THE RECORDER
GW: OKAY
AD: THE TIME IS APPROXIMATELY 2:20
GW: YES
STATE OF VERMONT COUNTY OF RUTLAND PROGRESSIVE INSURANCE COMPANY, Plaintiff
v.
*1188 GREGORY WASOKA, and ROBERT CERDEIRA, Defendants.
RUTLAND SUPERIOR COURT
DOCKET NO. 48-1-02 Rdcv
PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT Plaintiff Progressive Insurance Company (Hereinafter, "Progressive") moves for summary judgment pursuant to V.R.C.P. 56, on the grounds that there are no disputed material facts, and judgment is appropriate as a matter of law. In support of its motion, Plaintiff files the following Memorandum and the attached Statement of Undisputed Facts.
MEMORANDUM Summary Judgment is appropriate when there are no genuine