Filed: September 30, 2026
| Entered: September 30, 2026
Pizziconi v. Gray et al
370 Other Fraud | Connecticut
Currently before the Court are a number of motions and cross-motions for Summary Judgment by Plaintiff Andrea Pizziconi ("Pizziconi"), ECF Nos. 283 , 295 , 310 , 312 , 333 , 336 , and 420 , and a motion for summary judgment by Defendant Dmitry Kravtsov ("Kravtsov"), ECF No. 288 . The standard under which courts review motions for summary judgment is well established. "The court shall grant summary judgment if the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." Fed. R. Civ. P. 56(a). A fact is "material" if it "might affect the outcome of the suit under the governing law," while a dispute about a material fact is "genuine" if "the evidence is such that a reasonable jury could return a verdict for the nonmoving party." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). "Before summary judgment may be entered, the district court must ensure that each statement of material fact is supported by record evidence sufficient to satisfy the movant's burden of production even if the statement is unopposed." Jackson v. Fed. Express, 766 F.3d 189, 194 (2d Cir. 2014).
These motions compromise hundreds if not thousands of pages of voluminous exhibits. Unfortunately, Kravtsov and Pizziconi have each failed to comply with the Court's Local Rules, rendering it virtually impossible for the Court to discern the nature of any "undisputed material facts," and consequently whether the movant has met his or her initial burden. To help ensure that material facts are supported by record evidence, Local Rule 56(a) requires that a party seeking summary judgment file a Statement of Undisputed Material Facts setting forth "each material fact as to which the moving party contends there is no genuine issue to be tried... followed by a specific citation to (1) the affidavit of a witness competent to testify as to the facts at trial, or (2) other evidence that would be admissible at trial." D. Conn. L. Cr. R. 56(a)(1), (3). Failure to provide specific citations to evidence can result in, among other things, "the Court imposing sanctions, including, when the movant fails to comply, an order denying the motion for summary judgment." Id. at 56(a)(3). A party's "pro se status does not exempt a party from compliance with relevant rules of procedural and substantive law." Triestman v. Federal Bureau of Prisons, 470 F.3d 471, 477 (2d Cir. 2006) (internal quotation marks and citation omitted).
First, Kravtsov, in his entire Statement of Undisputed Material Facts, ECF No. 288, at 4-8 (referred to by ECF page number for clarity), provides only one citation to any record evidence. That single citation is to a portion of the transcript in Norman Gray's criminal trial. Id. para. 15. Although Kravtsov attaches his own Affidavit, he does not cite to the Affidavit and a quick comparison between the Affidavit and his 56(a) Statement reveals that they are not in complete alignment. This Statement of Undisputed Material Facts is therefore insufficient, and the Court will not engage in a burdensome hunt to scour the record for evidence that either confirms or denies those facts which Kravtsov failed to properly support. Moreover, in her response to Kravtsov's Rule 56(a) Statement, Pizziconi denies almost every asserted fact and in so doing cites to record evidence supporting the denial. See ECF No. [310-3]. While the record citations in Pizziconi's response are at times imperfect, a review of the voluminous submission reveals, at the very least, significant and unanswered questions of fact as to whether Kravtsov played any role, as alleged by Pizziconi, in the fraud that was perpetrated by Defendant Norman Gray. Kravtsov's Motion for Sum... (truncated)