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COMMONWEALTH OF MASSACHUSETTS
SUFFOLK, SS. SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
e-filed 9/15/2021
Transformative Healthcare, Inc. and Fallon RB
Ambulance Service, LLC,
Civil Action No.: 2084-cv-02375-
BLS1
Plaintiffs,
vs.
Patrick Sean Tyler and Randseco, LLC,
Defendants.
weer SS
JOINT STIPULATION TO ENLARGE TIME
Pursuant to Mass. R. Civ. P. 6(b), the parties to the above-captioned action jointly
stipulate to, and respectfully request that the Court approve, an extension of the deadlines
provided by the Court’s February 26, 2021 scheduling Order.
In support of this joint stipulation, the parties state the following:
1. On February 26, 2021, the Court entered an Order adopting a proposed tracking
order jointly submitted by the parties.
2. The parties have been diligently working to prepare the case for summary
judgment and/or trial and have undertaken substantial discovery efforts. These efforts have
included document discovery that has taken longer than anticipated. The parties have raised, and
narrowed or resolved, several discovery disputes. One deposition has been taken, but the others
may be taken more efficiently if conducted after written discovery has been completed. For
these reasons, among others, the parties require additional time to complete fact witness
depositions, which in turn impacts the rest of the case schedule. Accordingly, the parties jointlystipulate and respectfully request that the Court extend each of the future deadlines in the current
tracing order as follows:
Event
Schedule Entered Per
February 26, 2021 Order
Jointly Proposed Revised
Schedule
Fact Discovery Completed
September 30, 2021
November 12, 2021
Expert Witness Reports
Served
October 30, 2021
December 13, 2021
Rebuttal Expert Witness
Reports Served
December 31, 2021
February 14, 2022
Expert Witness Deposition
Notices Served
January 30, 2022
March 15, 2022
Expert Witness Depositions
Taken
February 15, 2022
March 31, 2022
Dispositive Motions Served
March 30, 2022
May 12, 2022
Final Pre-trial Conference
March 15, 2022 (or 30 days
after decision on motion(s)
for summary judgment, if
any)
April 27, 2022 (or 30 days
after decision on motion(s)
for summary judgment, if
any)
3. The parties stipulate that the foregoing proposed deadlines are subject to
modification upon a showing of good cause.
[signature page follows]Dated: September 15, 2021
/s/ Michael Boudett
Michael Boudett (BBO#558757)
James S. Fullmer (BBO#696682)
Foley Hoag LLP
Seaport West
155 Seaport Boulevard
Boston, MA 02210
(617) 832-1000
mboudett@foleyhoag.com
jfullmer@foleyhoag.com
Attorneys for Transformative Healthcare, Inc. and
Fallon Ambulance Service, LLC
/s/ Shepard Davidson
Shepard Davidson (BBO#557082)
Laura Lee Mittelman (BBO#689752)
Burns & Levinson LLP
125 High Street
Boston, MA 02110
(617) 345-3000
sdavidson@burnslev.com
Imittelman@burnslev.com
Attorneys for Patrick Sean Tyler and Randseco,
LLCCERTIFICATE OF SERVICE
I hereby certify that on September 15, 2021, I caused the foregoing Joint Stipulation to
Enlarge Time to be served on all counsel via e-mail.
/s/ James S. Fullmer
James S. Fullmer
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COMMONWEALTH OF MASSACHUSETTS SUFFOLK, SS. SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT e-filed 9/15/2021 Transformative Healthcare, Inc. and Fallon RB Ambulance Service, LLC, Civil Action No.: 2084-cv-02375- BLS1 Plaintiffs, vs. Patrick Sean Tyler and Randseco, LLC, Defendants. weer SS JOINT STIPULATION TO ENLARGE TIME Pursuant to Mass. R. Civ. P. 6(b), the parties to the above-captioned action jointly stipulate to, and respectfully request that the Court approve, an extension of the deadlines provided by the Court’s February 26, 2021 scheduling Order. In support of this joint stipulation, the parties state the following: 1. On February 26, 2021, the Court entered an Order adopting a proposed tracking order jointly submitted by the parties. 2. The parties have been diligently working to prepare the case for summary judgment and/or trial and have undertaken substantial discovery efforts. These efforts have included document discovery that has taken longer than anticipated. The parties have raised, and narrowed or resolved, several discovery disputes. One deposition has been taken, but the others may be taken more efficiently if conducted after written discovery has been completed. For these reasons, among others, the parties require additional time to complete fact witness depositions, which in turn impacts the rest of the case schedule. Accordingly, the parties jointlystipulate and respectfully request that the Court extend each of the future deadlines in the current tracing order as follows: Event Schedule Entered Per February 26, 2021 Order Jointly Proposed Revised Schedule Fact Discovery Completed September 30, 2021 November 12, 2021 Expert Witness Reports Served October 30, 2021 December 13, 2021 Rebuttal Expert Witness Reports Served December 31, 2021 February 14, 2022 Expert Witness Deposition Notices Served January 30, 2022 March 15, 2022 Expert Witness Depositions Taken February 15, 2022 March 31, 2022 Dispositive Motions Served March 30, 2022 May 12, 2022 Final Pre-trial Conference March 15, 2022 (or 30 days after decision on motion(s) for summary judgment, if any) April 27, 2022 (or 30 days after decision on motion(s) for summary judgment, if any) 3. The parties stipulate that the foregoing proposed deadlines are subject to modification upon a showing of good cause. [signature page follows]Dated: September 15, 2021 /s/ Michael Boudett Michael Boudett (BBO#558757) James S. Fullmer (BBO#696682) Foley Hoag LLP Seaport West 155 Seaport Boulevard Boston, MA 02210 (617) 832-1000 mboudett@foleyhoag.com jfullmer@foleyhoag.com Attorneys for Transformative Healthcare, Inc. and Fallon Ambulance Service, LLC /s/ Shepard Davidson Shepard Davidson (BBO#557082) Laura Lee Mittelman (BBO#689752) Burns & Levinson LLP 125 High Street Boston, MA 02110 (617) 345-3000 sdavidson@burnslev.com Imittelman@burnslev.com Attorneys for Patrick Sean Tyler and Randseco, LLCCERTIFICATE OF SERVICE I hereby certify that on September 15, 2021, I caused the foregoing Joint Stipulation to Enlarge Time to be served on all counsel via e-mail. /s/ James S. Fullmer James S. Fullmer