On October 16, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Fallon Ambulance Service Llc,
Transformative Healthcare Inc,
and
Randseco Llc,
Tyler, Patrick Sean,
for Business Litigation
in the District Court of Suffolk County.
Preview
~
20
COMMONWEALTH OF MASSACHUSETTS
SUFFOLK, SS. | SUPERIOR COURT DEPARTMENT
' BUSINESS LITIGATION SESSION
, CIVIL ACTION NO. 2084-CV-02375-
BLS1
‘TRANSFORMATIVE HEALTHCARE, INC.
and FALLON AMBULANCE SERVICES, LLC,
Plaintiffs,
v.
PARICK SEAN TYLER and RANDSECO, LLC,
Defendants,
DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT:
Pursuant to Rule 56 of the Massachusetts Rules of Civil Procedure, Defendants Patrick!
Sean Tyler and Randseco, LLC move this Court for entry of summary judgment on all claims in
Plaintiffs’ Amended Complaint.' As grounds for this Motion, Defendants state that there are no
disputed issues of material fact and they are entitled to a judgment in their favor on all of
Plaintiffs’ claims. Defendants rely upon the following documents, which are submitted
herewith, in support of this Motion:
1. Defendants’ Memorandum of Law in Support of their Motion for Summary
Judgment;
2. Joint Statement of Facts in Connection with Defendants’ Motion for Summary
Judgment; and
3. Summary Judgment Joint Appendix.
H
a 1
1 While the Court has not ruled on Plaintiffs’ ungpposed Motion for Leave to File an Amended Complaint,
Defendants’ Motion for Summary Judgment treats the Proposed Amended Complaint as the operative “Complaint”
in this action. i|
|
WHEREFORE, Defendants Patrick Sten Tyler and Randseco, LLC respectfully request
1
that this Court: |
A. — Allow this Motion;
B. — Enter summary judgment in Defendants’ favor on all Counts in the Amended
Complaint;
C. Award Defendants all of the costs, expenses and attorneys’ fees they have incurred
in defending the claims asserted against them in this action; and
D. Award Defendants such other and further relief that justice so requires,
Respectfully submitted,
PATRICK SEAN TYLER and
RANDSECO, LLC
By their attorneys,
/s/ Shepard Davidson
Shepard Davidson (BBO #557082)
sdavidson@burnslev.com
Laura Lee Mittelman (BBO #689752)
Imittelman@burnslev.com
Burns & Levinson LLP
125 High Street
Boston, MA 02110
617-345-3000
Dated: January 19, 2022
SUPERIOR COURT RULE 9C CERTIFICATE
I, Shepard Davidson, hereby certify that on January 14, 2022, I conferred with opposing
counsel in good faith to narrow the issues raised in this motion.
4s Shepard DavidsonCERTIFICATE OF SERVICE
I
I, Laura Lee Mittelman, hereby certify that on January 19, 2022 I served a true and
accurate copy of the foregoing document on the following counsel of record via email and U.S.
Mail. |
1
Michael Boudett, Esq.
James Fullmer, Esq.
Foley Hoag LLP
Seaport West
155 Seaport Boulevard
Boston, MA 02210-2600
mboudett@foleyhoag.com
jfullmer@foleyhoag.com
1
/s/ Laura Lee Mittelman
Document Filed Date
March 29, 2022
Case Filing Date
October 16, 2020
Category
Business Litigation
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
~ 20 COMMONWEALTH OF MASSACHUSETTS SUFFOLK, SS. | SUPERIOR COURT DEPARTMENT ' BUSINESS LITIGATION SESSION , CIVIL ACTION NO. 2084-CV-02375- BLS1 ‘TRANSFORMATIVE HEALTHCARE, INC. and FALLON AMBULANCE SERVICES, LLC, Plaintiffs, v. PARICK SEAN TYLER and RANDSECO, LLC, Defendants, DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT: Pursuant to Rule 56 of the Massachusetts Rules of Civil Procedure, Defendants Patrick! Sean Tyler and Randseco, LLC move this Court for entry of summary judgment on all claims in Plaintiffs’ Amended Complaint.' As grounds for this Motion, Defendants state that there are no disputed issues of material fact and they are entitled to a judgment in their favor on all of Plaintiffs’ claims. Defendants rely upon the following documents, which are submitted herewith, in support of this Motion: 1. Defendants’ Memorandum of Law in Support of their Motion for Summary Judgment; 2. Joint Statement of Facts in Connection with Defendants’ Motion for Summary Judgment; and 3. Summary Judgment Joint Appendix. H a 1 1 While the Court has not ruled on Plaintiffs’ ungpposed Motion for Leave to File an Amended Complaint, Defendants’ Motion for Summary Judgment treats the Proposed Amended Complaint as the operative “Complaint” in this action. i| | WHEREFORE, Defendants Patrick Sten Tyler and Randseco, LLC respectfully request 1 that this Court: | A. — Allow this Motion; B. — Enter summary judgment in Defendants’ favor on all Counts in the Amended Complaint; C. Award Defendants all of the costs, expenses and attorneys’ fees they have incurred in defending the claims asserted against them in this action; and D. Award Defendants such other and further relief that justice so requires, Respectfully submitted, PATRICK SEAN TYLER and RANDSECO, LLC By their attorneys, /s/ Shepard Davidson Shepard Davidson (BBO #557082) sdavidson@burnslev.com Laura Lee Mittelman (BBO #689752) Imittelman@burnslev.com Burns & Levinson LLP 125 High Street Boston, MA 02110 617-345-3000 Dated: January 19, 2022 SUPERIOR COURT RULE 9C CERTIFICATE I, Shepard Davidson, hereby certify that on January 14, 2022, I conferred with opposing counsel in good faith to narrow the issues raised in this motion. 4s Shepard DavidsonCERTIFICATE OF SERVICE I I, Laura Lee Mittelman, hereby certify that on January 19, 2022 I served a true and accurate copy of the foregoing document on the following counsel of record via email and U.S. Mail. | 1 Michael Boudett, Esq. James Fullmer, Esq. Foley Hoag LLP Seaport West 155 Seaport Boulevard Boston, MA 02210-2600 mboudett@foleyhoag.com jfullmer@foleyhoag.com 1 /s/ Laura Lee Mittelman