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
2s
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COMMONWEALTH OF MASSACHUSETTS
SUFFOLK, ss. ‘ SUPERIOR COURT
' CIVIL ACTION
' NO. 2084-CV-02375-BLS1
TRANSFORMATIVE HEALTHCARE, INC.
AND FALLON AMBULANCE SERVICE, LLC,
Plaintiffs,
v.
PATRICK SEAN TYLER AND RANDSECO, LLC,
ee
SHO] V1 2 BVH Ta»
Defendants.
PLAINTIFFS’ CROSS-MOTION FOR SUMMARY JUDGMENT.
Pursuant to Rule 56 of the Massachusetts Rules of Civil Procedure and Superior Court
Rule 9A, Plaintiffs Transformative Healthcare, Inc. and Fallon Ambulance Service, LLC move
this Court for entry of summary judgment (the “Cross-Motion”) on both counterclaims made by
\
Defendants Patrick Sean Tyler and Randseco, LLC in this action (“Defendants’ Counterclaims”)
(Paper No. 10). As grounds for this Motion, Plaintiffs state that there are no disputed issues of
material fact and they are entitled to a judgment in their favor on both of Defendants’
Counterclaims. Plaintiffs rely upon the following documents, which are submitted herewith, in
support of this Motion:
1. Plaintiff's Memorandum of Law in Support of Cross-Motion for Summary
Judgment;
2. Joint Statement of Material Facts Conceming Plaintiffs’ Cross-Motion for
Summary Judgment; and
3. Plaintiffs’ Additional Exhibits to Summary Judgment Joint Appendix.~
WHEREFORE, Plaintiffs Transformative Healthcare, Inc. and Fallon Ambulance
Service, LLC respectfully request that this Court:
A. Allow this Motion;
B. Enter summary judgment in Plaintiffs’ favor on both of Defendants’ Counterclaims;
C. Award Plaintiffs all of the costs, expenses and attorney’s fees they have incurred in
defending the claims asserted against them in this action; and
D. Award Plaintiffs such other and further relief that justice requires.
TRANSFORMATIVE HEALTHCARE, INC and
FALLON AMBULANCE SERVICE, LLC
By their attorneys,
/s/ Michael Boudett
Michael Boudett (BBO#558757)
James S. Fullmer (BBO#696682)
Foley Hoag LLP
Seaport West
155 Seaport Boulevard
Boston, MA 02210-2600
(617) 832-1000
mboudett@foleyhoag.com
jfullmer@foleyhoag.com
February 18, 2022CERTIFICATE OF SERVICE
I, Michael Boudett, hereby certify that on January 14, 2022, I conferred with opposing
counsel in good faith to narrow the issues raised in this motion.
/s/ Michael Boudett
Michael Boudett
CERTIFICATE OF SERVICE
I, James S. Fullmer, hereby certify that on February 18, 2022, I caused a copy of the
foregoing document to be served via email on:
Shepard Davidson
(sdavidson@burnslev.com) '
Laura Lee Mittelman
(Imittelman@burnslev.com)
Burns & Levinson LLP
125 High Street
Boston, MA 02110
isl James §. Fullmer
James S. Fullmer
Document Filed Date
March 29, 2022
Case Filing Date
October 16, 2020
Category
Business Litigation
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2s i COMMONWEALTH OF MASSACHUSETTS SUFFOLK, ss. ‘ SUPERIOR COURT ' CIVIL ACTION ' NO. 2084-CV-02375-BLS1 TRANSFORMATIVE HEALTHCARE, INC. AND FALLON AMBULANCE SERVICE, LLC, Plaintiffs, v. PATRICK SEAN TYLER AND RANDSECO, LLC, ee SHO] V1 2 BVH Ta» Defendants. PLAINTIFFS’ CROSS-MOTION FOR SUMMARY JUDGMENT. Pursuant to Rule 56 of the Massachusetts Rules of Civil Procedure and Superior Court Rule 9A, Plaintiffs Transformative Healthcare, Inc. and Fallon Ambulance Service, LLC move this Court for entry of summary judgment (the “Cross-Motion”) on both counterclaims made by \ Defendants Patrick Sean Tyler and Randseco, LLC in this action (“Defendants’ Counterclaims”) (Paper No. 10). As grounds for this Motion, Plaintiffs state that there are no disputed issues of material fact and they are entitled to a judgment in their favor on both of Defendants’ Counterclaims. Plaintiffs rely upon the following documents, which are submitted herewith, in support of this Motion: 1. Plaintiff's Memorandum of Law in Support of Cross-Motion for Summary Judgment; 2. Joint Statement of Material Facts Conceming Plaintiffs’ Cross-Motion for Summary Judgment; and 3. Plaintiffs’ Additional Exhibits to Summary Judgment Joint Appendix.~ WHEREFORE, Plaintiffs Transformative Healthcare, Inc. and Fallon Ambulance Service, LLC respectfully request that this Court: A. Allow this Motion; B. Enter summary judgment in Plaintiffs’ favor on both of Defendants’ Counterclaims; C. Award Plaintiffs all of the costs, expenses and attorney’s fees they have incurred in defending the claims asserted against them in this action; and D. Award Plaintiffs such other and further relief that justice requires. TRANSFORMATIVE HEALTHCARE, INC and FALLON AMBULANCE SERVICE, LLC By their attorneys, /s/ Michael Boudett Michael Boudett (BBO#558757) James S. Fullmer (BBO#696682) Foley Hoag LLP Seaport West 155 Seaport Boulevard Boston, MA 02210-2600 (617) 832-1000 mboudett@foleyhoag.com jfullmer@foleyhoag.com February 18, 2022CERTIFICATE OF SERVICE I, Michael Boudett, hereby certify that on January 14, 2022, I conferred with opposing counsel in good faith to narrow the issues raised in this motion. /s/ Michael Boudett Michael Boudett CERTIFICATE OF SERVICE I, James S. Fullmer, hereby certify that on February 18, 2022, I caused a copy of the foregoing document to be served via email on: Shepard Davidson (sdavidson@burnslev.com) ' Laura Lee Mittelman (Imittelman@burnslev.com) Burns & Levinson LLP 125 High Street Boston, MA 02110 isl James §. Fullmer James S. Fullmer