On October 29, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Karle, Robert,
Woods, Kelly,
and
Amedisys Holding Llc,
for Contract / Business Cases
in the District Court of Norfolk County.
Preview
Date Filed 8/23/2022 4:43 PM
Superior Court - Norfolk
Docket Number 2182CV00989 7
Docketed on 08/24/2022
COMMONWEALTH OF MASSACHUSETTS
NORFOLK, ss. SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
KELLY WOODS & ROBERT KARLE,
Plaintiffs,
C.A. No. 2182CV00989
v.
AMEDISYS HOLDING, LLC,
Defendant.
JOINT MOTION TO AMEND TRACKING ORDER DEADLINES
Plaintiffs Kelly Woods and Robert Karle, along with Defendant Amedisys Holding,
LLC, respectfully move the Court to amend the tracking order deadlines as set forth herein.
In support thereof, the parties state:
1. Per the Court’s Tracking Order in this case, the discovery deadline is August
25, 2022 and the deadline for (1) serving a dispositive motion is September 26, 2022, and (2)
filing the same is October 24, 2022.
2. The Plaintiff has served requests for production and interrogatories on
Defendant and Defendant is currently preparing its responses thereto.
3. Plaintiff intends to take a Rule 30(b)(6) deposition of Defendants, and
Defendants intend to take Plaintiffs’ depositions.
4. Due to the press of other business and prescheduled commitments in other
matters, the parties need some additional time to complete the discovery they intend to take,
as reflected above.
5. The parties, therefore, request that the Court extend the tracking order
deadlines as follows:
Date Filed 8/23/2022 4:43 PM
Superior Court - Norfolk
Docket Number 2182CV00989
a. Discovery Deadline: November 30, 2022;
b. Rule 56 Motions Served: January 31, 2023;
c. Rule 56 Motions Filed: March 3, 2023.
WHEREFORE, Plaintiffs and Defendant respectfully move the Court to amend the
Scheduled Order accordingly.
Respectfully submitted,
KELLY WOODS & ROBERT KARLE, AMEDISYS HOLDING, INC.
/s/ Stacy Thomsen /s/ Joshua D. Nadreau
Stacy Thomsen, BBO No. 706746 Joshua D. Nadreau, BBO No. 688970
Law Office of Nicholas F. Ortiz, P.C. FISHER & PHILLIPS LLP
50 Congress Street, Suite 540 200 State Street, 7th Floor
Boston, MA 02109 Boston, Massachusetts 02109
swt@mass-legal.com Tel: (617) 722-0044
Fax: (617) 532-5899
jnadreau@fisherphillips.com
Dated: August 23, 2022
CERTIFICATE OF SERVICE
I, Joshua D. Nadreau, counsel for Defendant, certify that a true copy of the foregoing
was served via email, upon the following:
Stacy Thomsen, Esq.
Law Office of Nicholas F. Ortiz, P.C.
50 Congress Street, Suite 540
Boston, MA 02109
swt@mass-legal.com
/s/ Joshua D. Nadreau
Joshua D. Nadreau
Dated: August 23, 2022
-2-
Document Filed Date
August 24, 2022
Case Filing Date
October 29, 2021
Category
Contract / Business Cases
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Date Filed 8/23/2022 4:43 PM Superior Court - Norfolk Docket Number 2182CV00989 7 Docketed on 08/24/2022 COMMONWEALTH OF MASSACHUSETTS NORFOLK, ss. SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT KELLY WOODS & ROBERT KARLE, Plaintiffs, C.A. No. 2182CV00989 v. AMEDISYS HOLDING, LLC, Defendant. JOINT MOTION TO AMEND TRACKING ORDER DEADLINES Plaintiffs Kelly Woods and Robert Karle, along with Defendant Amedisys Holding, LLC, respectfully move the Court to amend the tracking order deadlines as set forth herein. In support thereof, the parties state: 1. Per the Court’s Tracking Order in this case, the discovery deadline is August 25, 2022 and the deadline for (1) serving a dispositive motion is September 26, 2022, and (2) filing the same is October 24, 2022. 2. The Plaintiff has served requests for production and interrogatories on Defendant and Defendant is currently preparing its responses thereto. 3. Plaintiff intends to take a Rule 30(b)(6) deposition of Defendants, and Defendants intend to take Plaintiffs’ depositions. 4. Due to the press of other business and prescheduled commitments in other matters, the parties need some additional time to complete the discovery they intend to take, as reflected above. 5. The parties, therefore, request that the Court extend the tracking order deadlines as follows: Date Filed 8/23/2022 4:43 PM Superior Court - Norfolk Docket Number 2182CV00989 a. Discovery Deadline: November 30, 2022; b. Rule 56 Motions Served: January 31, 2023; c. Rule 56 Motions Filed: March 3, 2023. WHEREFORE, Plaintiffs and Defendant respectfully move the Court to amend the Scheduled Order accordingly. Respectfully submitted, KELLY WOODS & ROBERT KARLE, AMEDISYS HOLDING, INC. /s/ Stacy Thomsen /s/ Joshua D. Nadreau Stacy Thomsen, BBO No. 706746 Joshua D. Nadreau, BBO No. 688970 Law Office of Nicholas F. Ortiz, P.C. FISHER & PHILLIPS LLP 50 Congress Street, Suite 540 200 State Street, 7th Floor Boston, MA 02109 Boston, Massachusetts 02109 swt@mass-legal.com Tel: (617) 722-0044 Fax: (617) 532-5899 jnadreau@fisherphillips.com Dated: August 23, 2022 CERTIFICATE OF SERVICE I, Joshua D. Nadreau, counsel for Defendant, certify that a true copy of the foregoing was served via email, upon the following: Stacy Thomsen, Esq. Law Office of Nicholas F. Ortiz, P.C. 50 Congress Street, Suite 540 Boston, MA 02109 swt@mass-legal.com /s/ Joshua D. Nadreau Joshua D. Nadreau Dated: August 23, 2022 -2-