On December 30, 2020 a
Party Discovery
was filed
involving a dispute between
Pirzl, John H,
and
Bradley, Kelsey,
for Torts
in the District Court of Berkshire County.
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5 Despite the assurances, the Defendant has not provided
answers to Plaintiff's interrogatories.
Signed under the pains and penalties of perjury, this Ze
day of May, 2021.
(etl
Cynthia A. Spinola, ‘Esq.
(@ \
COMMONWEALTH OF MASSACHUSETTS
~
BERKSHIRE, SS. SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
..CIVIL ACTION NO. 2076CV189
THE COMMONWEALTH OF MASSACHUSETTS
BERKSHIRE S.S. SUPERIOR COURT
F F
JOHN PIRZL, | !
Plaintiff L L
E JUN 04 2021 E
| pene ae
Vv
KELSEY BRADLEY,
Defendant
AFFIDAVIT IN SUPPORT OF MOTION TO COMPEL
PRODUCTION OF ANSWERS TO INTERROGATORIES FROM DEFENDANT
I, Cynthia A. Spinola, Esq., being duly sworn, do depose and
say as follows:
1 I am an attorney with the firm of Hashim & Spinola
located at 82 Wendell Avenue, Pittsfield, MA, which firm
represents the plaintiff in this matter.
2 This claim is for personal injuries suffered by the
plaintiff as a result of the negligent operation of a motor
vehicle by the defendant on March 13, 2018.
3 On or about January 12, 2021, Defendant was forwarded
the Plaintiff's Request for Interrogatories.
4 On March 22, 2021 I participated in a 9C conference with
counsel and I was assured ‘that the interrogatory answers would be
made.
Document Filed Date
June 04, 2021
Case Filing Date
December 30, 2020
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5 Despite the assurances, the Defendant has not provided answers to Plaintiff's interrogatories. Signed under the pains and penalties of perjury, this Ze day of May, 2021. (etl Cynthia A. Spinola, ‘Esq. (@ \ COMMONWEALTH OF MASSACHUSETTS ~ BERKSHIRE, SS. SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT ..CIVIL ACTION NO. 2076CV189 THE COMMONWEALTH OF MASSACHUSETTS BERKSHIRE S.S. SUPERIOR COURT F F JOHN PIRZL, | ! Plaintiff L L E JUN 04 2021 E | pene ae Vv KELSEY BRADLEY, Defendant AFFIDAVIT IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF ANSWERS TO INTERROGATORIES FROM DEFENDANT I, Cynthia A. Spinola, Esq., being duly sworn, do depose and say as follows: 1 I am an attorney with the firm of Hashim & Spinola located at 82 Wendell Avenue, Pittsfield, MA, which firm represents the plaintiff in this matter. 2 This claim is for personal injuries suffered by the plaintiff as a result of the negligent operation of a motor vehicle by the defendant on March 13, 2018. 3 On or about January 12, 2021, Defendant was forwarded the Plaintiff's Request for Interrogatories. 4 On March 22, 2021 I participated in a 9C conference with counsel and I was assured ‘that the interrogatory answers would be made.