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  • Hanson, Eric W vs. Sr Ventures, Llc et al Declaratory Judgment G.L. c. 231A document preview
  • Hanson, Eric W vs. Sr Ventures, Llc et al Declaratory Judgment G.L. c. 231A document preview
						
                                

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Date Filed 8/25/2022 3:52 PM. ‘Superior Court - Middlegp> Docket Number 2281CV02278 L2 | COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, ss SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT ERIC W. HANSON a/k/a RICK HANSON, t Individually and derivatively on behalf of SR VENTURES, LLC, CIVIL ACTION NO. 2281CV02278 Plaintiff, Vv. RECEIVED 8/25/2022 t SR VENTURES, LLC, JOHN F. GALLANT, MICHAEL CONLEY and GALLANT & ERVIN, LLC, Defendants. MOTION OF THE PLAINTIFF, ERIC W. HANSON, TO AMEND THE COMPLAINT Now comes the plaintiff, Eric W. Hanson (“plaintiff”), and respectfully moves this Honorable Court, pursuant to Mass.R.Civ.P. 15(a), for leave to further amend the complaint in this case to add Kristen Ervin as a new party in order to determine the rights of the members to certain distributions made or to be made by SR Ventures, LLC (“SRV”). As grounds for the Motion, plaintiff states that at the time pleadings were filed in this case, he believed that the law firm of Gallant & Ervin LLC was a member of SRV as the capital contribution was identified as being made by Gallant & Ervin. However, defendant, John F. Gallant, recently provided information that he and Timothy Ervin separately owned their interest in SRV in their individual capacities and that Kristen Ervin now owns the interest held by her GALLAGHER & deceased spouse, Timothy Ervin. As a result, plaintiff seeks to amend his complaint to add CAVANAUGH LP COUNSELLORS AT LAW| THE GASLIGHT BUILDING} 22 SHATTUCK STREET Kristen Ervin as a party. g/27feote LOWELL, MA 01852 Date: On pevi Ce 978.452.0522 this motion is ALLOWED /' in, Fax 978.452.0482 7 hearin Slened: John T. Lu on yee no o becky y