On January 29, 2021 a
Miscellaneous
was filed
involving a dispute between
Alves, Antonia V,
and
Estate Of George Elvis Hodge,
Hodge, Lezan,
Lima, Goncalo,
Motorcade, Llc,
Paylee, Llc,
Schneider, Elliot,
for Equitable Remedies
in the District Court of Bristol County.
Preview
2
DOCKET NUMBER ‘Trial Court of Massachusetts ae a
file
2i1aevood1H4A
CIVIL ACTION COVER SHEET The Superior Court
PLAINTIFF(S}: Antonia Alves. col
Bristol
ADDRESS: 17 Travers Street, Dartmouth, MA 02747
DEFENDANT(S): Estate of George Elis Hodge, Paylee, LLC, & Lezan Hodge, 562 County
‘Street, New Bedford, MA 02740
ATTORNEY: John A, Markey, Jr, Esq. Motorcada, LLC & Eliot Schneider, 10 Owl Drive, Sharon MA, 02034
ADDRESS: ‘Moses, Smith, Markey, & Walsh, 50 Hemers Wharf, New Becford, MA ADDRESS: BRISTOL SS SUPERIOR COURT
02749, and Stophen S. Brown, Esq. Law Office of Stephen S. Brown, P.O. Box 50055 FILED
New Bedford, MA 02745 JAN 2 9 2074
BBO: Atty. Markey: 633540, Atty Brown: 687413
TYPE OF ACTION AND TRACK DESIGNATION (see reverse side) wiARC £SQ.
CODE NO. ‘TYPE OF ACTION (speclfy) cl
i ATE
D014 Specific Performance ES
*If "Other" please describe:
Is there a claim under G.L. c. 9347 Js this_a class actlon under Mass. R. Clv. P. 237
[xX] Yes * NO. complaint to be amended for 93A YES
STATEMENT OF DAMAGES PURSUANT TO GLL. c. 212, § 3A
The following is a full, itemized and detailed statement of the facts on which the undersigned plaintiff or plaintiffs counsel relies to determine money damages.
For this form, disregard double or treble damage claims; indicate single damages only.
(attach additional sheets as necessary)
|A. Documented medical expenses to date:
1. Total hospital expenses:
2. Total doctor expenses.
3, Total chiropractic expenses
4, Total physical therapy expel
5. Total other expenses (describe below)
|B. Documented lost wages and compensation to date
'C, Documented property damages to date ....
ID. Reasonably anticipated future medical and hospital expenses .
IE, Reasonably anticipated lost wages
IF. Other documented items of damages (desc 300,000
IG. Briefly describe plaintiff's injury, including the nature and extent of injury:
Seller in real estate transaction fraudulently conveyed property to third party before closing, retaining Plaintiffs deposit.
TOTAL (A-F):$ 300,000
CLA!
{attach additional sheets as necessary)
This.action includes a claim involving collection of a debt incurred pursuant fo a revolving c agreement. Mass. R. Civ. P. 8.1(a).
Provide a detailed description of claim(s):
TOTAL: $ 1200
Date; Yan 29, 2021
Signature of Attorney/ Unrepresented Plaintiff:
RELATED ACTIONS: Please provide the case me and county of any ross actions pending in the Superior Court.
CERTIFICATION PURSUANT TO SJC RULE 1:18
Uhereby certify that | have complied with requirements of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SJC
Rule 4:18) requiring that | provide my clients with information about cg f
Document Filed Date
January 29, 2021
Case Filing Date
January 29, 2021
Category
Equitable Remedies
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2 DOCKET NUMBER ‘Trial Court of Massachusetts ae a file 2i1aevood1H4A CIVIL ACTION COVER SHEET The Superior Court PLAINTIFF(S}: Antonia Alves. col Bristol ADDRESS: 17 Travers Street, Dartmouth, MA 02747 DEFENDANT(S): Estate of George Elis Hodge, Paylee, LLC, & Lezan Hodge, 562 County ‘Street, New Bedford, MA 02740 ATTORNEY: John A, Markey, Jr, Esq. Motorcada, LLC & Eliot Schneider, 10 Owl Drive, Sharon MA, 02034 ADDRESS: ‘Moses, Smith, Markey, & Walsh, 50 Hemers Wharf, New Becford, MA ADDRESS: BRISTOL SS SUPERIOR COURT 02749, and Stophen S. Brown, Esq. Law Office of Stephen S. Brown, P.O. Box 50055 FILED New Bedford, MA 02745 JAN 2 9 2074 BBO: Atty. Markey: 633540, Atty Brown: 687413 TYPE OF ACTION AND TRACK DESIGNATION (see reverse side) wiARC £SQ. CODE NO. ‘TYPE OF ACTION (speclfy) cl i ATE D014 Specific Performance ES *If "Other" please describe: Is there a claim under G.L. c. 9347 Js this_a class actlon under Mass. R. Clv. P. 237 [xX] Yes * NO. complaint to be amended for 93A YES STATEMENT OF DAMAGES PURSUANT TO GLL. c. 212, § 3A The following is a full, itemized and detailed statement of the facts on which the undersigned plaintiff or plaintiffs counsel relies to determine money damages. For this form, disregard double or treble damage claims; indicate single damages only. (attach additional sheets as necessary) |A. Documented medical expenses to date: 1. Total hospital expenses: 2. Total doctor expenses. 3, Total chiropractic expenses 4, Total physical therapy expel 5. Total other expenses (describe below) |B. Documented lost wages and compensation to date 'C, Documented property damages to date .... ID. Reasonably anticipated future medical and hospital expenses . IE, Reasonably anticipated lost wages IF. Other documented items of damages (desc 300,000 IG. Briefly describe plaintiff's injury, including the nature and extent of injury: Seller in real estate transaction fraudulently conveyed property to third party before closing, retaining Plaintiffs deposit. TOTAL (A-F):$ 300,000 CLA! {attach additional sheets as necessary) This.action includes a claim involving collection of a debt incurred pursuant fo a revolving c agreement. Mass. R. Civ. P. 8.1(a). Provide a detailed description of claim(s): TOTAL: $ 1200 Date; Yan 29, 2021 Signature of Attorney/ Unrepresented Plaintiff: RELATED ACTIONS: Please provide the case me and county of any ross actions pending in the Superior Court. CERTIFICATION PURSUANT TO SJC RULE 1:18 Uhereby certify that | have complied with requirements of Rule 5 of the Supreme Judicial Court Uniform Rules on Dispute Resolution (SJC Rule 4:18) requiring that | provide my clients with information about cg f