On July 29, 2020 a
Hearing
was filed
involving a dispute between
Htv International Pvt Ltd 2,
Nsamba, John,
and
Avix Mining Group Llc,
Borille, Alacir,
Borille, Bruno,
for Contract / Business Cases
in the District Court of Suffolk County.
Preview
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COMMONWEALTH OF MASSACHUSETTS
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SUFFOLK, ss THE SUPERIOR COURT | I
OF THE TRIAL COURT
CIVIL ACTION | ji
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JOHN NSAMBA HTV My
INTERNATIONAL PVT LTD 2
Plaintiffs, Docket No. 2084CV01691
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AVIX MINING GROUP LLC, I:
ALACIR BORILLE AND BRUNO te
BORILLE \|
Defendants
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MOTION TO CONTINUE DAMAGES HEARING "
NOT OPPOSED/ASSENTED TO BY DEFENDANTS COUNSEL I
Wy
NOW COMES Ed Tremblay, Esq. of the firm Edmond P. Tremblay and Assoc. PC.,
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and respectfully moves this Honorable Court to continue the Damages Hearing in the
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above-captioned action from December 7, 2021, an additional 2 months, to February yt
8.2022.
Connected to this Request for Continuance, a Motion for Withdrawal (for cause) by I fh
Plaintiffs’ Counsel was delayed due to the pendency of Plaintiffs’ earlier discovery I
motions. Plaintiffs would now be more appropriately served by alternative counsel, I fi
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but there is insufficient time for a traditional 9A rule motion, etc., to arrange for
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replacement counsel, preparation of calculation/proofs/affidavits in support of
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damages, 14-day notice, etc. in time for the scheduled December 7",2021, Damages
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Hearing, since receiving the Court Judgment order October 5, 2021.
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As further justification for this request, Defendants’ counsel notes a Bankruptcy Court |!
conflict on December 7%, 2021. il
Defendants’ Counsel has reviewed these papers and has expressed non-
opposition/assent to the proposed continuation thereto. Both Plaintiffs’ and
Defendants’ Counsels have conferred and agree that the intent of Rule 9A with respect
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to the parties is thereby provided for in this manner by virtue of the non-
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opposition/assent, etc.
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WHEREFORE, Counsel for Plaintiffs respectfully moves this Court for continuation
of the currently scheduled December 7, 2021 damages hearing to February 8",2022. It
Respectfully Submitted,
I,
John Nsamba
{|
HTV International Pvt Ltd 2
By Their Withdrawing Counsel, |
Respectfully submitted,
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Ed Tremblay, Esq.
BBO #642249 I
1278 GAR Highway # 66
Swansea, MA 02777 I I!
Phone: (508)672-5200 Ext. 126 li
Fax.: (508)300-9170 Hl
epti@eptlaw.com
Dated: 11/8/2021
4
Assenting Defendants by Their Attorney
Alex R. Hess [BBO# 679957]
Ahess@arhlawgroup.com
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Alex R. Hess Law Group
245 First Street, 18th Floor I
Riverview Il
Cambridge, MA 02142
Tel. (610) 730-9472 4
Fax.(617) 444-8405 i!
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Dated:
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Document Filed Date
November 12, 2021
Case Filing Date
July 29, 2020
Category
Contract / Business Cases
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" {i it COMMONWEALTH OF MASSACHUSETTS ‘| SUFFOLK, ss THE SUPERIOR COURT | I OF THE TRIAL COURT CIVIL ACTION | ji = I 3 oO ft JOHN NSAMBA HTV My INTERNATIONAL PVT LTD 2 Plaintiffs, Docket No. 2084CV01691 vl i Di s3 YS. | AVIX MINING GROUP LLC, I: ALACIR BORILLE AND BRUNO te BORILLE \| Defendants ‘| MOTION TO CONTINUE DAMAGES HEARING " NOT OPPOSED/ASSENTED TO BY DEFENDANTS COUNSEL I Wy NOW COMES Ed Tremblay, Esq. of the firm Edmond P. Tremblay and Assoc. PC., hy and respectfully moves this Honorable Court to continue the Damages Hearing in the I A above-captioned action from December 7, 2021, an additional 2 months, to February yt 8.2022. Connected to this Request for Continuance, a Motion for Withdrawal (for cause) by I fh Plaintiffs’ Counsel was delayed due to the pendency of Plaintiffs’ earlier discovery I motions. Plaintiffs would now be more appropriately served by alternative counsel, I fi | HW but there is insufficient time for a traditional 9A rule motion, etc., to arrange for [| replacement counsel, preparation of calculation/proofs/affidavits in support of \! damages, 14-day notice, etc. in time for the scheduled December 7",2021, Damages I Hearing, since receiving the Court Judgment order October 5, 2021. j lI I " |! a As further justification for this request, Defendants’ counsel notes a Bankruptcy Court |! conflict on December 7%, 2021. il Defendants’ Counsel has reviewed these papers and has expressed non- opposition/assent to the proposed continuation thereto. Both Plaintiffs’ and Defendants’ Counsels have conferred and agree that the intent of Rule 9A with respect i! to the parties is thereby provided for in this manner by virtue of the non- it " opposition/assent, etc. \ WHEREFORE, Counsel for Plaintiffs respectfully moves this Court for continuation of the currently scheduled December 7, 2021 damages hearing to February 8",2022. It Respectfully Submitted, I, John Nsamba {| HTV International Pvt Ltd 2 By Their Withdrawing Counsel, | Respectfully submitted, a i ve it Ed Tremblay, Esq. BBO #642249 I 1278 GAR Highway # 66 Swansea, MA 02777 I I! Phone: (508)672-5200 Ext. 126 li Fax.: (508)300-9170 Hl epti@eptlaw.com Dated: 11/8/2021 4 Assenting Defendants by Their Attorney Alex R. Hess [BBO# 679957] Ahess@arhlawgroup.com |\ 2 tI | Mi i . lI 1 Alex R. Hess Law Group 245 First Street, 18th Floor I Riverview Il Cambridge, MA 02142 Tel. (610) 730-9472 4 Fax.(617) 444-8405 i! |! Dated: \I ‘| 1! 1! I i Mu I | Ir Ul mt |! i: \ {| | Vl | i rt I i |I | 1 1 i Ir tf