On August 19, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Halilaj, Vera,
and
Abbvie Bioresearch Center Inc.,
Am-Pm Cleaning Services Inc.,
Gdi Services Inc.,
Lusignan Security Agency Inc.,
Worcester Tc Llc,
for Torts
in the District Court of Worcester County.
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ZA*N
COMMONWEALTH OF MASSACHUSETTS
Worcester, ss | Worcester Superior Court
No. 22CV942B i
VERA HALIUAJ,
VS
Plaintiff
I
FILED
|
JAN 21 2023
mm We
ABBVIE BIORESHARCH CENTER INC
GDI SERVICES formerly known as fi, .CLERK
AM-PM CLEAN iG SERVICES, INC.
and WORCESTERJTC LLC.
Defendants,
ILAINTIFF’S MOTION TO AMEND THE COMPLAINT
'
Now comejtthe Plaintiff in the above captioned matter and move this Honorable Court,
pursuant to MRCHR. 15(a) to add a Party Defendant to the Complaint.
As spund therefore the Plaintiff states the following:
i
13
1. The Defiindant, WORCESTER TC LLCi is a Party Defendant which isi outlined in
Colnt Tipree of the Second Amended Complaint & Claim for Jury Trial.
2.Nb will suffer any prejudice if the complaint isi amended. The case is not
current on any trial list. The Defendant will have ample opportunity well in advance
ofjtrial flo conduct discovery and prepare its defenses.
3. The allijwance of this motion will avoid duplicative litigation and ill be conducive to
judicial economy.
Wherefo: Plaintiff prays this Honorable Cor allow said Motion of the Plaintiff to
amend Complaint, which Amended Cofiplaitt is attached hereto as Exhibit “A”
“OS
ILA.
y Her Attofney,
DennisJ. Ellis Esquire
BBO: 551520
The Law Offices of Dennis J. Ellis & Associates
340 Main Street, Suite 300
Worcester, Massachusetts 01608
(508) 739-2000
| ellislaw@ellislawgroup.com
DATED: Jan
Document Filed Date
February 21, 2023
Case Filing Date
August 19, 2022
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ZA*N COMMONWEALTH OF MASSACHUSETTS Worcester, ss | Worcester Superior Court No. 22CV942B i VERA HALIUAJ, VS Plaintiff I FILED | JAN 21 2023 mm We ABBVIE BIORESHARCH CENTER INC GDI SERVICES formerly known as fi, .CLERK AM-PM CLEAN iG SERVICES, INC. and WORCESTERJTC LLC. Defendants, ILAINTIFF’S MOTION TO AMEND THE COMPLAINT ' Now comejtthe Plaintiff in the above captioned matter and move this Honorable Court, pursuant to MRCHR. 15(a) to add a Party Defendant to the Complaint. As spund therefore the Plaintiff states the following: i 13 1. The Defiindant, WORCESTER TC LLCi is a Party Defendant which isi outlined in Colnt Tipree of the Second Amended Complaint & Claim for Jury Trial. 2.Nb will suffer any prejudice if the complaint isi amended. The case is not current on any trial list. The Defendant will have ample opportunity well in advance ofjtrial flo conduct discovery and prepare its defenses. 3. The allijwance of this motion will avoid duplicative litigation and ill be conducive to judicial economy. Wherefo: Plaintiff prays this Honorable Cor allow said Motion of the Plaintiff to amend Complaint, which Amended Cofiplaitt is attached hereto as Exhibit “A” “OS ILA. y Her Attofney, DennisJ. Ellis Esquire BBO: 551520 The Law Offices of Dennis J. Ellis & Associates 340 Main Street, Suite 300 Worcester, Massachusetts 01608 (508) 739-2000 | ellislaw@ellislawgroup.com DATED: Jan