Motion,Ex Parte: Yanoff, Randy vs. Johns Sewer & Pipe Cleaning, Inc. et al

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                \O
                                                                                                                 O
                  uo
                  =>       COMMONWEALTH                   OF MASSACHUSETTS
                  Dk
  4.              oz
                 OD
                 Lo
 oF
NORFOLK»                                                            SUPERIOR COURT
                 lad
                 ao                                                  C.A. NO. 20 CV 1013
                  a

       ==
RANDY YANOFF,
                               Plaintiff



JOHN'S SEWER & PIPE CLEANING, INC.
KORY CAMACHO-DASILVA,
               Defendants



                       JOINT MOTION TO EXTEND DISCOVERY DEADLINE


            The Parties, Plaintiff, Randy Yanoff and Defendants, John’s Sewer & Pipe Cleaning Inc,

and Kory Camacho- DaSilva., jointly move to extend the discovery deadline in this matter to

December 1, 2021. As grounds for this motion, the parties state the following:

            1) The discovery deadline in this matter is August 23, 2021;

            2) The plaintiff continues to require medical treatment and recently underwent a medical

                 procedure at Beth Israel Hospital for the destruction of nerves on the right side of his

                 lower back;

            3) The plaintiff is scheduled for additional medical procedures in the coming months;

            4)   Counsel has had significant difficulty obtaining the extensive medical records of the

                 plaintiff due in part to the pandemic;

            5)   The Parties have been      working   diligently to complete   discovery, but have been

                 unable to do so due to various scheduling conflicts;
6)   This is the Parties’ first request for an extension of the discovery timelines.

         7) The Parties respectfully request that this Honorable            court extend the discovery

              deadline to December 1, 2021,      and all subsequent deadlines accordingly under the

              Tracking Order.



                                                        Respectfully submitted,


For the Plaintiff,                                      For the Defendants,
Randy Yanoff                                            John’s Sewer & Pipe Cleaning Inc et al
By his Attorney                                         By their Attorney


SAA            hp    t—
  . Chistolini, Esquire
I Oy# + 554457
                                                           Renn
                                                          BBO # 555453
                                                                      avd      ho
                                                          Bernard W. Schranze, Esquire
                                                                                       Sehrar
                                                                                                 vee
Chistolini & DeSimone,      P.C.                          Hanover Law Group
21 McGrath Highway, Suite 201                             50 Resnick Road, Suite 201B
Quincy, MA 02169                                          Plymouth, MA 02360
617 984 0021                                              508 591 6912




Dated:    June7, 2021
CERTIFICATE OF SERVICE


       I, John A. Chistolini, Counsel for the Plaintiff, Randy Yanoff, hereby certify that I served
a copy of The Joint Motion to Extend Discovery Deadline by US mail, postage prepaid, this 7th
day of June, 2021 to:



Bernard Schranze, Esquire
The Hanover Law Group
50 Resnik Road
Suite 201B
Plymouth, MA     02360


                                                              Od          4 ChYA—
                                                             Toho) Chistlini