On August 31, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Compton, Theresa D,
and
Smith, Eli,
University Of Massachusetts Dartmouth,
for Actions Involving the State/Municipality
in the District Court of Bristol County.
Preview
Date Filed 7/28/2023 1:53 PM
‘Superior Court - Bristol
Docket Number 2173CV00633.
BRISTOL,SS SUPERIOR COURT
Id. FILED
JUL 2 8 2023
COMMMONWEALTH OF MASSACHUSETTS JENNIFER A: SULLIVAN, ESQ.
GLERIC (MAGISTRATE
BRISTOL DIVISION . SUPERIOR COURT DEPT.
DOCKET NO.: 2173CV00633 -
THERESA D. COMPTON, Plaintiff vs. UNIVERSITY OF MASSACHUSETTS
DARTMOUTH and ELI SMITH, Defendants
JOINT MOTION TO EXTEND DISCOVERY DEADLINE AND STATEMENT OF
REASONS
Now come the plaintiff and Defendant University of Massachusetts [defendant Eli Smith
is in default for failure to file an answer]‘and moves for an extension of the discovery deadline
from August 22, 2023 to and including November 20, 2023.
The parties state as grounds that Plaintiff has noticed the depositions for August 1, 2023,
August 3, August 4, 2023 and August 9, 2023. The August 4, 2023 deposition has been
confirmed, and one of the other depositions has been continued to a date inside of the discovery
deadline, and the parties have agreed to continue the August 1, 2023 deposition. However,
because of scheduling conflicts and vacations of counsel and witnesses, additional time is needed.
to complete discovery. Further Defendant intends to take the Plaintiff's deposition.
Specifically:
e Defendant’s counsel is on vacation the week of August 7, 2023;
Plaintiff's counsel is on vacation and out the country from August 31, 2023 to
September 20, 2023.
Defendant’s counsel is on trial the last week of September 2023.
A witness is on vacation and out of state effectively the entire month of August
and her counsel is unavailable on August 3, 2023. Early October 2023 dates are
under discussion for her rescheduled deposition.
Date Filed 7/28/2023 1:53 PM.
Superior Court
- Bristol
Docket Number 2173CV00633
RESPECTFULLY SUBMITTED
Plaintiff .
Theresa Compton
By her attorney
/s/ Margaret A. Ishihara
Margaret A Ishihara, BBO#247930
Law Office of Margaret A. Ishihara
2527 Cranberry Highway, Unit D3
PO Box 71
Wareham,.MA. 02571
Telephone: (508) 295-1570
Email: ishiharalaw1 @gmail.com
Date: 28 July 2023
Defendant
University of Massachusetts
By their Attorney
s/ Michael Hoven
Michael Hoven
Associate Counsel
University of Massachusetts
Office of the General Counsel
333 South Street, 4" Floor
Shrewsbury, MA. 01545
Email: mhoven@umassp.edu
Date: 28 July 2023
Date Filed 7/28/2023 1:53 PM
‘Superior Court - Bristol
Docket Number 2173CV00633
CERTIFICATE OF SERVICE
‘Thereby certify that J have this day served the within document by electronic mail to:
Michael Hoven
Associate Counsel
University of Massachusetts
Office of the General Counsel
333 South Street, 4" Floor
Shrewsbury, MA. 01545
Email: mhoven@umassp.edu
Date: 28 July 2023 /s/ Margaret A. Ishihara
Margaret A. Ishihara
Document Filed Date
July 28, 2023
Case Filing Date
August 31, 2021
Category
Actions Involving the State/Municipality
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Date Filed 7/28/2023 1:53 PM ‘Superior Court - Bristol Docket Number 2173CV00633. BRISTOL,SS SUPERIOR COURT Id. FILED JUL 2 8 2023 COMMMONWEALTH OF MASSACHUSETTS JENNIFER A: SULLIVAN, ESQ. GLERIC (MAGISTRATE BRISTOL DIVISION . SUPERIOR COURT DEPT. DOCKET NO.: 2173CV00633 - THERESA D. COMPTON, Plaintiff vs. UNIVERSITY OF MASSACHUSETTS DARTMOUTH and ELI SMITH, Defendants JOINT MOTION TO EXTEND DISCOVERY DEADLINE AND STATEMENT OF REASONS Now come the plaintiff and Defendant University of Massachusetts [defendant Eli Smith is in default for failure to file an answer]‘and moves for an extension of the discovery deadline from August 22, 2023 to and including November 20, 2023. The parties state as grounds that Plaintiff has noticed the depositions for August 1, 2023, August 3, August 4, 2023 and August 9, 2023. The August 4, 2023 deposition has been confirmed, and one of the other depositions has been continued to a date inside of the discovery deadline, and the parties have agreed to continue the August 1, 2023 deposition. However, because of scheduling conflicts and vacations of counsel and witnesses, additional time is needed. to complete discovery. Further Defendant intends to take the Plaintiff's deposition. Specifically: e Defendant’s counsel is on vacation the week of August 7, 2023; Plaintiff's counsel is on vacation and out the country from August 31, 2023 to September 20, 2023. Defendant’s counsel is on trial the last week of September 2023. A witness is on vacation and out of state effectively the entire month of August and her counsel is unavailable on August 3, 2023. Early October 2023 dates are under discussion for her rescheduled deposition. Date Filed 7/28/2023 1:53 PM. Superior Court - Bristol Docket Number 2173CV00633 RESPECTFULLY SUBMITTED Plaintiff . Theresa Compton By her attorney /s/ Margaret A. Ishihara Margaret A Ishihara, BBO#247930 Law Office of Margaret A. Ishihara 2527 Cranberry Highway, Unit D3 PO Box 71 Wareham,.MA. 02571 Telephone: (508) 295-1570 Email: ishiharalaw1 @gmail.com Date: 28 July 2023 Defendant University of Massachusetts By their Attorney s/ Michael Hoven Michael Hoven Associate Counsel University of Massachusetts Office of the General Counsel 333 South Street, 4" Floor Shrewsbury, MA. 01545 Email: mhoven@umassp.edu Date: 28 July 2023 Date Filed 7/28/2023 1:53 PM ‘Superior Court - Bristol Docket Number 2173CV00633 CERTIFICATE OF SERVICE ‘Thereby certify that J have this day served the within document by electronic mail to: Michael Hoven Associate Counsel University of Massachusetts Office of the General Counsel 333 South Street, 4" Floor Shrewsbury, MA. 01545 Email: mhoven@umassp.edu Date: 28 July 2023 /s/ Margaret A. Ishihara Margaret A. Ishihara