Motion,Ex Parte: Granger, Charlotte vs. Trinity Health of New England Corporation, Inc.

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                                COMMONWEALTH OF MASSACHUSETTS

HAMPDEN, ss.                                          SUPERIOR COURT DEPARTMENT
                                                      CIVIL ACTION NO. 2079CV00681

CHARLOTTE GRANGER,                                    )
                                                      )
               Plaintiff,                             )

v.
                                                      )
                                                      )
                                                           04/27/2022
                                                      )
TRINITY HEALTH OF NEW ENGLAND                         )
CORPORATION, INC.,                                    )
                                                      )
               Defendant.                             )
                                                      )


                JOINT MOTION TO CONTINUE RULE 16 CONFERENCE


       The parties respectfully request that this Honorable Court allow a continuance in the

above captioned matter with regard to the Rule 16 Conference, which is currently scheduled on

April 28, 2022. The parties respectfully request the Court to docket the Rule 16 Conference for

May 18th or 24th or whatever later date best suits this Court.

       As grounds therefore, Plaintiff's counsel has just tested positive for COVID-19 and is

medically required to isolate. Defendant's counsel has kindly agreed to extend the date of this

Conference due to these circumstances.

       This Motion has not been filed for the purposes of delay and both parties agree that

neither will be prejudiced by allowance of this motion.




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RESPECTFULLY SUBMITTED,
PLAINTIFF CHARLOTTE GRANGER,
By Her Attorney
 /s/ Amy L. Mottor
Amy L. Mottor/BBO# 679263
DUNN & PHILLIPS, P.C.
150 Fearing Street, Suite 25
Amherst, MA 01002
(413)549-8849/Fax: (413) 835-0125
amottor@dunnandphillips.com


DEFENDANT TRINITY HEALTH
OF NEW ENGLAND CORPORATION, INC.
By its Attorney,
/s/ Jennifer A. Rymarksi
Jennifer A. Rymarski, BBO # 659824
MORRISON MAHONEY LLP
Tower Square
1500 Main Street, Suite 2400
PO Box 15387
Springfield, MA 01115
(P): 413-737-4373
(F): 413-739-3125



Dated: 4/26/22