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

• 
• 
• 
• 

						
                                
Preview
                                Date Filed 3/8/2023 10:38 AM
Superior Court - Hampden.
Docket Number 2079CV00681




                                                     COMMONWEALTH             OF MASSACHUSETTS

                   HAMPDEN.           SS.                                                SUPERIOR COURT DEPARTMENT

                                                                                         CIVIL ACTION NO.:        2079CV00681




                   CHARLOTTE GRANGER,

                               Plaintiff                                                                03/08/23
                                            Vv.

                   TRINITY HEALTH OF NEW ENGLAND
                   CORPORATION, INC.
                               Defendant



                                     ASSENTED TO MOTION TO CONTINUE STATUS CONFERENCE
                               Plaintiff respectfully requests that this Honorable Court allow a

                   continuance in the above captioned matter with regard to the Status Conference, which is

                   currently scheduled on March 13, 2023.

                               As grounds therefore, Plaintiff states that she served a Massachusetts Rules of Civil

                   Procedure 27 Petition to Conduct a Deposition on the Defendant on March 8, 2023 via Superior

                   Court Rule 9A.            It is anticipated that a hearing on this Petition will be scheduled, and as such,

                   this Court will be updated on the status of this case at said hearing.


                               Plaintiff has not filed this motion for the purposes of delay and both parties agree that

                   neither will be prejudiced by allowance of this motion.




                                                                                                                                 13
Date Filed 3/8/2023 10:38 AM
Superior Court - Hampden.
Docket Number 2079CV00681




                                                        RESPECTFULLY SUBMITTED,
                                                        PLAINTIFF CHARLOTTE GRANGER,
                                                        By Her Attorney
                   Date:       March 8, 2023


                                                        /s/ Amy L. Motto

                                                        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

                   ASSENTED TO:


                  /s/ Jennifer A. Rymarski
                   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