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COMMONWEALTH OF MASSACHUSETTS.
SUPERIOR COURT
CIVIL TRIAL COURT DIVISION NOTIFY
Suffolk, ss. Civil DocketNo. 2184CV02017 4
Seafan Realty Trust, LLC, Kathryn Wheaton, fea Dene /
Ape
Manager, and Kathryn Wheaton, Individual
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Plaintiffs oF
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Commercial Funding, LLC, and Thomas F. Meade ae
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Manager p= 2°
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Defendants =
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PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S ANSWER TO PLAINTIFF’S
COMPLAINT AND DEFENDANT’S OPPOSITION TO PLAINTIFF*S MOTIONS
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Now come the Plaintiffs, Seafan Realty Trust, LLC, Kathryn Wheaton, Manager and as Sande
Individual, (““Seafan and Kathryn Wheaton”), and do hereby respectfully and humbly move this
(OA3BS
Honorable Court to Strike from the Record and the Court’s review, the Defendants, 3C TCP,
LLC, Touchstone Capital Partners Commercial Funding, LLC, Thomas F. Meade, Manager,(“3C Wehehe
TCP and Thomas Meade”), Answer, if any, to Plaintiff's Complaint, and Opposition, if any, to
Plaintiff's Motions, for Defendant’s failure to have answered within twenty (20) days the Betz
Plaintiff's Complaint and Motions filed on September 2, 2021, served by Summons by the Pe
Norfolk Sheriff on September 7, 2021, and required under the Mass Rules of Civil Procedure to
have been answered by September 27, 2021 Lio
Wherefore, the Plaintiffs, Seafan and Kathryn Wheaton, have moved and pray that this
Honorable Court find and order the Defendants, 3C TCP and Thomas Meade, in default and to
enter a Default Judgment against the Defendants under MRCVP Rule 55, and thereby grant the
Relief requested by the Plaintiffs.
And Wherefore, the Plaintiffs, Seafan and Kathryn Wheaton, do hereby respectfully move
and pray that this Honorable Court order the Defendant’s Answer to Plaintiffs Complaint, if
any, and the Defendant’s Opposition to Plaintiff's Motions, if any, Stricken from the Record,
Preview
= .- “\ofoa’ Lola 11 COMMONWEALTH OF MASSACHUSETTS. SUPERIOR COURT CIVIL TRIAL COURT DIVISION NOTIFY Suffolk, ss. Civil DocketNo. 2184CV02017 4 Seafan Realty Trust, LLC, Kathryn Wheaton, fea Dene / Ape Manager, and Kathryn Wheaton, Individual = Plaintiffs oF of rs on sm Commercial Funding, LLC, and Thomas F. Meade ae Qe AD Sc oo zo mz Manager p= 2° AS Bo mis mS Defendants = a PLAINTIFF’S MOTION TO STRIKE DEFENDANT’S ANSWER TO PLAINTIFF’S COMPLAINT AND DEFENDANT’S OPPOSITION TO PLAINTIFF*S MOTIONS pope Now come the Plaintiffs, Seafan Realty Trust, LLC, Kathryn Wheaton, Manager and as Sande Individual, (““Seafan and Kathryn Wheaton”), and do hereby respectfully and humbly move this (OA3BS Honorable Court to Strike from the Record and the Court’s review, the Defendants, 3C TCP, LLC, Touchstone Capital Partners Commercial Funding, LLC, Thomas F. Meade, Manager,(“3C Wehehe TCP and Thomas Meade”), Answer, if any, to Plaintiff's Complaint, and Opposition, if any, to Plaintiff's Motions, for Defendant’s failure to have answered within twenty (20) days the Betz Plaintiff's Complaint and Motions filed on September 2, 2021, served by Summons by the Pe Norfolk Sheriff on September 7, 2021, and required under the Mass Rules of Civil Procedure to have been answered by September 27, 2021 Lio Wherefore, the Plaintiffs, Seafan and Kathryn Wheaton, have moved and pray that this Honorable Court find and order the Defendants, 3C TCP and Thomas Meade, in default and to enter a Default Judgment against the Defendants under MRCVP Rule 55, and thereby grant the Relief requested by the Plaintiffs. And Wherefore, the Plaintiffs, Seafan and Kathryn Wheaton, do hereby respectfully move and pray that this Honorable Court order the Defendant’s Answer to Plaintiffs Complaint, if any, and the Defendant’s Opposition to Plaintiff's Motions, if any, Stricken from the Record,