Motion,Ex Parte: Wheaton, Kathryn et al vs. 3C TCP LLC et al

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                                                                            NOTIFY
                            COMMONWEALTH            OF MASSACHUSETTS

SUFFOLK, SS.                                             SUPERIOR COURT DEPARTMENT
                                                         OF THE TRIAL COURT
                                                         CIVIL ACTION NO. 21-2017 B


SEAFAN REALTY TRUST, LLC,                                      Pe A /2 2) No cetrn
KATHRYN WHEATON, MANAGER, AND
KATHRYN WHEATON, INDIVIDUAL
Plaintiffs,
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3CTCP, LLC, TOUCHSTONE CAPITAL                                ste FC Dibeut.
PARTNERS COMMERCIAL FUNDING, LLC
THOMAS F. MEADE, MANAGER
Defendants.                                                              Jeiprho J? i
                          OPPOSITION TO PLAINTIFF’S
      MOTION FOR DEFAULT JUDGMENT AND MOTION TO STRIKE OPPOSITION
         and ALTERNATIVELY, EMERGENCY MOTION FOR ENLARGEMENT

         NOW COME the Defendants in the above-captioned action and hereby submits this
                                                                                                            Noh Ce.

 opposition to the Plaintiffs’ Motion for Default Judgment and Motion to Strike Defendant’s
                                                                                                            Sent
Answer to Plaintiff's Complaint and Defendant’s Opposition to Plaintiff's Motion. Alternatively,             ( © . \3,   2

 Defendants’ move for emergency enlargement of period to respond to Plaintiff's Complaint. As                Kee
 grounds therefor, the Defendants state the following:
                                                                                                             Sato
          1.   The   only relief requested in Plaintiffs’ Complaint was for a temporary restraining                 Pc
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               order against Defendants’ taking any adverse action against Plaintiffs with respect to

               the subject properties through September 30, 2021.                                               leu
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               After a hearing on September 9, 2021, this Court granted the relief requested in

               Plaintiffs’ Complaint by issuing a preliminary injunction through October 1, 2021.
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