On June 30, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Suazo, Ernest,
and
Nicholson, Lisa,
for Torts
in the District Court of Worcester County.
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COMMONWEALTH OF MASSACHUSETTS
WORCESTER, ss. WORCESTER SUPERIOR COURT
CA NO.: 2085CV00683
ERNEST SUAZO,
Plaintiff
Vv
LISA NICHOLSON,
Defendant
Joint Motion to Amend the Tracking Order to Extend Deadli
ne:
(Rule 9a Waived by the Parties)
The Plaintiff, Ernest Suazo and the Defendant , Lisa
Nicholson, in the above captioned
matter jointly request that this honorable C ourt extend
the current tracking order pursuant to
Standi ng Order I-88D as follows:
|Event Current Deadline Proposed Deadline
|Discovery Completed ~_| 8/26/2021 6/29/2022
Rule 56 Motions (served) —_| 5/26/2021 7/29/2022
Final Pre-Trial Conference N/A 8/29/2022_
As further grounds for the same, the parties state as follows:
4
This is a joint motion by all the parties.
2 This case arises out of a motor vehicle collision that occurre d in
Millbury, Massachusetts
on August 10, 2017. The Plaintiff filed the ins! tant action on June 30, 2020, seeking
damages for the injuries he sustained.
New Plaintiff's counsel appeared on November 5, 2021
The parties to this action are working together agreeably.
The parties’ depositions have not been conducted.
Standing Order 1-88D ‘anticipates that there will be i instances when...the tracking
deadlines cannot reasonably be met.”
Moreover, “amendments to the tracking order of a case may be
granted upon motion, filed
in accordance with Superior Court Rule 9A, and for good cause
shown.” See Standing
Order 1-88D(1).
No party will be unfairly prejudiced by the allowance of this motion
and its allowance will
serve the interests of justice.
A proposed Order is attached for the Court’s convenience as
Ex. “A”.
WHEREFORE, the parties in the above captioned matter respec
Court to extend the current tracking order tfully jointly move this
.
Respectfully Submitted, Respectfully Submitted,
The Plaintiff, Gregory Disher, The Defendant, Lisa Nicholson
By his attorney,
By her attorney,
Bai PEa end Ah, ZD
RyanP. Brady Gerardo Schiano, Esq.
BBO #: 699124 BBO#: 684602
KECHES LAW GROUP, P.C. Mazzocca & Associates
2 Lakeshore Center, Third Floor 2000 West Park Drive, Suite 100
Bridgewater, MA 02324 Westborough, MA 01581
Tel. No.: (508) 822-2000 Tel. No. (508) 949-4375
Email: rbrady@kecheslaw.com Email: GSchiano@mapfre.com
Date: January 27, 2022
EXHIBIT “A”
COMMONWEALTH OF MASSACHUSETTS
WORCESTER, ss.
WORCESTER SUPERIOR COURT
CA NO.: 2085CV00683
ERNEST SUAZO,
Plaintiff
Vv.
LISA NICHOLSON,
Defendant
Proposed Order
After consideration of the submissions of the
parties and hearing, if any, the Court
hereby Orders that the tracking order deadlines are
extended as follows:
All Discovery Requests and Depositions Serve
d
and Non-Expert Depositions Completed
6/29/2022
All Motions under MRCP 56
7/29/2022
Final Pre-Trial Conference held and/or
Firm Trial Date Set.
8/29/2022
So Ordered this day of 2022
Associate Justice of the Superior Court
Document Filed Date
January 27, 2022
Case Filing Date
June 30, 2020
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COMMONWEALTH OF MASSACHUSETTS WORCESTER, ss. WORCESTER SUPERIOR COURT CA NO.: 2085CV00683 ERNEST SUAZO, Plaintiff Vv LISA NICHOLSON, Defendant Joint Motion to Amend the Tracking Order to Extend Deadli ne: (Rule 9a Waived by the Parties) The Plaintiff, Ernest Suazo and the Defendant , Lisa Nicholson, in the above captioned matter jointly request that this honorable C ourt extend the current tracking order pursuant to Standi ng Order I-88D as follows: |Event Current Deadline Proposed Deadline |Discovery Completed ~_| 8/26/2021 6/29/2022 Rule 56 Motions (served) —_| 5/26/2021 7/29/2022 Final Pre-Trial Conference N/A 8/29/2022_ As further grounds for the same, the parties state as follows: 4 This is a joint motion by all the parties. 2 This case arises out of a motor vehicle collision that occurre d in Millbury, Massachusetts on August 10, 2017. The Plaintiff filed the ins! tant action on June 30, 2020, seeking damages for the injuries he sustained. New Plaintiff's counsel appeared on November 5, 2021 The parties to this action are working together agreeably. The parties’ depositions have not been conducted. Standing Order 1-88D ‘anticipates that there will be i instances when...the tracking deadlines cannot reasonably be met.” Moreover, “amendments to the tracking order of a case may be granted upon motion, filed in accordance with Superior Court Rule 9A, and for good cause shown.” See Standing Order 1-88D(1). No party will be unfairly prejudiced by the allowance of this motion and its allowance will serve the interests of justice. A proposed Order is attached for the Court’s convenience as Ex. “A”. WHEREFORE, the parties in the above captioned matter respec Court to extend the current tracking order tfully jointly move this . Respectfully Submitted, Respectfully Submitted, The Plaintiff, Gregory Disher, The Defendant, Lisa Nicholson By his attorney, By her attorney, Bai PEa end Ah, ZD RyanP. Brady Gerardo Schiano, Esq. BBO #: 699124 BBO#: 684602 KECHES LAW GROUP, P.C. Mazzocca & Associates 2 Lakeshore Center, Third Floor 2000 West Park Drive, Suite 100 Bridgewater, MA 02324 Westborough, MA 01581 Tel. No.: (508) 822-2000 Tel. No. (508) 949-4375 Email: rbrady@kecheslaw.com Email: GSchiano@mapfre.com Date: January 27, 2022 EXHIBIT “A” COMMONWEALTH OF MASSACHUSETTS WORCESTER, ss. WORCESTER SUPERIOR COURT CA NO.: 2085CV00683 ERNEST SUAZO, Plaintiff Vv. LISA NICHOLSON, Defendant Proposed Order After consideration of the submissions of the parties and hearing, if any, the Court hereby Orders that the tracking order deadlines are extended as follows: All Discovery Requests and Depositions Serve d and Non-Expert Depositions Completed 6/29/2022 All Motions under MRCP 56 7/29/2022 Final Pre-Trial Conference held and/or Firm Trial Date Set. 8/29/2022 So Ordered this day of 2022 Associate Justice of the Superior Court