On April 11, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Brown, Louis M,
and
City Of Leominster,
John Does 1 Through 10,
Massachusetts Interlocal Insurance Association,
Mazzarella, Dean,
for Torts
in the District Court of Worcester County.
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Date Filed 5/25/2023 10:09 AM
Superior Court - Worcester
Docket Number 2385CV00388
COMMONWEALTH OF MASSACHUSETTS
WORCESTER, ss. SUPERIOR COURT
C.A. NO.: 2385-CV-00388
LOUIS M. BROWN,
Plaintiff,
Vv.
CITY OF LEOMINSTER, JOHN DOES
1 THROUGH 10, MAYOR DEAN
MAZZARELLA and MASSACHUSETTS
INTERLOCAL INSURANCE
ASSOCIATION,
Defendants.
ASSENTED TO MOTION OF THE DEFENDANT, MASSACHUSETTS INTERLOCAL
INSURANCE ASSOCIATION [MISNAMED], TO SEVER AND STAY
COUNTS I AND Il] OF THE PLAINTIFF’S COMPLAINT
NOW COMES the defendant, incorrectly named as Massachusetts Interlocal Insurance
Association and more properly named as MIIA Property and Casualty Group, Inc. (“MIIA”), and
hereby moves to sever and stay Counts II and III of the plaintiff, Louis Brown’s (“Plaintiff”),
Complaint and Jury Claim (Docket Paper No. 2) until the underlying gross negligence claim
against the City of Leominster and Mayor Dean Mazzarella in Count I is resolved. This Motion
has been assented to by all parties. Additionally, in support of its Motion, MIIA relies upon the
attached Memorandum of Law.
WHEREFORE, the defendant, MIIA Property and Casualty Group, Inc., incorrectly
named as Massachusetts Interlocal Insurance Association, respectfully requests that this
Honorable Court grant its Motion to Sever and Stay and sever and stay Counts II and III of the
plaintiff, Louis Brown’s, Complaint and Jury Claim.
Date Filed 5/25/2023 10:09 AM
Superior Court - Worcester
Docket Number 2385CV00388
Dated: May 25, 2023 Respectfully submitted,
The Defendant,
MIIA Property and Casualty Group, Inc.,
By its attorneys,
/s/ Sarah Shipley
Arthur E. Maravelis (BBO# 564673)
Sarah A. Shipley (BBO# 678753)
TANG & MARAVELIS, P.C.
50 Mall Road, Suite 111
Burlington, MA 01803
781-221-1400
amaravelis@tangmaravelis.com
sshipley@tangmaravelis.com
Assented to:
/s/ Louis M. Brown
Louis M. Brown
Pro Se
16 Green Mountain Avenue
Leominster, MA 01453
617-935-4333
louismitchellbrown91@gmail.com
(Plaintiff)
/s/ Wendy L. Quinn
Wendy L. Quinn, Esquire (BBO #653954)
Hassett & Donnelly, P.C.
446 Main Street - 12th Floor
Worcester, MA 01608
508-791-6287
wquinn@hassettanddonnelly.com
(for Defendants, City of Leominster & Mayor Dean Mazzarella)
CERTIFICATE OF SERVICE
Thereby certify that a copy of the above document has been provided to the Plaintiff and
counsel of record for the Defendants this 25" day of May, 2023 via electronic mail.
/s/ Sarah A. Shipley
Sarah A. Shipley
Document Filed Date
May 25, 2023
Case Filing Date
April 11, 2023
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Date Filed 5/25/2023 10:09 AM Superior Court - Worcester Docket Number 2385CV00388 COMMONWEALTH OF MASSACHUSETTS WORCESTER, ss. SUPERIOR COURT C.A. NO.: 2385-CV-00388 LOUIS M. BROWN, Plaintiff, Vv. CITY OF LEOMINSTER, JOHN DOES 1 THROUGH 10, MAYOR DEAN MAZZARELLA and MASSACHUSETTS INTERLOCAL INSURANCE ASSOCIATION, Defendants. ASSENTED TO MOTION OF THE DEFENDANT, MASSACHUSETTS INTERLOCAL INSURANCE ASSOCIATION [MISNAMED], TO SEVER AND STAY COUNTS I AND Il] OF THE PLAINTIFF’S COMPLAINT NOW COMES the defendant, incorrectly named as Massachusetts Interlocal Insurance Association and more properly named as MIIA Property and Casualty Group, Inc. (“MIIA”), and hereby moves to sever and stay Counts II and III of the plaintiff, Louis Brown’s (“Plaintiff”), Complaint and Jury Claim (Docket Paper No. 2) until the underlying gross negligence claim against the City of Leominster and Mayor Dean Mazzarella in Count I is resolved. This Motion has been assented to by all parties. Additionally, in support of its Motion, MIIA relies upon the attached Memorandum of Law. WHEREFORE, the defendant, MIIA Property and Casualty Group, Inc., incorrectly named as Massachusetts Interlocal Insurance Association, respectfully requests that this Honorable Court grant its Motion to Sever and Stay and sever and stay Counts II and III of the plaintiff, Louis Brown’s, Complaint and Jury Claim. Date Filed 5/25/2023 10:09 AM Superior Court - Worcester Docket Number 2385CV00388 Dated: May 25, 2023 Respectfully submitted, The Defendant, MIIA Property and Casualty Group, Inc., By its attorneys, /s/ Sarah Shipley Arthur E. Maravelis (BBO# 564673) Sarah A. Shipley (BBO# 678753) TANG & MARAVELIS, P.C. 50 Mall Road, Suite 111 Burlington, MA 01803 781-221-1400 amaravelis@tangmaravelis.com sshipley@tangmaravelis.com Assented to: /s/ Louis M. Brown Louis M. Brown Pro Se 16 Green Mountain Avenue Leominster, MA 01453 617-935-4333 louismitchellbrown91@gmail.com (Plaintiff) /s/ Wendy L. Quinn Wendy L. Quinn, Esquire (BBO #653954) Hassett & Donnelly, P.C. 446 Main Street - 12th Floor Worcester, MA 01608 508-791-6287 wquinn@hassettanddonnelly.com (for Defendants, City of Leominster & Mayor Dean Mazzarella) CERTIFICATE OF SERVICE Thereby certify that a copy of the above document has been provided to the Plaintiff and counsel of record for the Defendants this 25" day of May, 2023 via electronic mail. /s/ Sarah A. Shipley Sarah A. Shipley