Motion-Secondary: Doe, Jennifer vs. Lett, Sr., Arnold F. et al

On December 13, 2022 a Motion-Secondary was filed involving a dispute between Doe, Jennifer, and Gowen, Scott, Lett, Sr., Arnold F., Ligouri, Alan, for Torts in the District Court of Barnstable County.

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|i JAN E42 2024

COMMONWEALTH OF MASSACHUSETTS
Ss

BARNSTABLE, ss. SUPE! (OR COURT™
C.A. NO. 2272CV00495

JENNIFER DOE,
be
Plaintiff, Adored
v.
ESTATE OF ARNOLD F. LETT, SR.,
By its Personal Representatives,
Scott Gowen and Alan Liguori,
Defendant.

MEMORANDUM IN SUPPORT OF DEFENDANT'S
MOTION TO COMPEL
FURTHER ANSWERS TO INTERROGATORIES

Now comes the Defendant, the Estate of Arnold F. Lett, Sr., By its Personal
Representatives, Scott Gowen and Alan Liguori, and submits this Memorandum in
Support of Defendant’s Motion to Compel Further Answers to Interrogatories.

Case background

The Plaintiff has brought this action against the estate of
(“Lett”), alleging he sexually abused her while she was a minor. Lett died in January
2022 and suit was filed in December 2022. Defendant answered the Complaint in
January 2023.

Discovery dispute

The Defendant served Interrogatories and a Request for Production of
Documents on the Plaintiff on February 7, 2023, The Plaintiff served Answers to
Interrogatories and a Response to Request for Production of Documents in June 2023.
The Plaintiff was deposed on November 29, 2023.

As grounds for the Motion, the Defendant submits that the objections are
improper the Plaintiff's Answers to Interrogatories Nos. 2, 3, 18 and 20 or the Answers
are incomplete. The Plaintiff's Answers to Interrogatories are attached hereto as Exhibit
1 in accordance with Superior Court Rule 9C.
ARGUMENT REGARDING ANSWER TO INTERROGATORY NO. 2

Interrogatory No. 2 requests the name, address and telephone number of all persons
with knowledge of the occurrences of sexual abuse and rape alleged in the Complaint
and for each person identified, what information they have.

The Plaintiff's boilerplate objection is unfounded and not advanced in good faith. The
Interrogatory is not “overly broad” and providing such information that is known to
the Plaintiff is not “unduly burdensome.” In fact, the Interrogatory goes to the core of
the Plaintiff's allegations that a now-deceased person committed such acts and the
corroboration of those allegations. The Answer acknowledges that this information is
known to the Plaintiff as she lists seven such persons - but provides a one sentence
“Answer” - “All seven know what, told them about sexually
abusing me.” What she told each of these seven people is not disclosed. The Plaintiff's
Answer fails to include the information each listed person has received from the
Plaintiff, concerning the occurrences of sexual abuse and rape alleged in the Complaint.

ARGUMENT REGARDING ANSWER TO INTERROGATORY NO. 3

Interrogatory No. 3 requests the name, address and telephone number of all persons
with knowledge of the Plaintiff's alleged injuries and damages resulting from the
occurrences of sexual abuse and rape alleged in the Complaint, and for each person
identified, what information they have.

The Plaintiff's boilerplate objection is unfounded and not advanced in good faith. The
Interrogatory is not “overly broad” and providing such information that is known to
the Plaintiff is not “unduly burdensome.” The Interrogatory goes to the core of the
Plaintiff's claim of damages, The Answer acknowledges that this information is known
to the Plaintiff but is not disclosed. Nonetheless; the Plaintiffs Answer fails to include
the information each listed person has concerning the damages allegedly resulting from
the occurrences of sexual abuse and rape alleged in the Complaint.

ARGUMENT REGARDING ANSWER TO INTERROGATORY NO. 18

Interrogatory No. 18 requests in itemized form all expenses incurred or damages the
Plaintiff claims she has suffered as a result of the occurrences of sexual abuse and rape
alleged in the Complaint.
The Answer includes the identical improper boilerplate objection as prior Answers.
The Interrogatory requests in itemized form all expense incurred or damage the
Plaintiff suffered as a result of the alleged tortious acts. The Interrogatory is not “over
broad” and answering it would not be “unduly burdensome.” The Plaintiff has alleged
damages and is required to answer an Interrogatory concerning her expenses and
damages which she seeks to recover. The Plaintiff's post-objection “Answer” is that she
“reserves the right to supplement this [answer to] interrogatory.” The Plaintiff is
required to provide an Answer to this Interrogatory that reflects these itemized
damages as of the today - and the reservation is proper only as to subsequently-
incurred expenses and damages.

ARGUMENT REGARDING ANSWER TO INTERROGATORY NO. 20

The Interrogatory seeks the name and address of each provider who has diagnosed the
Plaintiff with the following conditions, and the date of diagnosis: Post-Traumatic Stress
VU
Disorder; C-PTSD; Severe Social Anxiety; Obsessive Compulsive Disorder; Panic
Attacks; Self-mutilation/ cutting; and Insomnia.

The Plaintiff's Answer is that she “self-diagnosed [herself] through [her] own research.”
However, at her deposition, the Plaintiff testified that she had been treated
approximately 2 years ago by a psychiatrist who saw her approximately 10 times and
who diagnosed her with OCD and ADHD. She discussed the alleged sexual abuse with
the psychiatrist and she “told him that I had childhood sexual abuse.” The Plaintiff
failed to disclose this treatment in her Answers to Interrogatories and did not produce
her records in response to the Request for Production of Documents. A result the
Defendant did not have those records for (Ex. 2) her deposition. Further, at her
deposition she testified that she had seen a mental health provider the day before the
deposition, for two hours, but could not recall her name. (It should be noted that she
asked if she could ask her lawyer the mental health professional’s name and her lawyer
responded, “No. If you don’t know, it’s okay to say I don’t know.”) (Ex. 2) The Plaintiff
acknowledged that she “probably could get access to [her medical records].” However,
her attorney interjected, “Do you have access right now?” (Ex. 2) Itis quite clear the
Plaintiffs Answer was incomplete and she made no effort to obtain the information
necessary, nor it would appear, was she advised by counsel that she was required to do
so.

Conclusion

Plaintiff's Answers to Interrogatories include multiple boilerplate objections that are
patently inapplicable to the Interrogatories in light of the Plaintiff's claims. They were
not interposed in good faith, They demonstrate a failure to.comply with a party's
obligations under the Rules of Civil Procedure and they impaired the Defendant's
ability to conduct a full examination of the Plaintiff at her deposition. Following the
deposition, the Plaintiff failed to take any steps to remedy the harm caused by her non-
3
compliance, even after a Superior Court Rule 9C conference was requested and the
basis for this Motion to Compel was set out.

For the reasons set forth above, and the Plaintiff's refusal to participate in a Superior
Court Rule 9C conference as requested and required, the Defendant submits the Motion
to Compel should be allowed the Plaintiff should be required to sit for a further
deposition and the Defendant be awarded the costs of attempting to comply with
Superior Court Rule 9C and the cost of bringing this motion.

The Defendant,
By its Attorneys,

/s/ Scott J. Tucker
Scott J. Tucker - BBO# 503940
Ann M. Donovan - BBO# 552819
Tucker, Dyer & O’Conneil, LLP
199 Wells Avenue
Newton, MA 02459
SJT - (617) 986-4223
AMD - (617) 986-4205
tucker@tdolaw.com
donovan@tdolaw.com
Dated: December 26, 2023
CERTIFICATE OF SERVICE

I, Scott J. Tucker, hereby certify that on December 26, 2023, Ihave served a copy
of:

MEMORANDUM IN SUPPORT OF DEFENDANT’S
MOTION TO COMPEL
FURTHER ANSWERS TO INTERROGATORIES

by electronic mail only, to the following counsel of record:

Kristen Greenwood, Esquire
Law Office of Kristen Greenwood, PLLC
349 Old Plymouth Rd., First Floor
Sagamore Beach, MA 02562
kristen@attykg.com

Lf Scott J. Tucker
Scott J. Tucker
EXHIBIT 1
COMMONWEALTH OF MASSACHUSETTS
TRIAL COURT

BARNSTABLE, ss. SUPERIOR COURT
C.A, NO. 2272CV00495

JENNIFER DOE,
Plaintiff,

Y
ESTATE OF ARNOLD F, LETT, SR.,
Defendant.

PL, INTIFI FIRST. WERS TO DI NDANT’S INTERROGAT!
[O PLAINTIF F

IS 3G. YNO. I

Please state your full name, date of birth, current residential address, occupation, and the name
and address of your employer.

PLAINTIFE’S ANSW.

Currently Unemployed

NTERROGATORY NO, 2

Please stale the name. address and telephone number of all persons with knowledge of the
occurrences of sexual abuse and rape alleged in your Complaint (the “Occurrences” and for
each person identified, please state what information each has.
.
LAINTIFE'S ANSWER 2:

Plaintit¥ objects to this question to the extent that it seeks answers that are overly broad and
unduly burdensome. Without waiving this objection. Plaintiff states:

Jordan Wheeler, 68 Cassidy Ave.. South Dennis, MA, (508) 762-7252
Brenden Lees. 33 Whistler Ln., South Dennis, MA, (508) 760-6686
Toni Lett, 33 Whistler I.n., South Dennis, MA, (508) 760-6686
Arnold Lett Jr. 33 Whistler Ln., South Dennis, MA, (508) 760-6686
Limma Gowen. 5 Liberty Rd. jedway. MA. (617) 943-6787
Deanna Kurloweez, 50 Swanson Lane Carlisle, MA (508) 626-6341
Scott Gowen, 5 Liberty Rd.. Medway. MA, (617) 943-6787

1
Allseven know what, 1. told them about sexually abusing me.

NTERROGATORY NOU3

Please state the name, address and telephone number of all persons with knowledge of your
alleged injuries and damages resulting from the Occurrences, and for cach person identified.
please state what information each has.

LAINTIFF'S ANSWER 3:

PlaintifT objects to this question to the extent that it secks answers that are overly broad and
unduly burdensome. Without waiving this objection. Plaintiff states:

Jordan Wheeler, 68 Cassidy Ave., South Dennis, MA, (S08) 762-7252
Brenden Lees. 33 Whistler I.n., South Dennis, MA, (508) 760-6686
Toni Lett, 33 Whistler Ln,, South Dennis, MA, (508) 760-6686
Amold Lett Jr.. 33 Whistler Ln., South Dennis, MA, (508) 760-6686
Emma Gowen, 5 Liberty Rd.. Medway, MA, (617) 943-6787
Deanna Kurloweez, 50 Swanson Lane, Carlisle, MA (508) 626-6341
Scott Gowen, 3 Liberty Rd., Medway, MA, (617) 943-6787

Not limited to those seven, Plaintiff reserves the right to update and supplement this
interrogatary.

L RROGATORY NO. 4

If you are enrolled in Medicare or Mass! fealth, please provide:

a. Your Health Insurance Claim Number (LICN); and

b. The date cligibility began.
PLAINTIPE'S A S £ RA

a, Not applicable,

b. Not applicable,

INTERROGATORY NO. 5

Please provide the complete list of your current and past employers, and state as to each:

a. Your employer's name and business address:

2
Your job title and a complete and specific description of your job duties and
obligations;

. Your average weekly income received from your work at that time, specilying
whether you were an hourly or salaried employee. and your rate of pay if hourly;

Your dates of employment: and

Your reason(s) for leaving that employment.

tt TE WE 3:

PlaintifY objects to this question to the extent that it seeks answers that are overly broad and
unduly burdensome. Without waiving this objection. Plaintiff states:

ay
Cookie’s Seafood, 1120 lyannough Rd.. Hyannis, MA, (308) 775-0450
The Knack (same owner as Cookies Seafood), 5 Rte. 6A, Orleans, MA, (774) 316-
4595

Worked at counter taking orders and handing the food and drinks to the people.

c., Worked seasonally at both splitting 20 hours/week muking $12.00 per hour

Worked from March 2016 - October 2017

Lefi the job duc to menial health reasons.

(2)
Upper Crust Pizza, 1782 Massachusetts Ave., Cambridge. MA. (617) 492-1111

Worked al the counter taking orders and handing the food and drinks to the people.

Not applicable

One week in November 2017

Left the job due to mental health reasons.

INTERR ‘ORY NO. 6

Please provide the complete list of your current and past educational institutions attended, and
state as lo each:
‘The institution's name and address:

Your student status at each institution (full-time. part-time):

The dates between which you attended that institution;

Your area of study;

The amount of attempted credits and credits earned; and

Your rcason(s) for incomplete credits or leaving that institution.

PLAID ER

Plaintiff objects to this question to the extent that it secks answers that are overly broad and
unduly burdensome. Without waiving this objection, Plaintiff states:

a)
a. Lighthouse Charter School, 225 Rte. GA, Orleans, MA

b. Full-time

Graduated 2009

Not applicable

Graduated through 8" grade
Not applicable

2)
Sturgis High School, 427 Main St.. Hyannis, MA

/ Full-time

Started September 2009 - did not finish first semester

Not applicable

12 credits

Left for mental health reasons

G)
Dennis- Yarmouth Regional High School. 296 Station Ave., South Yarmouth. MA
Full-time

Started spring semester 2011 and dropped out fall 2012

Not applicable

12 credits

Left for mental health reasons

(4)
Cape Cod Community College, 2240 lyannough Rd., West Barnstable, MA

Part-time

January 2013-2017
a
AA in Liberal Arts

142 credits attempted; 126 credits earned

Not applicable

G)
Suffolk University, 73 Tremont St, Boston, MA

Full-time

Septernber - November 2018

English major

16 credits attermpted; 0 credits earned

Mental health reasons

(6)
Bridgewater State University

Full-time

January 2019 - April 2020

4. PR Communication major
f Left after 2020 semester afier learning that a professor had been charged with rape of
some students.

INTERROGATORY NO. 7

Please state when you carned your GED and describe in complete and specific detail all cfforts
since then to pursue a higher degree, certification or professional licensure.

LAINTIFF'S ANSWER 7:

Tearmed my GED in December 2012.

_ INTERROGATO: i NO, 8

Ifyou have applied for Social Security disability benefits as a result of the Occurrences, please
provide:

a. The date you applicd:

b. Ifand when the claim was denied;

c. ‘The reason(s) the Social Security Administration provided for denying the claim;

Whether and when the claim was appealed:

the result(s) of the uppeal(s);

Whether and when benefits were eventually awarded or amended:

&. The date the Social Security Administration determined your disability began:

The reason(s) the Social Sceurity Administration provided for finding you to be
disabled, including specific injuries, disabilities and/or limitations:

The amount of the benefits awarded, including any past-due benefits; and

The period for which benefits were orate being paid.

LAIN TIFE'S ANSWER 8:

Not applicable - | have not applied for Sovial Security disability benefits.
INTERROGATORY NO,

For cach fact witness, including medical providers, that you intend to call at the tial of this
action, please state as to each:

a. Their name. employer, business address, residential address, and telephone number:

“b, The subject matter on which they are expected to testily; and

«. The substance of their expected testimony,

PLAINTIFE'S ANSWER 9:

No decision has been made yet as to what witnesses will be called. Plaintiff reserves the right to
supplement this interrogatory,

NEERROG. ORY NO. 10

Ifyou received or are receiving any medical treatment or counseling as a result of any physical
harm resulting from the Occurrences, identify the person(s) who provided such treatment or
counseling, setting forth as accurately as possible:

a The name, professional affiliation and address of all persons or institutions which
provided such care:

‘The number of treatments and dates such care was provided:

The nature of such care or treatment;

An itemized account of all expenses incurred for such care, identifying which have been
paid by you and which have not been paid hy you: and

¢. For any expenses that have not been paid by you, identify by name or institution who
paid those expenses.

LAINTIFE’S ANSWER 10:

Not applicable at this time. Plaintiff reserves the right to supplement this interrogatory.

INTERROGATORY NO. Ii
Ifyou received or are receiving any medical treatment or counseling as a result of any emotional
harm resulting from the Occurrences, idemtily the person(s) who provided such treatment or
counseling. setting forth as accurately as possible:

a The name. professional affiliation and address of all persons or institutions which
provided such care;

The number of treatments and dates such care was provided:

G ‘The nature of such care or treatment:

d, An itemized account of all expenses incurred for such care, identifying which have been
paid by you and which have not been paid by you: and

For any expenses that have not been paid by you, identily by name or institution who
paid those expenses.

PLAIN TIVIOS ANSWER 11:

Not applicable at this time. Plaintiff reserves the right to supplement this interrogatory.

INTERROGATORY NO.

If you received or are recciving any medical treatment or counseling as a result of any
psychological harm resulting from the Occurrences, identify the person(s) who provided such
treatment or counseling. setting forth as accurately as possible:

a. The name, prolessional affiliation and address of all persons or institutions which
provided such care;

The number of treatments and dates such care was provided:

The nature of such care or treatment;

d. An itemized account of all expenses incurred for such care, identifying which have becn
paid by ‘ou and which have not been paid by you: and

For any expenses that have not been paid by you, identify by name or institution who
paid those expenses.

RY vE 2

Not applicable at this time. Plaintiff reserves the right to supplement this interrogatory.
TERROGATORY NO. 13

Tf you, your agents. servants or anyone acting on your behalf obtained statements from any
individuals relating to the Oxeurrences or your alleged injurics and damages, please state:

a. The names and addresses of all persons present at the time cach statement was given:

b. The date, time and place that each statement was given; and

c. ‘The person who made each statement, the substance of cach statement, and a full
description of uny documentation of each such statement, including every recording.
photograph, drawing and signed and unsigned document which reflects. represents or
pertains to the same.

LFE’S ANSWER

Plaintiff objects to this question to the extent that it seeks answers that are overly broad and
unduly burdensome. Without waiving this objection, Plaintiff states:

mM
please sce Answer to interrogatory No. 2
Emma Gowen. 5 Liberty Rd., Medway. MA
Scott Ciowen, 5 Liberty Rd.. Medway, MA

b, On or around May 16, 2022

©, T e-mailed imma Gowen and Scott Gowen about the sexual abuse I had suffered from

@)
a, sce Answer to Interrogatory No. 2
Toni Lett, see Interrogatory No. 2
Scott Gowen. Liberty Rd., Medway, MA

b. On or around May 22, 2022. aftemoon, Windward Rd., West Dennis, MA

My mother and | stopped by Scott Gowen’s cottage and discussed
sexual abuse on me.

1 told Scott that | respected him putting my mental health first because this was a
pretty severe thing in my past and I hated having to bring it up to any other family.
Scott told me he understood. He also told me that he and his wife Emma were talking
about it,

Scott asked me how long ago it happened. I said that my carliest memories were from
about S years old. 1 told him that continued sexually harassing me
until | was about 16 or 17, | also told Scott that my
knew and she protected me from him. but that was very abusive
Scott said that he got it and understood,

Scolt also told us that he was glad we came over. He said that it broke his heart to
hear it, and that he was so sorry and started to ery. I also told Scott that | protected
T told him that I never left ‘alone in
the same room with him. Scott said that he appreciated thal,

My mom told Scout that she confronted about this at his house. She
told me didn’t deny it and just told my mom to get out of his house. (I
believe this was around April 2022).

Scott also told me that if he had known this he would not have stayed neutral and that
you can't do that to a child. Scott also sa jd that he noticed that when | was younger I
was very clingy to my mother and that it now kind of clicks. He also said that he now
understands the bigger picture. Scott also said that no one could second judge me and
that he. gets it and understands.

(3) Please see Answer to Interrogatory No.
Deanna Kurlowecz. 50 Swanson Lane. Carlisle, MA (508) 626-6341

a Letter sent to Deanna on or around March 8, 2022. The letter is from me and
describes the sexual abuses that happened to me -
copy of the letter is being sent in response to the Request for Production of
Documents

(4) please see Answer to Interrogatary No, 2
uma Gowen, Scott Gowen. 5 Liberty Rd., Medway, MA

Email sent to Emma Gowen on or around May 16, 2622, which I sent to my mom and
was emailed to Emma. The letter is from me and describes the sexual abuses that
happened to me A copy of the email is being sent
in response to the Request for Production of Documents.
QJ

NTERROGA TORY NO. 1

For each expert witness you expect to call at the trial of this action please state:

a. Their name. business address. residential address, educational and employment
history:

b. The subject matter on which cach such expert witness is expecied to testify; and

10
c. A detailed summary of all of the grounds for each such opinion together with the
substance of all facts upon which opinions are based.

PLAINTIFF'S ANSWER 14:

At this time, a list of experts is unable to be provided. However. Plaintiff reserves the right to
supplement a list in the future.

INTERROGATORY NO. 1

Please describe in complete and specific detail all communications with the Defendant, Ammold
F. Lett. Sr. concerning any of Defendant's conduct that you allege was tortious, including in
your Answer:

a. ‘The method of communication:

b. The date(s), time and location of communication:
The name of the parties to the communication:

The substance of the communication;

Whether the communications were reduced to writing or an audio recording. and. if'so.
the keeper of that record: and

f Whether the communications included photographs and video, and the keeper of that
record.

LAINTIFE'S ANSWER 15:

Please See Answer to Interrogatory No. 2 and Answer tw Interrogatory No. 13.
5
INTERROGATORY NO. 16
Please describe in complete and specific detail all non-privileged communications to which you
were a party concerning any of Defendant’s conduct that you allege was tortious, including in
your Answer:

4a, ‘The method of communication:

b The date(s), time and location of communication:
The name of the parties to the communication;

d ‘rhe substance of the communication:

1
Whether the communications were reduced to writing or an audio recording, and, if so.
the keeper of that record; and

Whether the communications included photographs and video, and the keeper of that
record,

PLAINTIFF'S ANSWER 16:

Please see Plaintiffs Answers to Interrogatory No. 2 and Answers to Interrogatory No. 13.

INTERROGATORY NO. 17

Please describe in complete and specific detail all communications with the Administrators of
Detendani Fatale concerning any of Defendant's conduct that you allege was tortious,
including in your Answer:

a The method of communication:

b. The date(s). time and location of communication:

¢ The name of the parties to the communication;

‘The substance of the communication:

Whether the communications were reduced to writing or an audio recording. and, il’ so.
the keeper of that record; and

Whether the communications included photographs and video, and the keeper of that
record.

PLAL TE SWER 17:

Please see Plaintiff's Answers to Interrogatory No. 2 and Answers to Interrogatory No, 13.

INTE! GATORY NO. 18
\
Please state in itemized form all expense incurred or damage you suffered as a result of the
Occurrences.

PLAINTIFF'S ANSWER 18:

Plaintill objects to this question to the extent that it seeks answers that are overly broad and
unduly burdensome. Plaintiff reserves the right to supplement this interrogatory.

INTERROGATORY NO. 19

12
Please describe in complete and specific detail the substance of your confidence in your mother
and the subsequent confrontation, as alleged in Paragraph 19 of your Complaint, including in
your Answer:

a. ‘The date of each instance;

b. The name, address and phone number of each individual present at the time of each
instance;

¢. The substance of your confidence in your mother: and

d. The substunce of the confrontation between your mother and Defendant.

PL IFF'S ANSW

{eventually trusted my mother enough to tell her about how sexually abused me.
I was so young and traumatized that I kept the abuse to myself for years.

a. J told her about 4 years aga.

b, It was just me and my mom.

The substance was how sexually abused me.
d. See Plaintils Answer to Interrogatory No. 13.

ROG. NO. 2

Please provide the name and address of cach provider who diagnosed you with the following
conditions, und state as to each the date of diagnosis:

a. Post-Traumatic Stress Disorder;

b. “PTSD;

Severe Social Anxiety;

Obsessive Compulsive Disorder;

Panic Attacks:

Seif-mutilation/cunting; and

8 Insomnia.

PLAINTIFICS ANS'

a. | self-diagnosed myself through my own research.
13
\

b Eselt-diagnosed myself through my own research
€ t sel ENosed myself through my own research
d I sel iaynosed myself thraugh my own research.
¢ self ‘diagnosed myself through my own research
-
{ I sel fd nosed myself-through my own research
B | self-diapnosed my self through oiy own research

NTERROGATORY NO. 2

H'you are taking any drugs, including prescription medication, over the counter medication, and
reercational drugs, to treat uny of the conditions you allege are a result of the Oveurrences, please
identify those drugs by name, purpose. dosage. frequency of use. and prescriber (if any).

PLAINTIFF'S ANSWER:

Plaintiff objects to this question to the extent tlt it seeks answors that are overly broad and
unduly burdensome. Without waiving this objection, Plaintiff states:
P smoke marijuana to deal with my conditions an uccasion.

NTERROGATORY NO. 2

Please state how often you stayed at Defendant's home from 2002 through 2010. including dates
of stays, and identify by name, address, and relationship cach individual who was present at
Defendant's home during your slay.

LAINTIFE'S ANSWER 22:
/
Plaintiffobj to this interrogatory as it is overly broad, unduly burdensome and vague.
Without waiving this objection. the Plaintiff states: | never stayed overnight at 1
house Irom 2002 to 2010.

jh of June, 2023 under the pains and penalties of perjury,

As to objections,
Plaintiff.
By her Attorney.

4
igh CNW BBO# 678189
Law ‘Office of Kristen Greenwood, PLLC
349 Old Plymouth Road. First Floor
Sagamore Beach. MA 02562
P: 508-299-3965
F: 508-815-1620
F: Kristen@attykg.com

Dated: June 20, 2023

CERTIFICATE OF SERVICE,

1. Kristen Greenwood, Esq., hereby certify that on June 20. 2023, I have served a copy of:

PLAINTIFF'S ANSWERS TO DEFENDANTS
FIRST SUT OF INTERROGATORIES TO PLAINTIFF

by electronic mail only, to the following counsel of record:

ss. Kristen Greenwood, Exg.
Kristen Greenwood, Lsq.

=
3
EXHIBIT 2
Pages: 1-84
Exhibits: 1-2

COMMONWEALTH OF MASSACHUSETTS

BARNSTABLE,
ss. SUPERIOR COURT
C.A. NO.: 2272CV00495

———

JENNIFER DOE,

Plaintiff,

ESTATE OF ARNOLD F. LETT, SR.,
By its Personal Representatives,
Scott Gowen and Alan Ligouri,

Deféndant.
_~ oe

DEPOSITION OF appearing
at Tucker, Dyer &O'Connell, LLP, 199 Wells Avenue,
Newton, MA 02459, taken pursuant to Notice under the
applicable provisions of the Massachusetts Rules of
Civil Procedure on behalf of the Defendant, before
Linda M. Ordway, Professional Court Reporter and
Notary Public in and for the Commonwealth of
Massachusetts, commencing on Wednesday, November 29,
2023, at 10:06 a.m.

SIMONNE J. ELWOOD - COURT REPORTERS
117 MENDON ROAD
NORTH ATTLEBORO, MA 02760
508-577-1181 FAX 508-761-5677 samjerpr@aol.com
APPEARANCES

FOR THE PLAINTIFF:

Kristen Greenwood, Esquire

LAW OFFICE OF KRISTEN GREENWOOD, PLLC

349 Old Plymouth Road, First Floor

Sagamore Beach, MA 02562

508-299-3965

keisten@attyka.
com

FOR THE DEFENDANT:

Scott J. Tucker, Esquire

nep
LLP»
TUCKER, DYER & O'CONNELL, Fi
199 Wells Avenue

Newton, MA 02459

617-986-4223
29

for OCD?

A No.

Q Have you ever taken any medication for

depression or anxiety?

A No. There was a medication I was on for

migraines very briefly when I was thirteen I think

it is technically an SSRI. It didn't work and also it

was a long time ago.

Q Do you remember when you are were diagnosed

10 with migraines?

il A. I started experiencing them around thirteen

12 and I got a diagnosis, you know, along the way.

13 Probably sometime as a teenager, I am sure, someone

14 wrote down on paper migraines.

15 Q. Was that when Dr. Marz was your only medical

16 provider?

17 A. Yes.

18 Q By the way, do you have any of your medical

19 records from these various providers that you see? Do

20 you have copies of them or access to them through a

21 portal?

22 A. I probably could get access to them.

23 MS. GREENWOOD: Do you have access right

24 now?
30

Right now, no.

Q. You are currently a patient at Brigham and

Women's, correct?

For their neurology, yes.

And when you go to that appointment you get a

notice later that the appointment notes are available,

correct?

A I don't know if my child records are backed

up on that same portal.

10 Q. But your current medical records are

il available through the portal, all you have to do is

12 put your user name and your password in, correct?

13 A Yes.

14 Q And I assume you have had occasion to do that

15 yourself, right?
16 AB Um-um.

17 Q Yes?

18 A Yes.

19 When you say "um-um" I have to ask you to say

20 yes or no, that's all.

21 Yeah, I know. It's a lot all at once.

22 Q. Understood.

23 I am doing my best here.

24 Q I appreciate that.
31

Have you seen any mental health providers --

A. I saw one yesterday.

Q. Okay, who was the mental health provider you

Saw?

Can I.ask my lawyer what her name was?

MS. GREENWOOD: No. If you don't know,

it's okay to say I don't remember.

Q How many times have you seen that mental

health provider?

10 A. I saw her once.

11 And that was yesterday?

12 A. Yesterday, Yep.

13 Q. And where did you see her?

14 A. At the Memory Center in Hyannis. That's my

15 best answer;

16 Q. Is it a male or female?

17 A. Female.

18 Q. Is she part of a practice?

19 A I'm not sure.

20 Q Is the Memory Center located at a hospital or

21 a medical center?

22 A It is located in Hyannis on Cedar Street.

23 Q How long did you spend with her?

24 A Two hours.
32

Do you know what her medical degree is in?

Yes.

Q What is it?
A Her degrees are in social work and she is a

licensed therapist. I am not sure if she has any

other degrees other than that, but those are the ones

I know of.

Q Do you remember her first name?

A I think it was -- no, I don't remember.

10 Q And other than the social worker, licensed

11 therapist you saw yesterday, have you seen any other

mental health provider in the last two years?

13 A I 'saw a psychiatrist. I think it would fall

14 in the two year mark. Dr. David Fish is the one who

15 diagnosed me with OCD and ADHD and helped me find the

16 treatment for that to help manage the symptoms.

17, Q. Where is Dr. Fish located?

18 AB I don't know, I don't see him anymore.

19 Q When you saw him where was he?

20 A. I think in Dedham. It was during the

21 pandemic, I never went there.

22 Q What town did you just say?

23 A I think Dedham.

24 Q Is it on the Cape?
33

No, it's closer to this area

Dedham?

A. I have never been there.

You saw him remote?

Yes.

And how many times did you see him?

A Many times. I saw him once a month for let's

say four months and then checkups every couple of

months. So I probably saw him around maybe like ten

10 times total over the course of a year-ish.

11 Q Did he prescribe any medication?

12 A The Adderall and the Prozac and now my PCP

13 just does it.

14 Q. Did you ever discuss with Dr. Fish any events

15 relating to

16 A Yes, I told him that I had childhood sexual

17 abuse.

18 Q Did he recommend you see anybody who had

19 expertise in that field for mental health issues?

20 A. I saw him for the OCD and ADHD, that was the

21 reason I was there.

22 Q I understand that. Did he tell you --

23 A I don't think.

24 Q -- did he recommend or suggest you see any
34

mental health provider -=

A I don't remember.

Q. -- you have to let me finish the question.

A Sorry.

Q. Did Dr. Fish tell you or suggest to you that

there were any mental health providers whose expertise

was in sexual abuse survivors who you might see?

A. I don't think so.

Q I'm sorry?

10 A. No, he didn't give me a recommendation for

11 that, like I said.

12 Q. Now, we have talk about Dr. Fish, we talked

13 about the neurologist at Brigham and Women's, we have

14 talked about your pediatrician.

15 Are there any other medical care providers

16 that you have seen in the last two years?

17 A A neurologist at Cape Cod Neurology. I saw

18 an ENT to check on my sinuses because I get sinus

19 infections. I went to him one time when I was living

20 in Bridgewater around the pandemic. I also saw an

21 orthopedic surgeon for my Ehlers-Danlos syndrome.

22 Q. I'm sorry?

23 A I saw an orthopedic surgeon, just a

24 consultation, about an injury that I had.

Case Info

Judge

Thomas J. Perrino Track Judge’s New Case

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Document Filed Date

January 11, 2024

Case Filing Date

December 13, 2022

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Motion-Secondary: Doe, Jennifer vs. Lett, Sr., Arnold F. et al

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