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  • Bureau, Real vs. Essex County Sheriff's Department Kevin Coppinger Tortious Action involving an Incarcerated Party document preview
  • Bureau, Real vs. Essex County Sheriff's Department Kevin Coppinger Tortious Action involving an Incarcerated Party document preview
  • Bureau, Real vs. Essex County Sheriff's Department Kevin Coppinger Tortious Action involving an Incarcerated Party document preview
  • Bureau, Real vs. Essex County Sheriff's Department Kevin Coppinger Tortious Action involving an Incarcerated Party document preview
						
                                

Preview

O r§ COMMONWEALTH OF MASSACHUSETTS e ESSEX, ss. SUPERIOR COURT C.A. No. 2377CV00492A meer peeps, Vv. ou Ss ae KEVIN COPPINGER, SHERIFF AND zm ESSEX COUNTY SHERIFFS’ oo DEPARTMENT, S Bo Defendant. DEFENDANTS, KEVIN COPPINGER, SHERIFF AND ESSEX COUNTY SHERIFF’S Q24 DEPARTMENT’S MOTION TO DISMISS PLAINTIFF, REAL BUREAU’S COMPLAINT PURSUANT TO RULE 12 (b)(6) OF THE MRCP FOR FAILURE TO STATE A CLAIM UPON WHICH RELIEF CAN BE GRANTED Defendants, Kevin Coppinger, Sheriff and Essex County Sheriffs Department, by the accompanying motion and as more fully explained in the attached Memorandum of Law, move for this Honorable Court to dismiss Plaintiff, Real Bureau’s Complaint, pursuant to Rule 12 (b) 2 (6) of the Massachusetts Rules of Civil Procedure for failure to state a claim upon which relief can be granted. Defendants have filed this motion in accordance with Superior Court Administrative Directive No. 92-1 concerning civil actions filed by incarcerated parties KEVIN COPPINGER, SHERIFF AND ESSEX COUNTY SHERIFF’S DEPARTMENT 333 By its Attorneys 3 ANDREA CAMPBELL ATT IEY GENERAL air II, Esq. (BBO# 654369) iy Special Assistant Attorney General Dan V. Bair II, Attorney at Law 15 Foster Street Quincy, MA 02169 Tel: (508) 277-0720 Fax: (617) 770-4091 dbair@danbairlaw.com Date: August 16, 2023 CERTIFICATE OF SERVICE I, Dan V. Bair, II, Special Assistant Attorney General, do hereby certify that I made service of the foregoing document on this 16th Day of August, 2023 via first class mail, postage prepaid to: Real Bureau, Inmate # W116849, MCI Shirley Medium Prison, 1 Harvard Road, P.O. Box 1218, Shirley, MA 01464. — ZLS DanV. Bair, I ~ Special Assistant Attorney General oa cat so mo