Document for Nikolova, Hristina vs. Trustees Of Boston College

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    Date Filed 12/12/2023 4:16 PM
    Superior Court - Suffolk
    Docket Number 2384CV02425

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                                                   COMMONWEALTH             OF MASSACHUSETTS

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  XS            <   x   SUFFOLK, ss.                                                            SUPERIOR COURT
                                                                                                CIVIL ACTION


Qo S            No                                                                              NO. 2384CV02425 E


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8      SY               HRISTINA NIKOLOVA,
                              Plaintiff,


Sox                     TRUSTEES OF BOSTON COLLEGE,
                              Defendant.

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                             DEFENDANT TRUSTEES OF BOSTON COLLEGE’S MOTION TO EXTEND TIME
                                   TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT

we                                  Defendant Trustees of Boston College (“BC”) hereby moves that the time within which

                        BC may file its Answer and/or other response to the Complaint of Plaintiff Hristina Nikolova

                         (“Plaintiff”) be extended from December 7, 2023, to January 19, 2024. As grounds, BC states

                         that:

                                 1) the Complaint is 71 pages in length, contains 251 paragraphs, and raises allegations
                         over a multi-year period of Plaintiff's former employment at BC;
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                                 2) the Complaint contains 7 counts, some or all of which are potentially subject to
         S&S             dismissal under Rule 12(b)(6);

                                3) undersigned counsel has numerous other deadlines in pending litigation in the months
                         of December and early January and pre-planned vacation during that period;

=                                   4) analysis of the Complaint and preparation of an Answer and potential Rule 12 motion
                         will require substantial additional time;

aS                                  5) the Tracking Order in this matter provides until February 23, 2024 for filing of an
                         answer or service of a Rule 12 motion, until March 25, 2024 for filing of a Rule 12 motion, and
                         until April 23, 2024 for a hearing on a Rule 12 motion;
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                                6) BC is not aware of any undue prejudice to Plaintiff that would result from an extension
=                        of BC’s deadline to Answer or otherwise respond to the Complaint, particularly where the
                         Complaint was filed on October 26, 2023 but not served on BC until November 17, 2023; and
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