Preview
Date Filed 1/23/2024 3:09 PM
Superior Court - Middlesex
Docket Number
COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, SS. SUPERIOR COURT DEPT.
IN RE:
CIVIL ACTION NO.:
AYU8I Cuda!’ Y
APPLICATION OF SOPHIA SCAVULLO,
LYNETTE SCAVULLO,
and MICHAEL SCAVULLO,
FOR AN ORDER PURSUANT TO
M.G.L. CH. 223A, § 11 MG
01/23/2024 RECEIVED
APPLICATION FOR ORDER FOR ISSUANCE OF SUBPOENA
INSIDE COMMONWEALTH FOR PROCEEEDING IN TRIBUNAL
OUTSIDE COMMONWEALTH PURSUANT TO M.. CH. 223A, § 11
Sophia Scavullo, Lynette Scavullo, and Michael Scavullo (hereafter “Plaintiffs”) hereby
apply to this Court pursuant to the provisions of M.G.L Ch. 223A, § 11 for an Order allowing the
service of a subpoena upon the following:
Candela Corporation
Legal Department
251 Locke Drive
Marlborough, MA 01752-5569
Plaintiffs hereby apply for an order directing Candela Corporation to produce documents and
appear for deposition and give testimony for use in proceedings now pending in the Philadelphia
County Court of Common Pleas, entitled Sophia Scavullo, Lynette Scavullo, and Michael
Scavullo v. The Children’s Hospital of Philadelphia and David W. Low, M.D., bearing Docket
No. 221201506 (the “Pennsylvania Action”). The documents and testimony sought are relevant,
material, and necessary to the issues involved in the Pennsylvania Action.
As grounds for this application, Plaintiffs state as follows:
1 Defendants David W. Low and the Children’s Hospital of Pennsylvania utilized
a Candela Corporation product in the treatment of Plaintiff Sophia Scavullo, which is now the
Date Filed 1/23/2024 3:09 PM
Superior Court - Middlesex
Docket Number
subject of Ms. Scavullo’s medical malpractice complaint. The documents requested from Candela
contain information relating to the product’s function, maintenance, and compliance; information
pertaining to its use in the treatment of Scavullo and other patients affected by possible defaults;
communications between Candela Corporation and Defendants.
2. Plaintiffs propose that this honorable Court order Candela Corporation to appear
for deposition and produce relevant documents by 10:00 AM on February 22, 2024, at the offices
of Tymann, Davis & Duffy LLP, One Boston Place, Suite 2600, Boston, MA 02108.
3 In support of this application, the undersigned states that Plaintiffs have obtained
a Commission from the Court of Common Pleas of Pennsylvania, County of Philadelphia (the
“Pennsylvania Order”). A copy of the Philadelphia Order is attached hereto as Exhibit A.
4. The documents to be subpoenaed and the topics for deposition are also included
in the Pennsylvania Order.
5 A copy of the proposed subpoena is attached as Exhibit B.
6 For the Court’s convenience, a copy of a Proposed Order is attached hereto as
Exhibit C.
WHEREFORE, the undersigned applicant respectfully requests that this Court:
1. Issue an Order authorizing the undersigned (a) to issue a subpoena to Candela
Corporation in accordance with the procedure of Mass. R. Civ. P. 30(b)(6) and
45, to compel the deposition and production of documents as specified in the
Pennsylvania Order, and (b) to have said subpoena served on Candela
Corporation.
Authorize any Notary Public of the Commonwealth of Massachusetts to issue
the subpoena.
3. Take any other action it deems appropriate.
Date Filed 1/23/2024 3:09 PM
Superior Court - Middlesex
Docket Number
RESPECTFULLY SUBMITTED,
Sophia Scavullo, Lynette Scavullo,
and Michael Scavullo,
By their attorneys,
Chan Davee
Ethan Z. Davis (BBO #668973)
edavis@tddlegal.com
TYMANN, DAVIS & DUFFY LLP
One Boston Place, Suite 2600
Boston, MA 02108
(617) 933-9490
Dated: January 23, 2024
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‘Superior Court - Middlesex
Docket Number
EXHIBIT A
Date Filed 1/23/2024 3:09 PM
Superior Court - Middlesex
Docket Number
6B
SOPHIA-SCA\
LYNE:
SCAVOLLO GOURTOF: [ON PLEAS
+ PHILADEL: COUNTY, PA.
NO. 2261506
THE CHILDREN’S HOSPITAL OF
JURY TRIAL DEMANDED
DAVID W, TOW, MB
Detéidants,
AND NOW, this_1aay
d ss ingots ‘cotisideration of Blatt
Petition for Gitotstate. Catrinission, 0% toy ORDERED thet Plaintifis’ Petition.is
GRANTED,
Seis Se
is hereby issued in the'litigation.to the Court: andior-appropriate authority in.the.
State of Massachuseity td. seve: & Subpoena ar-2, Subpoena, for Décumients Oiily: ayon Candela,
Comration 530 Boston Post Road, ‘Wayland,
and: MA. ‘1778-18
a
POCKETED
DEC 202023
vi
Z
K, CALDWELL
S
JUDICIAL RECORD
“Seoreenenmcicnieon)
HMA "cosh mba te: ‘F
s1D: ve
“43 N3GAO
Date Filed 1/23/2024 3:09 PM
Superior Court - Middlesex
Docket Number
EXHIBIT B
Date Filed 1/23/2024 3:09 PM
Superior Court - Middlesex
Docket Number
COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, SS. SUPERIOR COURT DEPT.
CIVIL ACTION NO.:
IN RE:
APPLICATION OF SOPHIA SCAVULLO,
LYNETTE SCAVULLO,
and MICHAEL SCAVULLO
FOR AN ORDER PURSUANT TO
M.G.L. CH. 223A, § 11
SUBPOENA DUCES TECUM
To. Candela Corporation
Legal Department
251 Locke Drive
Marlborough, MA 01752-5569
Pursuant to Mass. R. Civ. P. Rules 30(b)(6) and 45, and this Court’s Order dated January
__, 2024, YOU ARE HEREBY COMMANDED, in the name of the Commonwealth of
Massachusetts, to produce the documents identified Exhibit A, attached hereto, and to designate
a witness to appear for deposition at the office of TYMANN, DAVIS & DUFFY LLP, 45
Bromfield Street, Sixth Floor, Boston, MA 02108, on February 22, 2024, at 10:00 a.m., and from
day to day thereafter, until the deposition is completed. You are to bring with you the following:
HEREOF FAIL NOT, as your failure to appear as required will subject you to such pains
and penalties as the law provides.
Date Filed 1/23/2024 3:09 PM
Superior Court - Middlesex
Docket Number
Dated: January __, 2024
Ethan Z. Davis, BBO #668973
TYMANN, DAVIS & DUFFY LLP Notary Public
One Boston Place, Suite 2600 My Commission expires:
Boston, MA. 02108
(617) 933-9490
edavis@tddleglal.com
Date Filed 1/23/2024 3:09 PM
Superior Court
- Middlesex
Docket Number
EXHIBIT A
DEFINITIONS AND INSTRUCTIONS
1. The definitions set forth in Superior Court Rule 30A apply and are incorporated by
reference herein, including, but not limited to, the definitions of: “communication,” “document,”
“dentify” (with respect to documents and persons), “person,” and “concerning.” As used herein,
“relating to” and “pertaining to” (as well as any derivative forms thereof) have the same meaning
as the uniform definition of the term “concerning” as set forth in Superior Court Rule 30A.
2. “Document” means all forms of documents and electronically stored information
(“ESI”) — including writings, emails, correspondence, memoranda, notices, drawings, graphs,
charts, photographs, audio recordings, images, and other data or data compilations — stored in
any medium from which information can be obtained either directly or, if necessary, after
translation into a usable form.
3. As used herein, “relating to” and “pertaining to” have the same meaning as the
niform definition of the term “concerning” as set forth in Superior Court Rule 30A.
4. “And” as well as “or” shall be construed either conjunctively or disjunctively, the
singular as well as the plural shall be construed as either singular or plural, and the feminine as
well as the masculine gender shall be construed as either feminine or masculine as necessary to
bring within the scope of these document requests all subjects which might otherwise be outside
their scope.
5. The term “person” as used herein shall mean any natural person and/or any
corporation, company, partnership, joint venture, association, or other entity.
6. YOU”, “YOUR”, or “YOURS” means Candela Corporation and its attorneys,
employees, representatives, or anyone else acting on behalf of the company.
7. “WE” or “the SUBPOENAING PARTY” means Plaintiffs Sophia Scavullo,
Lynette Scavullo, and Michael Scavullo, or their counsel or other representatives.
8 “ACTION” means the case Sophia Scavullo, Lynette Scavullo, and Michael
Scavullo v. the Children’s Hospital of Pennsylvania and David W. Low, M.D., Civil Action No.
22120156 now pending in the Court of Common Pleas, Philadelphia County, PA.
9. “CHOP” means Defendant Children’s Hospital of Pennsylvania.
10. The “UNIT” means the Candela VBeam Prima Laser System (Model Number
9914-00-9080) in the operating room at the Children’s Hospital of Pennsylvania, purchase date
8/8/2019.
11. These requests require supplemental responses to the fullest extent required by Rule
26 of the Massachusetts Rules of Civil Procedure.
12. If any requested document is unavailable because it has been lost, discarded, or
destroyed, please identify such document, and state the circumstances in which it was lost,
Date Filed 1/23/2024 3:09 PM
Superior Court - Middlesex.
Docket Number
discarded or destroyed, and identify each person having knowledge of the circumstances in which
it was lost, discarded, or destroyed. For any document with an unknown location, identify all
persons that might possess or know the location of that document.
13. If there are no documents in existence that are requested in a particular paragraph
of the Subpoena, Candela’s response must include a statement to that effect.
14. All documents produced for inspection shall be produced as they are kept in the
usual course of business or shall be organized and labeled to correspond with the paragraphs of
the Document Requests.
DOCUMENTS REQUESTED
1. Any and all documents, emails, correspondence, communications and/or things of
any kind relating to Sophia Scavullo.
2. Any and all documents, emails correspondence, communications, notifications,
and/or things of any kind with respect to complaints, inquiries, repair requests, calibration requests,
maintenance requests and/or incident/injury/adverse/reportable event reports from CHOP and/or
its employees and/or agents regarding the Unit.
3.Maintenance and service logs pertaining to the Unit from August 8, 2019 to August
8, 2021, to include but not limited to: date of service, nature of service (e.g. preventative
maintenance, calibration, repair); name and credentials of technician or engineer who performed
the service; and a description of the work performed on the Unit.
4, Calibration records pertaining to the Unit from August 8, 2019 to August 8, 2021,
to include but not limited to: the date of calibration, the calibration standards used; calibration
certificates; and the results of the calibration of the Unit.
5. Repair records pertaining to the Unit from August 8, 2019 to August 8, 2021, to
include but not limited to: date of repair description of the issue; name and credentials of technician
or engineer who performed the service; description of the repair; and results of post-repair testing
to verify proper functionality.
6. Preventative maintenance records pertaining to the Unit from August 8, 2019 to
August 8, 2021, to include but not limited to: cleaning, inspections, adjustments and other routine
tasks.
7. Training records pertaining to the Unit from August 8, 2019 to August 8, 2021, to
include but not limited to: training dates; the topics covered; and the names of the individuals who
provided and received the training, to include but not limited to: documentation relative to the
October 24, 2019 in-person training conducted at CHOP.
8. Software and Firmware updates pertaining to the Unit from August 8, 2019 to
August 8, 2021, to include but not limited to: when and why the updates were applied; what
changes were made; and who performed the updates.
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9. Compliance documentation pertaining to the Unit from August 8, 2019 to August
8, 2021, to include but not limited to: records of compliance assessments and any corrective actions
taken.
10. Audit Trails pertaining to the Unit from December 1, 2020 to December 31, 2020.
11. Medical Device Report (MDR) Supplemental MDR and/or MDR event file(s)
pertaining to the Unit from August 8, 2019 to date, to include but not limited to: records of
investigations; actions or evaluations taken to address the reportable event(s); and reports/adverse
event reports (FDA 3500A) submitted to the FDA or other federal or state regulatory agency.
12. MDR Report Number: 1218402-2021-00024 and any all supplementals.
13, All Global Patient Impact Communications Forms, MDR’s, or reports of serious
injury submitted by CHOP and/or its employees and/or agents from August 8, 2019 to August 8,
2021, to include but not limited to: the 3/15/21 and 3/21/21 Forms.
14. Recall information pertaining to the Unit from August 8, 2019 to August 8, 2021.
Date Filed 1/23/2024 3:09 PM.
‘Superior Court - Middlesex
Docket Number
EXHIBIT C
Preview
Date Filed 1/23/2024 3:09 PM Superior Court - Middlesex Docket Number COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, SS. SUPERIOR COURT DEPT. IN RE: CIVIL ACTION NO.: AYU8I Cuda!’ Y APPLICATION OF SOPHIA SCAVULLO, LYNETTE SCAVULLO, and MICHAEL SCAVULLO, FOR AN ORDER PURSUANT TO M.G.L. CH. 223A, § 11 MG 01/23/2024 RECEIVED APPLICATION FOR ORDER FOR ISSUANCE OF SUBPOENA INSIDE COMMONWEALTH FOR PROCEEEDING IN TRIBUNAL OUTSIDE COMMONWEALTH PURSUANT TO M.. CH. 223A, § 11 Sophia Scavullo, Lynette Scavullo, and Michael Scavullo (hereafter “Plaintiffs”) hereby apply to this Court pursuant to the provisions of M.G.L Ch. 223A, § 11 for an Order allowing the service of a subpoena upon the following: Candela Corporation Legal Department 251 Locke Drive Marlborough, MA 01752-5569 Plaintiffs hereby apply for an order directing Candela Corporation to produce documents and appear for deposition and give testimony for use in proceedings now pending in the Philadelphia County Court of Common Pleas, entitled Sophia Scavullo, Lynette Scavullo, and Michael Scavullo v. The Children’s Hospital of Philadelphia and David W. Low, M.D., bearing Docket No. 221201506 (the “Pennsylvania Action”). The documents and testimony sought are relevant, material, and necessary to the issues involved in the Pennsylvania Action. As grounds for this application, Plaintiffs state as follows: 1 Defendants David W. Low and the Children’s Hospital of Pennsylvania utilized a Candela Corporation product in the treatment of Plaintiff Sophia Scavullo, which is now the Date Filed 1/23/2024 3:09 PM Superior Court - Middlesex Docket Number subject of Ms. Scavullo’s medical malpractice complaint. The documents requested from Candela contain information relating to the product’s function, maintenance, and compliance; information pertaining to its use in the treatment of Scavullo and other patients affected by possible defaults; communications between Candela Corporation and Defendants. 2. Plaintiffs propose that this honorable Court order Candela Corporation to appear for deposition and produce relevant documents by 10:00 AM on February 22, 2024, at the offices of Tymann, Davis & Duffy LLP, One Boston Place, Suite 2600, Boston, MA 02108. 3 In support of this application, the undersigned states that Plaintiffs have obtained a Commission from the Court of Common Pleas of Pennsylvania, County of Philadelphia (the “Pennsylvania Order”). A copy of the Philadelphia Order is attached hereto as Exhibit A. 4. The documents to be subpoenaed and the topics for deposition are also included in the Pennsylvania Order. 5 A copy of the proposed subpoena is attached as Exhibit B. 6 For the Court’s convenience, a copy of a Proposed Order is attached hereto as Exhibit C. WHEREFORE, the undersigned applicant respectfully requests that this Court: 1. Issue an Order authorizing the undersigned (a) to issue a subpoena to Candela Corporation in accordance with the procedure of Mass. R. Civ. P. 30(b)(6) and 45, to compel the deposition and production of documents as specified in the Pennsylvania Order, and (b) to have said subpoena served on Candela Corporation. Authorize any Notary Public of the Commonwealth of Massachusetts to issue the subpoena. 3. Take any other action it deems appropriate. Date Filed 1/23/2024 3:09 PM Superior Court - Middlesex Docket Number RESPECTFULLY SUBMITTED, Sophia Scavullo, Lynette Scavullo, and Michael Scavullo, By their attorneys, Chan Davee Ethan Z. Davis (BBO #668973) edavis@tddlegal.com TYMANN, DAVIS & DUFFY LLP One Boston Place, Suite 2600 Boston, MA 02108 (617) 933-9490 Dated: January 23, 2024 Date Filed 1/23/2024 3:09 PM ‘Superior Court - Middlesex Docket Number EXHIBIT A Date Filed 1/23/2024 3:09 PM Superior Court - Middlesex Docket Number 6B SOPHIA-SCA\ LYNE: SCAVOLLO GOURTOF: [ON PLEAS + PHILADEL: COUNTY, PA. NO. 2261506 THE CHILDREN’S HOSPITAL OF JURY TRIAL DEMANDED DAVID W, TOW, MB Detéidants, AND NOW, this_1aay d ss ingots ‘cotisideration of Blatt Petition for Gitotstate. Catrinission, 0% toy ORDERED thet Plaintifis’ Petition.is GRANTED, Seis Se is hereby issued in the'litigation.to the Court: andior-appropriate authority in.the. State of Massachuseity td. seve: & Subpoena ar-2, Subpoena, for Décumients Oiily: ayon Candela, Comration 530 Boston Post Road, ‘Wayland, and: MA. ‘1778-18 a POCKETED DEC 202023 vi Z K, CALDWELL S JUDICIAL RECORD “Seoreenenmcicnieon) HMA "cosh mba te: ‘F s1D: ve “43 N3GAO Date Filed 1/23/2024 3:09 PM Superior Court - Middlesex Docket Number EXHIBIT B Date Filed 1/23/2024 3:09 PM Superior Court - Middlesex Docket Number COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, SS. SUPERIOR COURT DEPT. CIVIL ACTION NO.: IN RE: APPLICATION OF SOPHIA SCAVULLO, LYNETTE SCAVULLO, and MICHAEL SCAVULLO FOR AN ORDER PURSUANT TO M.G.L. CH. 223A, § 11 SUBPOENA DUCES TECUM To. Candela Corporation Legal Department 251 Locke Drive Marlborough, MA 01752-5569 Pursuant to Mass. R. Civ. P. Rules 30(b)(6) and 45, and this Court’s Order dated January __, 2024, YOU ARE HEREBY COMMANDED, in the name of the Commonwealth of Massachusetts, to produce the documents identified Exhibit A, attached hereto, and to designate a witness to appear for deposition at the office of TYMANN, DAVIS & DUFFY LLP, 45 Bromfield Street, Sixth Floor, Boston, MA 02108, on February 22, 2024, at 10:00 a.m., and from day to day thereafter, until the deposition is completed. You are to bring with you the following: HEREOF FAIL NOT, as your failure to appear as required will subject you to such pains and penalties as the law provides. Date Filed 1/23/2024 3:09 PM Superior Court - Middlesex Docket Number Dated: January __, 2024 Ethan Z. Davis, BBO #668973 TYMANN, DAVIS & DUFFY LLP Notary Public One Boston Place, Suite 2600 My Commission expires: Boston, MA. 02108 (617) 933-9490 edavis@tddleglal.com Date Filed 1/23/2024 3:09 PM Superior Court - Middlesex Docket Number EXHIBIT A DEFINITIONS AND INSTRUCTIONS 1. The definitions set forth in Superior Court Rule 30A apply and are incorporated by reference herein, including, but not limited to, the definitions of: “communication,” “document,” “dentify” (with respect to documents and persons), “person,” and “concerning.” As used herein, “relating to” and “pertaining to” (as well as any derivative forms thereof) have the same meaning as the uniform definition of the term “concerning” as set forth in Superior Court Rule 30A. 2. “Document” means all forms of documents and electronically stored information (“ESI”) — including writings, emails, correspondence, memoranda, notices, drawings, graphs, charts, photographs, audio recordings, images, and other data or data compilations — stored in any medium from which information can be obtained either directly or, if necessary, after translation into a usable form. 3. As used herein, “relating to” and “pertaining to” have the same meaning as the niform definition of the term “concerning” as set forth in Superior Court Rule 30A. 4. “And” as well as “or” shall be construed either conjunctively or disjunctively, the singular as well as the plural shall be construed as either singular or plural, and the feminine as well as the masculine gender shall be construed as either feminine or masculine as necessary to bring within the scope of these document requests all subjects which might otherwise be outside their scope. 5. The term “person” as used herein shall mean any natural person and/or any corporation, company, partnership, joint venture, association, or other entity. 6. YOU”, “YOUR”, or “YOURS” means Candela Corporation and its attorneys, employees, representatives, or anyone else acting on behalf of the company. 7. “WE” or “the SUBPOENAING PARTY” means Plaintiffs Sophia Scavullo, Lynette Scavullo, and Michael Scavullo, or their counsel or other representatives. 8 “ACTION” means the case Sophia Scavullo, Lynette Scavullo, and Michael Scavullo v. the Children’s Hospital of Pennsylvania and David W. Low, M.D., Civil Action No. 22120156 now pending in the Court of Common Pleas, Philadelphia County, PA. 9. “CHOP” means Defendant Children’s Hospital of Pennsylvania. 10. The “UNIT” means the Candela VBeam Prima Laser System (Model Number 9914-00-9080) in the operating room at the Children’s Hospital of Pennsylvania, purchase date 8/8/2019. 11. These requests require supplemental responses to the fullest extent required by Rule 26 of the Massachusetts Rules of Civil Procedure. 12. If any requested document is unavailable because it has been lost, discarded, or destroyed, please identify such document, and state the circumstances in which it was lost, Date Filed 1/23/2024 3:09 PM Superior Court - Middlesex. Docket Number discarded or destroyed, and identify each person having knowledge of the circumstances in which it was lost, discarded, or destroyed. For any document with an unknown location, identify all persons that might possess or know the location of that document. 13. If there are no documents in existence that are requested in a particular paragraph of the Subpoena, Candela’s response must include a statement to that effect. 14. All documents produced for inspection shall be produced as they are kept in the usual course of business or shall be organized and labeled to correspond with the paragraphs of the Document Requests. DOCUMENTS REQUESTED 1. Any and all documents, emails, correspondence, communications and/or things of any kind relating to Sophia Scavullo. 2. Any and all documents, emails correspondence, communications, notifications, and/or things of any kind with respect to complaints, inquiries, repair requests, calibration requests, maintenance requests and/or incident/injury/adverse/reportable event reports from CHOP and/or its employees and/or agents regarding the Unit. 3.Maintenance and service logs pertaining to the Unit from August 8, 2019 to August 8, 2021, to include but not limited to: date of service, nature of service (e.g. preventative maintenance, calibration, repair); name and credentials of technician or engineer who performed the service; and a description of the work performed on the Unit. 4, Calibration records pertaining to the Unit from August 8, 2019 to August 8, 2021, to include but not limited to: the date of calibration, the calibration standards used; calibration certificates; and the results of the calibration of the Unit. 5. Repair records pertaining to the Unit from August 8, 2019 to August 8, 2021, to include but not limited to: date of repair description of the issue; name and credentials of technician or engineer who performed the service; description of the repair; and results of post-repair testing to verify proper functionality. 6. Preventative maintenance records pertaining to the Unit from August 8, 2019 to August 8, 2021, to include but not limited to: cleaning, inspections, adjustments and other routine tasks. 7. Training records pertaining to the Unit from August 8, 2019 to August 8, 2021, to include but not limited to: training dates; the topics covered; and the names of the individuals who provided and received the training, to include but not limited to: documentation relative to the October 24, 2019 in-person training conducted at CHOP. 8. Software and Firmware updates pertaining to the Unit from August 8, 2019 to August 8, 2021, to include but not limited to: when and why the updates were applied; what changes were made; and who performed the updates. Date Filed 1/23/2024 3:09 PM ‘Superior Court - Middlesex Docket Number 9. Compliance documentation pertaining to the Unit from August 8, 2019 to August 8, 2021, to include but not limited to: records of compliance assessments and any corrective actions taken. 10. Audit Trails pertaining to the Unit from December 1, 2020 to December 31, 2020. 11. Medical Device Report (MDR) Supplemental MDR and/or MDR event file(s) pertaining to the Unit from August 8, 2019 to date, to include but not limited to: records of investigations; actions or evaluations taken to address the reportable event(s); and reports/adverse event reports (FDA 3500A) submitted to the FDA or other federal or state regulatory agency. 12. MDR Report Number: 1218402-2021-00024 and any all supplementals. 13, All Global Patient Impact Communications Forms, MDR’s, or reports of serious injury submitted by CHOP and/or its employees and/or agents from August 8, 2019 to August 8, 2021, to include but not limited to: the 3/15/21 and 3/21/21 Forms. 14. Recall information pertaining to the Unit from August 8, 2019 to August 8, 2021. Date Filed 1/23/2024 3:09 PM. ‘Superior Court - Middlesex Docket Number EXHIBIT C