On December 13, 2022 a
Party Discovery
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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SUPERIOR COURT
BARNSTABLE, SS
JAN 26 2023
COMMONWEALTH OF MASSACHUSETTS
D
Scott w. Niok erson, Cle
BARNSTABLE, ss SUPERIOR COURT rk
C.A. NO. : 2272 CV 00495
JENNIFER DOE,
Plaintiff, MOTION TO QUASH DEPOSITION
Vv. SUBPOENA DUCES TECUM
ESTATE OF ARNOLD F. LETT, SR.,
By its Personal Representatives, Scott Gowen
and Alan Liguori,
Defendants
Arnold F. Lett, Jr. moves for an order to quash the subpoena heretofore
served upon him by the defendant upon the ground that the subpoena is
unreasonable and oppressive in that:
1. Arnold F. Lett, Jr. was not a percipient witness to any allegations in the
complaint made by the plaintiff.
2. Amold. F. Lett, Jr. will not be testifying in this case.
3. Arnold F. Lett, Jr. is a practicing attorney in the Commonwealth. Sometime
after the death of his father, Arnold F. Lett Sr., a family member, Jennifer
Doe, presented him with some legal issues she wanted to discuss. Any
discussions she may have had with Attorney Lett would be privileged.
4. Arnold F. Lett, Jr. is not in possession of any transcripts of recording of
conversations to which either of the Estate’s representatives was a party.
Attached hereto, is the affidavit of Amold F. Lett, Jr., which the undersigned will
rely upon in support of this motion.
Lgl PIAL:
‘Amold F. Lett, Jr. Date: January 5, 2024
33 Whistler Lane
Dennisport, MA 02639
CERTIFICATE OF SERVICE
Thereby certify that a true copy of this motion and accompanying affidavit along
with the Deposition Subpoena Duces Tecum was served upon Scott J. Tucker of
Tucker, Dyer & O’Connell, LLp, 199 Wells Ave., Newton, MA 02459 on January
5, 2024 by first-class mail postage pre-paid.
2 LB ZA.
Arnold F. Lett, Jr.
Document Filed Date
January 26, 2024
Case Filing Date
December 13, 2022
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SUPERIOR COURT BARNSTABLE, SS JAN 26 2023 COMMONWEALTH OF MASSACHUSETTS D Scott w. Niok erson, Cle BARNSTABLE, ss SUPERIOR COURT rk C.A. NO. : 2272 CV 00495 JENNIFER DOE, Plaintiff, MOTION TO QUASH DEPOSITION Vv. SUBPOENA DUCES TECUM ESTATE OF ARNOLD F. LETT, SR., By its Personal Representatives, Scott Gowen and Alan Liguori, Defendants Arnold F. Lett, Jr. moves for an order to quash the subpoena heretofore served upon him by the defendant upon the ground that the subpoena is unreasonable and oppressive in that: 1. Arnold F. Lett, Jr. was not a percipient witness to any allegations in the complaint made by the plaintiff. 2. Amold. F. Lett, Jr. will not be testifying in this case. 3. Arnold F. Lett, Jr. is a practicing attorney in the Commonwealth. Sometime after the death of his father, Arnold F. Lett Sr., a family member, Jennifer Doe, presented him with some legal issues she wanted to discuss. Any discussions she may have had with Attorney Lett would be privileged. 4. Arnold F. Lett, Jr. is not in possession of any transcripts of recording of conversations to which either of the Estate’s representatives was a party. Attached hereto, is the affidavit of Amold F. Lett, Jr., which the undersigned will rely upon in support of this motion. Lgl PIAL: ‘Amold F. Lett, Jr. Date: January 5, 2024 33 Whistler Lane Dennisport, MA 02639 CERTIFICATE OF SERVICE Thereby certify that a true copy of this motion and accompanying affidavit along with the Deposition Subpoena Duces Tecum was served upon Scott J. Tucker of Tucker, Dyer & O’Connell, LLp, 199 Wells Ave., Newton, MA 02459 on January 5, 2024 by first-class mail postage pre-paid. 2 LB ZA. Arnold F. Lett, Jr.