Miscellaneous: Life Care Centers Of America, Inc. D/B/A Life Care Center Of Leominster vs. Louise Lammers, By And Through Her Conservator, Rachael Stanton et al

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                                Date Filed 2/8/2024 12:52 PM
Superior Court - Bristol
Docket Number
                                                                                DOCKET NUMBER                           Massachusetts Trial Court
                     CIVIL ACTION COVER SHEET                                                                           Superior Court
                                                                                                                       COUNTY]
         Plaintiff                   Life Care Centers of America, Inc. d/b/a Life Care         Center| nefendant:                Couise Lammers. Harvey Lammers, Chery! Lammers,
                                ——~-of Leominster                                                                                 and Paul Reis
         ADDRESS:               370 West Street, Leominster, Massachusetts 01453                       ADDRESS:             370 West Street, Leominster, Massachusetts 01453
                                                                                                        309 Hillman Street, New Bedford, MA 02740


         Piaintiff Attorney:                                                                            Defendant Attomey:
         ADDRESS:               Thomas J. Cleary, Esq. / Christopher J. Leazott, Esq.                   ADDRESS:
         122 Dean Street, Taunton, MA 02780


                                669296 / 705564                                                         BBO:
                                                       TYPE OF ACTION AND TRACK DESIGNATION (see instructions section on next page)
                      CODE NO.                              TYPE OF ACTION (specify)               TRACK             HAS A JURY CLAIM BEEN MADE?
                AO                                Services                                      F                     (ves         fX] No
         “If "Other" please describe:
                                           Js there a claim under G.L. c. 93A7                                             ts there a class action under Mass. R. Civ. P. 237
                                                  (yes       (1) no                                                           (7 yes           (]No
                                                                  STATEMENT OF DAMAGES REQUIRED BY G.L. ¢. 212, § 34
        ‘The following is a full, itemized and detailed statement of the facts on which the undersigned plaintiff or piaintiffs counsel relies to determine money damages.
        (Note to plaintiff: for this form, do not state double or treble damages; indicate single damages only.)
                                                                                           T CLAN
        A, Documented medical expenses to date
                       4. Total hospital expenses
                       2. Total doctor expenses
                       3. Total chiropractic expenses.
                       4. Total physical therapy expenses
                       5, Total other expenses (describe below)
                          |                                                                                              Subtotal (1-5):                              $0.00
         B. Documented lost wages and compensation to date
         C, Documented property damages to date
         D. Reasonably anticipated future medical and hospital expenses
         E. Reasonably anticipated lost wages
         F. Other documented items of damages (describe below)

         |                                                                                                               TOTAL (AF):                                      $0.00
             G. Briefly describe plaintiffs injury, including the nature and extent of the injury:

         [_                                                                               CONTRACT CLAIMS
               {[] This action includes a claim involving collection of a debt incurred pursuant to a revolving credit agreement. Mass. R. Civ. P. 8.1(@)
                litem #                                                    Detailed Description of Each Claim                                                                 Amount
                 1             Breach of contract, quantum meruit, and claims pursuant to M.G.L, ¢. 109A as well as M.G.L. ¢. 203E                                                $157,440.80



                                                                             7
                                                                                                                                                              Total               $157,440.80



             Signature of Attorney/Self-Represented Plaintiff: X           Lo                                                                    |        [Date:      a       Ray
             RELATED ACTIONS: Please provide the case number, caserifne, and county of any related actions pending in the Superior Court.

                                                                           CERTIFICATION UNDER S.J.C. RULE 1:18(5)
              [hereby certify that | have compl            irements of Rule $ of Supreme Judicial Court Rule 1:18: Uniform Rules on Dispute Resolution, requiring that | inform my clients about
              court-connected dispute resoluti             iid discuss with them the advantages and disadvantages of the various methods of dispute resolution.
        | Signaturea
                   of Attorney: X a                                                                                                                  |_   [Pate:       B=
               so000t: 02/24             4           :                             www.mass.govicourts                                                     Date/Time Printed:02-06-2024 19:01:54