Party Discovery: In the Matter of: Mcnabb, Diane

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                                NO         i    ry                                          4
                                    COMMONWEALTH              OF MASSACHUSETTS

          SUFFOLK, SS.                                                         SUPERIOR COURT
                                                                               CIVIL ACTION


LS
                                                                               NO. 2484CV00395




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          DIANE McNABB,

                    Plaintiff


8         Vv.


          TERRENCE McNABB,

                    Defendant


                         JOINT MOTION TO IMPOUND DOCUMENTS RELATED TO
                PLAINTIFF/APPLICANT DIANE MCNABB’S APPLICATION FOR ISSUANCE OF
“>                            SUBPOENAS PURSUANT TO G.L. ¢. 223A, § 11

                   Plaintiff/Applicant Diane McNabb (“Ms. McNabb”) and interested party Clean Restroom

vs    Rentals, Inc. (“CRR”) hereby jointly move to impound any documents filed in this matter that
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      contain the personal and/or confidential information of Ms. McNabb, Terrance McNabb, CRR,

      and Scott K. LeMay (collectively, the “Parties”), as the Parties may designate, including, but not

&     limited to, Plaintiff/A pplicant Diane McNabb’s Response to Objection of Clean Restroom

      Rentals, Inc. and Scott K. LeMay to Application for Issuance of Subpoenas Pursuant to G.L. c.

‘Ss   233A, § II (the “Response”), pursuant to the Uniform Rules on Impoundment Procedure and

      Superior Court Rule 18.

                   Proposed findings and proposed order are filed herewith as Exhibit A.

      I            The Materials Sought to Be Impounded

                   The materials sought to be impounded are the Response and any other documents that

      may be filed in this matter that contain the personal and/or confidential information of the