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Commontneatth of Hlassachusetts
THE TRIAL COURT
PROBATE AND FAMILY COURT DEPARTMENT
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PLYMOUTH DIVISION Plymouth, ss robate CourDOCKET #P123P1323
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fe #PL23P1324
he in Motions hereby-atteweek
In the interests of:
s
Angelina E. Maharajh
Nathaniel A. Maharajh of Probate Court
SAN
RESPONDENT'S MOTION TO COMPEL ANSWERS TO RESPONSES TO Vien
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BIOLOGICAL MOTHER’S REQUEST FOR PRODUCTION OF DOCUMENTS OF y
PETITIONER(S) PURSUANT TO MASS. R. DOM. REL. P. 34
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SUos
NOW COMES Respondent, Nicole Ramhit, (hereinafter “Mother”) in the above-captioned matter
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and respectfully moves this Honorable Court, pursuant to Mass. R. Dom. Rel. P. 37 (d), to. compel
Petitioners, Katherine Gentile and Mohini Maharajh, to forthwith provide Mother
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with 0 .
supplemental responses to Request for Production of Documents of’ Petitioner(s) Pursuant gl
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to Mass. na
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: d oe
R. Dom. Rel. P. 34. Respondent further moves this Honorable Court, pursuant to Mass.
R. Dom.
Rel. P. 37 (d), to order the Petitioners to pay the Respondent’s reasonable expenses,
including
attorney’s fees, incurred in the preparation and presentation of this Motion to Compel. In
support ~
of the within Motion, the Respondent states the following:
1. The underlying petition for Grandparent(s) Visitation was filed on or about June 6, 2023.
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2. On or about July 14, 2023, Counsel for Respondent served upon Petitioners; Biologica X
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Mother’s Request for Production of Documents of Petitioner, Katherine Gentile,
to Mass. R. Dom. Rel. P. 34. and Biological Mother’s Request for Producti
Pursuant AS
3
on ‘of
Documents of Petitioner, Mohini Maharajh, Pursuant to Mass. R. Dom. Rel. P. 34,
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[Exhibit
Al. :
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On or about August 17, 2023, Counsel for Respondent sought a 26(g)
conference in ton x
of the Petitioners’ failure to produce any documents from the Mother’s
Request for : 2
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Production of Documents served upon Ms. Gentile and Ms. Mohini on o!
t about July 14, J “d
2023. [Exhibit B}. i
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OCT 3 0 2023
PROBATE 4 FAMILY COURT JU§
PLYMOUTH DIVISION
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4. Following the Respondent's request for a 26(g) conference, no response was received by
August 23, 2023, which was set forth in the August 17, 2023, 26(g) request. Furthermore,
no correspondence regarding the outstanding documents was received at all.
WHEREFORE, Respondent requests that this Honorable Court enter the following order:
1, That Petitioners shall serve their Supplemental Responses to Respondent’s Request for
Production of Documents dated July 14, 2023, within seven (7) days of the date of this
Order;
Award Respondent her reasonable attorney fees and costs incurred in obtaining the within
order as proscribed pursuant to Rule 37(a)(4) of the Massachusetts Rules of Domestic
Relations Procedure; and
The Petitioners shall be prohibited from conducting any further discovery and be
precluded from introducing any exhibit that they do not provide to the Respondent in
discovery until they produce complete discovery responses.
Dated: septenve, 2023 Respectful] bmitted.
Nic e R:
By Attprney,\
i shol: . Halks, Esquire BBO #688768
ilynn M. Palaima, Esquire BBO #711501
THE HALKS FIRM
233 Needham Street, Suite 540
Newton, MA 02464
Telephone: 617-658-7070
n-halks@halkslaw.com
k.palaima@halkslaw.com
RULE 26(G) CERTIFICATION
I, Nicholas A. Halks, Esquire, Counsel of Record for the Respondent, certify that my office sent
correspondence to Petitioners’ counsel on August 17, 2023, in an attempt to procure outstanding
discovery from the Petitioners, as set forth in the within Motion to Compel. Said request was
ignored and no discovery conference was held.
Dated: september 2, 2023 f
Nichy AM Halks, Esq.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true copy of the within Respondent’s Motion to Compel
was served upon Petitioners to Jack P. Milgrim, Attomey for Petitioners, of Law Offices of Jack
Milgrim, 21 Mayor Thomas J. McGrath Highway, Suite 203, Quincy, MA 02169 and to Michael
Nashawaty, Esq., Attorney for Father, of Nashawaty & Rand, 654
MA 02184, via first class mail postage prepaid and el nic Wail.
Dated: Septemb %
er 2023
ry A. Ha, Esq.
NOTICE OF HEARING ON MOTION
To: Jack P. Milgrim, Esq. and Michael Nashawaty, Esq.
iS
Please take notice that the undersigned will present for hearing the within Respondent’s Motion
to Compel before the Plymouth Division of the Probi ate ly Court holden in Brockton on
September 18, 2023 at 9:00am or as soon thereafter as co
Dated: September & 2023 ,
Nictblad A HB, Esquire
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Commonwealth of Filassathusetts
THE TRIAL COURT
PROBATE AND FAMILY COURT DEPARTMENT
PLYMOUTH DIVISION DOCKET #PL23P1323
#PL23P1324
In the interests of:
Angelina E. Maharajh
Nathaniel A. Maharajh
AFFIDAVIT OF COUNSEL IN SUPPORT OF ATTORNEY’S FEES
I, Nicholas A. Halks, Esquire, Counsel for the Respondent, do hereby state that the
following affidavit is an accurate representation of the fees for services and costs incurred by the
Respondent as a result of the representation of this office, to the best of my knowledge and belief
and represent my usual and customary hourly rate of $500.00 per hour, the associate rate of $300.00
per hour, and the paralegal rate of $150.00 per hour.
Activity or Fee Name Hours Fees Total
26(g) Letter sent to Opposing Counsel 0.20 hours $300.00 $60.00
Draft Motion to Compel 0.80 hours $150.00 $120.00
Draft Affidavit for Attorney’s Fees 0.40 Hours $150.00 $60.00
Draft Proposed Order on Motion to Compel 0.20 hours $150.00 $30.00
Anticipated Travel Time to and From Court 2.00 hours $500.00 $1000.00
Anticipated Court Time 2.00 hours $500.00 $1000.00
Total Hours 5.60
hours___$2,270,00
i)
Einal Total and Amount Requested.
Signed this 8— day of September 2023
I,
las ;, Esquire
CERTIFICATE OF SEI
The undersigned hereby certifies that a true, yy of th Affidavit of Counsel in
Support of Attomey’s Fees was this day served fonPr ioyfers’ Att¢rney, Jack P. Milgrim, via
electronic mail.
Dated: Septemb: er %Vs 2023
Nichflas A. Halks, Esquire
~/
Commontwealth of Massachusetts
THE TRIAL COURT
PROBATE AND FAMILY COURT DEPARTMENT
PLYMOUTH DIVISION DOCKET #PL23P1323
#PL23P1324
In the interests of:
Angelina E. Maharajh
Nathaniel A. Maharajh
PROPOSED ORDER ON RESPONDENT'S MOTION TO COMPEL ANSWERS TO
RESPONSES TO BIOLOGICAL MOTHER’S REQUEST FOR PRODUCTION OF
DOCUMENTS OF PETITIONER(S) PURSUANT TO MASS. R. DOM. REL. P. 34
AFTER HEARING and consideration of Respondent's Motion to Compel Petitioners
Responses to Request for Production of Documents, it is hereby ordered that:
1. That Petitioners shall serve their Responses to Respondent’s Request for Production of
Documents as set forth in Respondent’s Motion to Compel within seven (7) days of the
date of this Order.
Award respondent her reasonable attorney fees and costs incurred in obtaining the within
order as proscribed pursuant to Rule 37(a)(4) of the Massachusetts Rules of Domestic
Relations Procedure in the amount of $2,270.00.
Order that Petitioners shall be prohibited from conducting any further discovery and be
precluded from introducing any exhibit that they do not provide to Respondent in
discovery until they produce complete discovery responses.
Dated:
Justice of the Probate and Family Court
EXHIBIT A
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SY
?HALKS FIRM
www.HALKSFIRM.com
Nicholas Alexander Halks 233 Needham Street, Suite 540
Lauren M. Scanion Ne ‘Massachusetts 02464
Kimberly R. Hopkins TEL: (617) 658-7070
Kailynn M. Palaima FAX: (617) 964-4631
VIA U.S. MAIL and EMAIL
July 14, 2023
Jack P. Milgram, Esquire
Law Offices of Jack P. Milgram,
21 Mayor Thomas J McGrath Highway,
Suite 203
Quincy,MA 02169
IN RE: Angelina Maharajh & Nathaniel Maharajh
Docket No.: PL23P1323/24
Dear Counsel,
Enclosed please find:
1. Biological Mother’s Request for Production of Documents of Petitioner,
Katherine Gentile; and
2. Biological Mother’s Request for Production of Documents of Petitioner,
Mohini Maharajh.
il
Please contact my office with any questions or concerns.
Respectfully yours,
Enclosures
TY
Commonwealth of Massachusetts
THE TRIAL COURT
PROBATE AND FAMILY COURT DEPARTMENT
PLYMOUTH DIVISION DOCKET #PL23P1323/24
In the interests of:
Angelina E. Maharajh
Nathaniel A. Maharajh
BIOLOGICAL MOTHER’S REQUEST FOR PRODUCTION OF DOCUMENTS OF
PETITIONER, KATHERINE GENTILE, PURSUANT TO MASS. R. DOM. REL. P. 34
NOW COMES Mother, Nicole Ramhit, in the above-captioned matter and, in accordance with the
provisions of Mass. R. Dom. Rel. P, 34, requests that Temporary Guardian, Katherine Gentile to
fumish Mother's Attomey with the documents hereinafter described, and permit Mother’s
Attorney to inspect and to copy such of them as may be desired.
This request is intended to cover all records and documents in the possession of Petitioners/T:
Guardians or subject to Petitioners’ custody and control, whether they are located at Petitioners’ place
of residence, any principal or secondary business office, or within the possession of any other person
or organization and being subject to Petitioners’ custody and control.
As used in this request, the terms “documents” and “records” shall mean the original, all copies and
drafts of writings of any kind, including, and without limiting the generality of the foregoing,
correspondence, memoranda, reports, notes, letters, messages (including reports, notes and
memoranda of telephone conversations and conferences), calendar and diary entries, contracts,
records, data, agreements, checks and cancelled checks, check registers, bank statements, brokerage
account statements or other writings and printed materials specifically referred to in the following
numbered requests. The terms shall also apply to any information requested which is recorded within
or upon any computer, computer disk, computer printout, tape, data sheet or data processing card, and
shall likewise include any other written, recorded, transcribed, punched, taped, filmed or graphic
matter.
All documents and records specified in each of the numbered paragraphs which follow shall be for
the period commencing May 1, 2023, up to and including the date of production of said documents,
unless a different date is specified; provided, however, that Petitioners shall supplement all responses
to this Request for Production of Documents with any such documents and records required after the
production date and until time of trial.
DOCUMENTS AND RECORDS REQUESTED
Any and all documents evidencing any relationship between the minor children and
petitioner, Katherine Gentile. Including in your response photographs, familial
information, contact information and the like.
Any and all documents pertaining to any “Go Fund Me” accounts created regarding the
ongoing litigation, Mr. Maharajh’s criminal matters, or the minor children. Include in
your response all postings, all funds received, comments and the like.
Any and all documents evidencing the purchase of any vehicle for the benefit of the
children, including the purchase and sale, any loan application, proof of
payment/downpayment, financing documents and the like.
Any and all social media postings regarding this ongoing litigation; Mother, Nicole
Ramhit; Father, Amrith Maharajh; the minor children; or you (the petitioner).
A current CORI/CARI of Katherine Gentile.
Any and all documentation regarding any individual(s) who resides with the minor
children & petitioner since May 1, 2023, criminal history and/or record, including but
not limited to, police reports, arrest reports, judgment(s) on conviction of a felony
and/or misdemeanor, and background check(s) relative to said individual(s).
Any and all pictures of the children’s current living arrangements, include in your
response any and all spaces that are designated solely for the benefit of the minor
children.
Any and all medical or educational records of Angelina or Nathaniel Maharajh from
May 1, 2023 in your care, custody or control, including but not limited to all ‘urgent
care visits, emergency roonvhospitalizations or the like,
A copy of any and all correspondence between the petitioner(s) and the Department of
Children and Families relative to the minor children and/or Mother, Nicole Ramhit.
Said response shall include text messages, emails, telephone call logs, and the like.
10. Any and all documents which illustrate your compliance with the Order of the Court
dated May 19, 2023, including a list of all dates in which Mother has seen the minor
children.
11. Copies of any and all communications including but not limited to emails, text
messages, telephone call logs, and “apps” between Katherine Gentile and Mohini
Maharajh.
12. Copies of any and all documents and communications you, petitioner have had with
Father regarding the minor children from May 1, 2023, to the present,
13. Copies of any and all documents and communications you, petitioner have had with
Mother regarding the minor children from May 1, 2023, to the present.
14. Any and all documentation evidencing expenses incurred as a result of having cared
for the minor children from June 9, 2023 to the present date.
15. Any and all documents or records showing any funds given or paid to you, any bills or
expenses paid on your behalf to any other individual or entity from June 1, 2023 to the
present. Including all documentation regarding funds provided to you by any member
of your family, friends religious community or the like for the benefit of the minor
children.
16. Any and all documents related to any Department of Children and Families (@CF)
Investigation, or case in which you were a party or a parent, regarding the care and
protection of any child.
17. Copies of your four most recent pay stubs, or documents relative to any income
received from any and all members of the household from May 1, 2023 to the present.
18. Any and all records evidencing any benefits received for the benefit of the household
from May 1, 2023 to the present including but not limited to SNAP benefits, wIc,
welfare, Social Security benefits (whether it be pursuant to SSI or SSDN,
rental/subleasing income and/or food stamps/AFDC/MassHealth.
19. Any and all records evidencing any benefits received for the benefit of the minor
children from May 1, 2023 to the present including but not limited to SNAP benefits,
WIC, welfare, Social Security benefits (whether it be pursuant to SSI or SSDN,
rental/subleasing income and/or food stamps/AFDC/MassHealth/daycare vouchers,
etc.
20. Any and all documents which you expect or intend to offer into evidence at the trial
in
this action.
Mother further requests that the foregoing documents and records be made available for inspection
and copying at the office of Mother’s Attomey, as set forth below, within days thirty (30) from the
date of service hereof.
_~
es Se
Dated: July /44 2023 Respectfully submitted.
Nicole Ramhit,
By Mother’s Attorney,
Ww
iM las Halks
Attomey for Mother
The Halks Firm
233 Needham Street
Suite 540
Newton, MA 02464
BBO#: 688768
Phone: (617) 658-7070
Email: n.halks@halkslaw.com
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true copy of the within Mother’s Request for Production
of Documents pursuant to Mass. R. Dom. Rel. P. 34 was this day served upon Petitioner, Katherine
Gentile, to their Counsel of Record, Jack P Milgram, Esquire 21 Mayor Thomas J McGrath
Highway, Suite 203 Quincy, MA 02169.
Dated: July /42023
r~
Commonwealth of Massachusetts
THE TRIAL COURT
PROBATE AND FAMILY COURT DEPARTMENT
PLYMOUTH DIVISION DOCKET #PL23P1323/24
In the interests of:
Angelina E. Maharajh
Nathaniel A. Maharajh
BIOLOGICAL MOTHER’S REQUEST FOR PRODUCTION OF DOCUMENTS OF :
PETITIONER, MOHINI MAHARAJH, PURSUANT TO MASS. R. DOM. REL. P. 34
NOW COMES Mother, Nicole Ramhit, in the above-captioned matter and, in accordance with the
provisions of Mass. R. Dom. Rel. P. 34, requests that Temporary Guardian, Mohini Maharajh, to
furnish Mother’s Attomey with the documents hereinafter described, and permit Mother’s
Attomey to inspect and to copy such of them as may be desired.
This request is intended to cover all records and documents in the possession of Petitioners/T'
Guardians or subject to Petitioners’ custody and control, whether they are located at Petitioners’ place
of residence, any principal or secondary business office, or within the possession of any other person
or organization and being subject to Petitioners’ custody and control.
As used in this request, the terms “documents” and “records” shall mean the original, all copies and
drafts of writings of any kind, including, and without limiting the generality of the foregoing,
correspondence, memoranda, reports, notes, letters, messages (including reports, notes and
memoranda of telephone conversations and conferences), calendar and diary entries, contracts,
records, data, agreements, checks and cancelled checks, check registers, bank statements, brokerage
account statements or other writings and printed materials specifically referred to in the following
numbered requests. The terms shall also apply to any information requested which is recorded within
or upon any computer, computer disk, computer printout, tape, data sheet or data processing card, and
shall likewise include any other written, recorded, transcribed, punched, taped, filmed or graphic
matter.
All documents and records specified in each of the numbered paragraphs which follow shall be for
the period commencing May 1, 2023, up to and including the date of production of said documents,
unless a different date is specified; provided, however, that Petitioners shall supplement all responses
to this Request for Production of Documents with any such documents and records Tequired after the
production date and until time of trial.
DOCUMENTS AND RECORDS REQUESTED
Any and all records relating to any Abuse Prevention Orders, Harassment Prevention
Orders, No Trespass Orders, or the like that you have requested, received, or applied
for against Father, Amrith Maharajh. Include in your Tesponse copies of the
applications, affidavit, and any order(s) issued.
Any and all documents evidencing any relationship between the minor children and
petitioner, Mohini Maharajh. Including in your Tesponse photographs, familial
information, contact information and the like.
Any and all documents pertaining to any “Go Fund Me” accounts created regarding the
ongoing litigation, Mr. Maharajh’s criminal matters, or the minor children. Include in
your response all postings, all funds received, comments and the like,
Any and all documents evidencing the purchase of any vehicle for the benefit of the
children, including the purchase and sale, any loan application, proof
of
payment/downpayment, financing documents and the like.
Any and all social media postings regarding this ongoing litigation; Mother, Nicole
Ramhit; Father, Amrith Maharajh; the minor children; or you (the petitioner),
A current CORI/CARI of Mohini Maharajh
Any and all documentation regarding any individual(s) who resides with
the minor
children & petitioner since May 1, 2023 , criminal history and/or record, including but
not limited to, police reports, arrest reports, judgment(s) on conviction of a felony
and/or misdemeanor, and background check(s) relative to said individual(s).
Any and all pictures of the children’s current living arrangements, include in your
Tesponse any and all spaces that are designated solely for the benefit of the minor
children.
Copies of any and all police reports relative to you, and Amrith Maharajh in your care,
custody or control.
10. Any and all medical or educational records of Angelina or Nathaniel Maharajh
from
May 1, 2023 in your care, custody or control, including but not limited to all urgent
care visits, emergency room/hospitalizations or the like.
11. A copy of any and all correspondence between the petitioner(s) and the Department of
Children and Families relative to the minor children and/or Mother, Nicole Ramhit.
Said response shall include text messages, emails, telephone call logs, and the like.
—~
12. Any and all documents which illustrate your compliance with the Order of the
Court
dated May 19, 2023, including a list of all dates in which Mother has seen the minor
children,
13. Copies of any and all communications including but -not limited to emails, text
messages, telephone call logs, and “apps” between Katherine Gentile and Mohini
Maharajh.
14. Copies of any and all documents and communications you, petitioner have had
with
Father regarding the minor children from May 1, 2023, to the present.
15. Copies of any and all documents and communications you, petitioner have had
with
Mother regarding the minor children from May 1, 2023, to the present,
16. Any and all documentation evidencing expenses incurred as a result of having
cared
for the minor children from June 9, 2023 to the present date.
17, Any and all documents or records showing any funds given or paid to you, any bills or
expenses paid on your behalf to any other individual or entity from June 1, 2023 to the
present. Including all documentation regarding funds provided to you by any member
of your family, friends religious community or the like for the benefit of the minor
children.
18, Any and all documents related to any Department of Children and Families (DCF)
Investigation, or case in which you were a party or a parent, regarding the care and
protection of any child.
19. Copies of your four most recent pay stubs, or documents relative to any income
received from any and all members of the household from May 1, 2023 to the present.
20. Any and all records evidencing any benefits received for the benefit of the
household
from May 1, 2023 to the present including but not limited to SNAP benefits,
WIC,
welfare, Social Security benefits (whether it be pursuant to SSI or SSDD,
rental/subleasing income and/or food stamps/AFDC/MassHealth.
21. Any and all records evidencing any benefits received for the benefit of the
minor
children from May 1, 2023 to the present including but not limited to SNAP
benefits,
WIC, welfare, Social Security benefits (whether it be pursuant to SSI or SSD),
rental/subleasing income and/or food stamps/AFDC/MassHealth/daycare vouchers
,
ete.
22, Any and all documents which you expect or intend to offer into evidence at
the trial in
this action.
Mother further requests that the foregoing documents and records be made available for inspection
and copying at the office of Mother’s Attomey, as set forth below, within days thirty (30) from the
date of service hereof.
Dated: July “2023 Respectfully submitted.
Nicole Ramhit,
By Mother’s Attorney,
Attorney for Mother
The Halks Firm
233 Needham Street
Suite 540
Newton, MA 02464
BBO#: 688768
Phone: (617) 658-7070
Email: n.halks@halkslaw.com
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true copy of the within Mother’s Request for Production
of Documents pursuant to Mass. R. Dom. Rel. P. 34 was this day served upon Petitioner, Mohini
Maharajh to her Counsel of Record, Jack P Milgram, Esquire 21 Mayor Thomas J McGrath
Highway, Suite 203 Quincy, MA 02169.
Dated: July \Y 2023 NA
Nicholas Halks, Esq
Vim sonCP>
juire
EXHIBIT B
*?HALKS FIRM
www.HALKSFIRM.com
‘Nicholas Alexander Halks 233 Needham Street, Suite 540
Lauren M. Scanlon Newton, Massachusetts 02464
Kimberly R. Hopkins TEL: (617) 658-7070
Kailynn M. Ney FAX: (617) 964-4631
VIA U.S, MAIL and EMAIL
August 17, 2023
Jack P. Milgrim, Esquire
Law Offices of Jack P. Milgrim
21 Mayor Thomas J. McGrath Highway
Suite 203
Quincy,
MA 02169
RE: Ramhit v. Mah: b
Docket No.: PL23P1323/24
Dear Counsel,
Iam writing as Mother’s Requests for Production of Documents served upon Ms.
Katherine Gentile and Ms. Mohini Maharajh on or about July 14, 2023 remain outstandii
Please advise, no later than Wednesday, August 23, 2023 as to your availability for a discovery
conference pursuant to Mass, R. Dom. Rel. P. 26(G).
look forward to receiving your Clients’ responses forthwith. Thank you for your
anticipated cooperation.
Respecthtl]
jE LL
Nictolas Halks, Esq
NAH/kmn v
Ce: Client
Preview
- wy vv id: 123 i Commontneatth of Hlassachusetts THE TRIAL COURT PROBATE AND FAMILY COURT DEPARTMENT ‘ oa PLYMOUTH DIVISION Plymouth, ss robate CourDOCKET #P123P1323 & fe #PL23P1324 he in Motions hereby-atteweek In the interests of: s Angelina E. Maharajh Nathaniel A. Maharajh of Probate Court SAN RESPONDENT'S MOTION TO COMPEL ANSWERS TO RESPONSES TO Vien YW BIOLOGICAL MOTHER’S REQUEST FOR PRODUCTION OF DOCUMENTS OF y PETITIONER(S) PURSUANT TO MASS. R. DOM. REL. P. 34 S SUos NOW COMES Respondent, Nicole Ramhit, (hereinafter “Mother”) in the above-captioned matter } ; and respectfully moves this Honorable Court, pursuant to Mass. R. Dom. Rel. P. 37 (d), to. compel Petitioners, Katherine Gentile and Mohini Maharajh, to forthwith provide Mother Vs with 0 . supplemental responses to Request for Production of Documents of’ Petitioner(s) Pursuant gl 8S to Mass. na 3 : d oe R. Dom. Rel. P. 34. Respondent further moves this Honorable Court, pursuant to Mass. R. Dom. Rel. P. 37 (d), to order the Petitioners to pay the Respondent’s reasonable expenses, including attorney’s fees, incurred in the preparation and presentation of this Motion to Compel. In support ~ of the within Motion, the Respondent states the following: 1. The underlying petition for Grandparent(s) Visitation was filed on or about June 6, 2023. > ~ § 2. On or about July 14, 2023, Counsel for Respondent served upon Petitioners; Biologica X l _X Mother’s Request for Production of Documents of Petitioner, Katherine Gentile, to Mass. R. Dom. Rel. P. 34. and Biological Mother’s Request for Producti Pursuant AS 3 on ‘of Documents of Petitioner, Mohini Maharajh, Pursuant to Mass. R. Dom. Rel. P. 34, Y [Exhibit Al. : \ On or about August 17, 2023, Counsel for Respondent sought a 26(g) conference in ton x of the Petitioners’ failure to produce any documents from the Mother’s Request for : 2 Se Q Production of Documents served upon Ms. Gentile and Ms. Mohini on o! t about July 14, J “d 2023. [Exhibit B}. i FILED fs tok Se VN KS OCT 3 0 2023 PROBATE 4 FAMILY COURT JU§ PLYMOUTH DIVISION ~ \ 4. Following the Respondent's request for a 26(g) conference, no response was received by August 23, 2023, which was set forth in the August 17, 2023, 26(g) request. Furthermore, no correspondence regarding the outstanding documents was received at all. WHEREFORE, Respondent requests that this Honorable Court enter the following order: 1, That Petitioners shall serve their Supplemental Responses to Respondent’s Request for Production of Documents dated July 14, 2023, within seven (7) days of the date of this Order; Award Respondent her reasonable attorney fees and costs incurred in obtaining the within order as proscribed pursuant to Rule 37(a)(4) of the Massachusetts Rules of Domestic Relations Procedure; and The Petitioners shall be prohibited from conducting any further discovery and be precluded from introducing any exhibit that they do not provide to the Respondent in discovery until they produce complete discovery responses. Dated: septenve, 2023 Respectful] bmitted. Nic e R: By Attprney,\ i shol: . Halks, Esquire BBO #688768 ilynn M. Palaima, Esquire BBO #711501 THE HALKS FIRM 233 Needham Street, Suite 540 Newton, MA 02464 Telephone: 617-658-7070 n-halks@halkslaw.com k.palaima@halkslaw.com RULE 26(G) CERTIFICATION I, Nicholas A. Halks, Esquire, Counsel of Record for the Respondent, certify that my office sent correspondence to Petitioners’ counsel on August 17, 2023, in an attempt to procure outstanding discovery from the Petitioners, as set forth in the within Motion to Compel. Said request was ignored and no discovery conference was held. Dated: september 2, 2023 f Nichy AM Halks, Esq. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true copy of the within Respondent’s Motion to Compel was served upon Petitioners to Jack P. Milgrim, Attomey for Petitioners, of Law Offices of Jack Milgrim, 21 Mayor Thomas J. McGrath Highway, Suite 203, Quincy, MA 02169 and to Michael Nashawaty, Esq., Attorney for Father, of Nashawaty & Rand, 654 MA 02184, via first class mail postage prepaid and el nic Wail. Dated: Septemb % er 2023 ry A. Ha, Esq. NOTICE OF HEARING ON MOTION To: Jack P. Milgrim, Esq. and Michael Nashawaty, Esq. iS Please take notice that the undersigned will present for hearing the within Respondent’s Motion to Compel before the Plymouth Division of the Probi ate ly Court holden in Brockton on September 18, 2023 at 9:00am or as soon thereafter as co Dated: September & 2023 , Nictblad A HB, Esquire ~ ( ~ ’ Commonwealth of Filassathusetts THE TRIAL COURT PROBATE AND FAMILY COURT DEPARTMENT PLYMOUTH DIVISION DOCKET #PL23P1323 #PL23P1324 In the interests of: Angelina E. Maharajh Nathaniel A. Maharajh AFFIDAVIT OF COUNSEL IN SUPPORT OF ATTORNEY’S FEES I, Nicholas A. Halks, Esquire, Counsel for the Respondent, do hereby state that the following affidavit is an accurate representation of the fees for services and costs incurred by the Respondent as a result of the representation of this office, to the best of my knowledge and belief and represent my usual and customary hourly rate of $500.00 per hour, the associate rate of $300.00 per hour, and the paralegal rate of $150.00 per hour. Activity or Fee Name Hours Fees Total 26(g) Letter sent to Opposing Counsel 0.20 hours $300.00 $60.00 Draft Motion to Compel 0.80 hours $150.00 $120.00 Draft Affidavit for Attorney’s Fees 0.40 Hours $150.00 $60.00 Draft Proposed Order on Motion to Compel 0.20 hours $150.00 $30.00 Anticipated Travel Time to and From Court 2.00 hours $500.00 $1000.00 Anticipated Court Time 2.00 hours $500.00 $1000.00 Total Hours 5.60 hours___$2,270,00 i) Einal Total and Amount Requested. Signed this 8— day of September 2023 I, las ;, Esquire CERTIFICATE OF SEI The undersigned hereby certifies that a true, yy of th Affidavit of Counsel in Support of Attomey’s Fees was this day served fonPr ioyfers’ Att¢rney, Jack P. Milgrim, via electronic mail. Dated: Septemb: er %Vs 2023 Nichflas A. Halks, Esquire ~/ Commontwealth of Massachusetts THE TRIAL COURT PROBATE AND FAMILY COURT DEPARTMENT PLYMOUTH DIVISION DOCKET #PL23P1323 #PL23P1324 In the interests of: Angelina E. Maharajh Nathaniel A. Maharajh PROPOSED ORDER ON RESPONDENT'S MOTION TO COMPEL ANSWERS TO RESPONSES TO BIOLOGICAL MOTHER’S REQUEST FOR PRODUCTION OF DOCUMENTS OF PETITIONER(S) PURSUANT TO MASS. R. DOM. REL. P. 34 AFTER HEARING and consideration of Respondent's Motion to Compel Petitioners Responses to Request for Production of Documents, it is hereby ordered that: 1. That Petitioners shall serve their Responses to Respondent’s Request for Production of Documents as set forth in Respondent’s Motion to Compel within seven (7) days of the date of this Order. Award respondent her reasonable attorney fees and costs incurred in obtaining the within order as proscribed pursuant to Rule 37(a)(4) of the Massachusetts Rules of Domestic Relations Procedure in the amount of $2,270.00. Order that Petitioners shall be prohibited from conducting any further discovery and be precluded from introducing any exhibit that they do not provide to Respondent in discovery until they produce complete discovery responses. Dated: Justice of the Probate and Family Court EXHIBIT A / Z SY ?HALKS FIRM www.HALKSFIRM.com Nicholas Alexander Halks 233 Needham Street, Suite 540 Lauren M. Scanion Ne ‘Massachusetts 02464 Kimberly R. Hopkins TEL: (617) 658-7070 Kailynn M. Palaima FAX: (617) 964-4631 VIA U.S. MAIL and EMAIL July 14, 2023 Jack P. Milgram, Esquire Law Offices of Jack P. Milgram, 21 Mayor Thomas J McGrath Highway, Suite 203 Quincy,MA 02169 IN RE: Angelina Maharajh & Nathaniel Maharajh Docket No.: PL23P1323/24 Dear Counsel, Enclosed please find: 1. Biological Mother’s Request for Production of Documents of Petitioner, Katherine Gentile; and 2. Biological Mother’s Request for Production of Documents of Petitioner, Mohini Maharajh. il Please contact my office with any questions or concerns. Respectfully yours, Enclosures TY Commonwealth of Massachusetts THE TRIAL COURT PROBATE AND FAMILY COURT DEPARTMENT PLYMOUTH DIVISION DOCKET #PL23P1323/24 In the interests of: Angelina E. Maharajh Nathaniel A. Maharajh BIOLOGICAL MOTHER’S REQUEST FOR PRODUCTION OF DOCUMENTS OF PETITIONER, KATHERINE GENTILE, PURSUANT TO MASS. R. DOM. REL. P. 34 NOW COMES Mother, Nicole Ramhit, in the above-captioned matter and, in accordance with the provisions of Mass. R. Dom. Rel. P, 34, requests that Temporary Guardian, Katherine Gentile to fumish Mother's Attomey with the documents hereinafter described, and permit Mother’s Attorney to inspect and to copy such of them as may be desired. This request is intended to cover all records and documents in the possession of Petitioners/T: Guardians or subject to Petitioners’ custody and control, whether they are located at Petitioners’ place of residence, any principal or secondary business office, or within the possession of any other person or organization and being subject to Petitioners’ custody and control. As used in this request, the terms “documents” and “records” shall mean the original, all copies and drafts of writings of any kind, including, and without limiting the generality of the foregoing, correspondence, memoranda, reports, notes, letters, messages (including reports, notes and memoranda of telephone conversations and conferences), calendar and diary entries, contracts, records, data, agreements, checks and cancelled checks, check registers, bank statements, brokerage account statements or other writings and printed materials specifically referred to in the following numbered requests. The terms shall also apply to any information requested which is recorded within or upon any computer, computer disk, computer printout, tape, data sheet or data processing card, and shall likewise include any other written, recorded, transcribed, punched, taped, filmed or graphic matter. All documents and records specified in each of the numbered paragraphs which follow shall be for the period commencing May 1, 2023, up to and including the date of production of said documents, unless a different date is specified; provided, however, that Petitioners shall supplement all responses to this Request for Production of Documents with any such documents and records required after the production date and until time of trial. DOCUMENTS AND RECORDS REQUESTED Any and all documents evidencing any relationship between the minor children and petitioner, Katherine Gentile. Including in your response photographs, familial information, contact information and the like. Any and all documents pertaining to any “Go Fund Me” accounts created regarding the ongoing litigation, Mr. Maharajh’s criminal matters, or the minor children. Include in your response all postings, all funds received, comments and the like. Any and all documents evidencing the purchase of any vehicle for the benefit of the children, including the purchase and sale, any loan application, proof of payment/downpayment, financing documents and the like. Any and all social media postings regarding this ongoing litigation; Mother, Nicole Ramhit; Father, Amrith Maharajh; the minor children; or you (the petitioner). A current CORI/CARI of Katherine Gentile. Any and all documentation regarding any individual(s) who resides with the minor children & petitioner since May 1, 2023, criminal history and/or record, including but not limited to, police reports, arrest reports, judgment(s) on conviction of a felony and/or misdemeanor, and background check(s) relative to said individual(s). Any and all pictures of the children’s current living arrangements, include in your response any and all spaces that are designated solely for the benefit of the minor children. Any and all medical or educational records of Angelina or Nathaniel Maharajh from May 1, 2023 in your care, custody or control, including but not limited to all ‘urgent care visits, emergency roonvhospitalizations or the like, A copy of any and all correspondence between the petitioner(s) and the Department of Children and Families relative to the minor children and/or Mother, Nicole Ramhit. Said response shall include text messages, emails, telephone call logs, and the like. 10. Any and all documents which illustrate your compliance with the Order of the Court dated May 19, 2023, including a list of all dates in which Mother has seen the minor children. 11. Copies of any and all communications including but not limited to emails, text messages, telephone call logs, and “apps” between Katherine Gentile and Mohini Maharajh. 12. Copies of any and all documents and communications you, petitioner have had with Father regarding the minor children from May 1, 2023, to the present, 13. Copies of any and all documents and communications you, petitioner have had with Mother regarding the minor children from May 1, 2023, to the present. 14. Any and all documentation evidencing expenses incurred as a result of having cared for the minor children from June 9, 2023 to the present date. 15. Any and all documents or records showing any funds given or paid to you, any bills or expenses paid on your behalf to any other individual or entity from June 1, 2023 to the present. Including all documentation regarding funds provided to you by any member of your family, friends religious community or the like for the benefit of the minor children. 16. Any and all documents related to any Department of Children and Families (@CF) Investigation, or case in which you were a party or a parent, regarding the care and protection of any child. 17. Copies of your four most recent pay stubs, or documents relative to any income received from any and all members of the household from May 1, 2023 to the present. 18. Any and all records evidencing any benefits received for the benefit of the household from May 1, 2023 to the present including but not limited to SNAP benefits, wIc, welfare, Social Security benefits (whether it be pursuant to SSI or SSDN, rental/subleasing income and/or food stamps/AFDC/MassHealth. 19. Any and all records evidencing any benefits received for the benefit of the minor children from May 1, 2023 to the present including but not limited to SNAP benefits, WIC, welfare, Social Security benefits (whether it be pursuant to SSI or SSDN, rental/subleasing income and/or food stamps/AFDC/MassHealth/daycare vouchers, etc. 20. Any and all documents which you expect or intend to offer into evidence at the trial in this action. Mother further requests that the foregoing documents and records be made available for inspection and copying at the office of Mother’s Attomey, as set forth below, within days thirty (30) from the date of service hereof. _~ es Se Dated: July /44 2023 Respectfully submitted. Nicole Ramhit, By Mother’s Attorney, Ww iM las Halks Attomey for Mother The Halks Firm 233 Needham Street Suite 540 Newton, MA 02464 BBO#: 688768 Phone: (617) 658-7070 Email: n.halks@halkslaw.com CERTIFICATE OF SERVICE The undersigned hereby certifies that a true copy of the within Mother’s Request for Production of Documents pursuant to Mass. R. Dom. Rel. P. 34 was this day served upon Petitioner, Katherine Gentile, to their Counsel of Record, Jack P Milgram, Esquire 21 Mayor Thomas J McGrath Highway, Suite 203 Quincy, MA 02169. Dated: July /42023 r~ Commonwealth of Massachusetts THE TRIAL COURT PROBATE AND FAMILY COURT DEPARTMENT PLYMOUTH DIVISION DOCKET #PL23P1323/24 In the interests of: Angelina E. Maharajh Nathaniel A. Maharajh BIOLOGICAL MOTHER’S REQUEST FOR PRODUCTION OF DOCUMENTS OF : PETITIONER, MOHINI MAHARAJH, PURSUANT TO MASS. R. DOM. REL. P. 34 NOW COMES Mother, Nicole Ramhit, in the above-captioned matter and, in accordance with the provisions of Mass. R. Dom. Rel. P. 34, requests that Temporary Guardian, Mohini Maharajh, to furnish Mother’s Attomey with the documents hereinafter described, and permit Mother’s Attomey to inspect and to copy such of them as may be desired. This request is intended to cover all records and documents in the possession of Petitioners/T' Guardians or subject to Petitioners’ custody and control, whether they are located at Petitioners’ place of residence, any principal or secondary business office, or within the possession of any other person or organization and being subject to Petitioners’ custody and control. As used in this request, the terms “documents” and “records” shall mean the original, all copies and drafts of writings of any kind, including, and without limiting the generality of the foregoing, correspondence, memoranda, reports, notes, letters, messages (including reports, notes and memoranda of telephone conversations and conferences), calendar and diary entries, contracts, records, data, agreements, checks and cancelled checks, check registers, bank statements, brokerage account statements or other writings and printed materials specifically referred to in the following numbered requests. The terms shall also apply to any information requested which is recorded within or upon any computer, computer disk, computer printout, tape, data sheet or data processing card, and shall likewise include any other written, recorded, transcribed, punched, taped, filmed or graphic matter. All documents and records specified in each of the numbered paragraphs which follow shall be for the period commencing May 1, 2023, up to and including the date of production of said documents, unless a different date is specified; provided, however, that Petitioners shall supplement all responses to this Request for Production of Documents with any such documents and records Tequired after the production date and until time of trial. DOCUMENTS AND RECORDS REQUESTED Any and all records relating to any Abuse Prevention Orders, Harassment Prevention Orders, No Trespass Orders, or the like that you have requested, received, or applied for against Father, Amrith Maharajh. Include in your Tesponse copies of the applications, affidavit, and any order(s) issued. Any and all documents evidencing any relationship between the minor children and petitioner, Mohini Maharajh. Including in your Tesponse photographs, familial information, contact information and the like. Any and all documents pertaining to any “Go Fund Me” accounts created regarding the ongoing litigation, Mr. Maharajh’s criminal matters, or the minor children. Include in your response all postings, all funds received, comments and the like, Any and all documents evidencing the purchase of any vehicle for the benefit of the children, including the purchase and sale, any loan application, proof of payment/downpayment, financing documents and the like. Any and all social media postings regarding this ongoing litigation; Mother, Nicole Ramhit; Father, Amrith Maharajh; the minor children; or you (the petitioner), A current CORI/CARI of Mohini Maharajh Any and all documentation regarding any individual(s) who resides with the minor children & petitioner since May 1, 2023 , criminal history and/or record, including but not limited to, police reports, arrest reports, judgment(s) on conviction of a felony and/or misdemeanor, and background check(s) relative to said individual(s). Any and all pictures of the children’s current living arrangements, include in your Tesponse any and all spaces that are designated solely for the benefit of the minor children. Copies of any and all police reports relative to you, and Amrith Maharajh in your care, custody or control. 10. Any and all medical or educational records of Angelina or Nathaniel Maharajh from May 1, 2023 in your care, custody or control, including but not limited to all urgent care visits, emergency room/hospitalizations or the like. 11. A copy of any and all correspondence between the petitioner(s) and the Department of Children and Families relative to the minor children and/or Mother, Nicole Ramhit. Said response shall include text messages, emails, telephone call logs, and the like. —~ 12. Any and all documents which illustrate your compliance with the Order of the Court dated May 19, 2023, including a list of all dates in which Mother has seen the minor children, 13. Copies of any and all communications including but -not limited to emails, text messages, telephone call logs, and “apps” between Katherine Gentile and Mohini Maharajh. 14. Copies of any and all documents and communications you, petitioner have had with Father regarding the minor children from May 1, 2023, to the present. 15. Copies of any and all documents and communications you, petitioner have had with Mother regarding the minor children from May 1, 2023, to the present, 16. Any and all documentation evidencing expenses incurred as a result of having cared for the minor children from June 9, 2023 to the present date. 17, Any and all documents or records showing any funds given or paid to you, any bills or expenses paid on your behalf to any other individual or entity from June 1, 2023 to the present. Including all documentation regarding funds provided to you by any member of your family, friends religious community or the like for the benefit of the minor children. 18, Any and all documents related to any Department of Children and Families (DCF) Investigation, or case in which you were a party or a parent, regarding the care and protection of any child. 19. Copies of your four most recent pay stubs, or documents relative to any income received from any and all members of the household from May 1, 2023 to the present. 20. Any and all records evidencing any benefits received for the benefit of the household from May 1, 2023 to the present including but not limited to SNAP benefits, WIC, welfare, Social Security benefits (whether it be pursuant to SSI or SSDD, rental/subleasing income and/or food stamps/AFDC/MassHealth. 21. Any and all records evidencing any benefits received for the benefit of the minor children from May 1, 2023 to the present including but not limited to SNAP benefits, WIC, welfare, Social Security benefits (whether it be pursuant to SSI or SSD), rental/subleasing income and/or food stamps/AFDC/MassHealth/daycare vouchers , ete. 22, Any and all documents which you expect or intend to offer into evidence at the trial in this action. Mother further requests that the foregoing documents and records be made available for inspection and copying at the office of Mother’s Attomey, as set forth below, within days thirty (30) from the date of service hereof. Dated: July “2023 Respectfully submitted. Nicole Ramhit, By Mother’s Attorney, Attorney for Mother The Halks Firm 233 Needham Street Suite 540 Newton, MA 02464 BBO#: 688768 Phone: (617) 658-7070 Email: n.halks@halkslaw.com CERTIFICATE OF SERVICE The undersigned hereby certifies that a true copy of the within Mother’s Request for Production of Documents pursuant to Mass. R. Dom. Rel. P. 34 was this day served upon Petitioner, Mohini Maharajh to her Counsel of Record, Jack P Milgram, Esquire 21 Mayor Thomas J McGrath Highway, Suite 203 Quincy, MA 02169. Dated: July \Y 2023 NA Nicholas Halks, Esq Vim sonCP> juire EXHIBIT B *?HALKS FIRM www.HALKSFIRM.com ‘Nicholas Alexander Halks 233 Needham Street, Suite 540 Lauren M. Scanlon Newton, Massachusetts 02464 Kimberly R. Hopkins TEL: (617) 658-7070 Kailynn M. Ney FAX: (617) 964-4631 VIA U.S, MAIL and EMAIL August 17, 2023 Jack P. Milgrim, Esquire Law Offices of Jack P. Milgrim 21 Mayor Thomas J. McGrath Highway Suite 203 Quincy, MA 02169 RE: Ramhit v. Mah: b Docket No.: PL23P1323/24 Dear Counsel, Iam writing as Mother’s Requests for Production of Documents served upon Ms. Katherine Gentile and Ms. Mohini Maharajh on or about July 14, 2023 remain outstandii Please advise, no later than Wednesday, August 23, 2023 as to your availability for a discovery conference pursuant to Mass, R. Dom. Rel. P. 26(G). look forward to receiving your Clients’ responses forthwith. Thank you for your anticipated cooperation. Respecthtl] jE LL Nictolas Halks, Esq NAH/kmn v Ce: Client