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COMMONWEALTH OF MASSACHUSETTS
TRIAL COURT
BARNSTABLE, SS BARNSTABLE SUPERIOR
COURT
C.A. NO. 2272CV00495
Jennifer Doe,
Plaintiff,
Vv.
The Estate of Arnold F. Lett, Sr.
by its Personal Representatives,
Scott Gowen and Alan Ligouri,
Defendants
panne
i
PLAINTIFF’S MOTION FOR NONDISCLOSURE AND TO IMPOUND
PLAINTIFF'S IDENTITY AND BIOGRAPHICAL INFORMATION TO THE PUBLIC —
ASSENTED TO
NOW COMES the Plaintiff, in the above captioned matter, pursuant to-Trial Court Rule
VIII (Uniform Rules on Impoundment Procedure (“URIP”)), Mass. R. Sup. Ct. 18, A & B, which
states
Trial Court Rule VIII
Rule 18. Impoundment and Personal Identifying Information (Applicable in all counties)
A Impoundment
1. Impoundment in the Superior Court shall be governed by Trial Court Rule VIII
1 (Uniform Rules on Impoundment Procedure (“URIP”)), as supplemented by paragraph
2(b), below.
2. a. Purpose. Paragraph 2(b) of this Rule makes exceptions to the notice requirement of
URIP Rule 13(b), which ordinarily requires that when a person files impounded material
he or she also must file a notice alerting the clerk to that material. b. Exceptions to Notice
Requirement of URIP Rule 13(b).
Because the following materials are impounded by law, and the clerks! offices impound
them in the normal course, no Rule 13(b) notice is necessary when filing any of them:
1, an Affidavit of Indigency and Request for Waiver, Substitution or State Payment of
Fees & Costs, on the form prescribed by the Chief Justice of the Supreme Judicial Court
under G.L. ¢. 261, § 27B
2. a Petition for Abortion Authorization under G.L. c. 112, § 12S, or any materials in
such matter;
3. an action for judicial review of a decision of the Sex Offender Registry Board, under
GL. c. 6, § 178M, or any materials in such matter; or
4. any confidential document or other material prepared especially for a pre-indictment
judicial hearing concerning a grand jury proceeding. c.
Duty of the Clerk.
The clerk shall maintain the impounded material described above in accordance with the
clerk’s duties prescribed in URIP Rule 9.
B. Personal Identifying Information
3. Redaction and treatment of personal identifying information shall be governed by
Supreme Judicial Court Rule 1:24, as supplemented by paragraph 4 below.
4. Pursuant to Section 5(c) of Supreme Judicial Court 1:24, personal identifying
information contained in administrative records filed by agencies shall be treated as may
be provided in Standing Order 1-96, as amended from time to time.
Who have filed this Assented to Mzsti=s=keiat Motion for Nondisclosure and Impound the
Plaintiff's Identity of the Plaintiff to the Public with respect to the above captioned matter to
prevent the dissemination of, the impound of and the nondisclosure and of the Plaintiff, Jennifer
Doe’s personal identity, including but not limited to, her name, address, social security number,
birthdate, and any and all other biographical, and identifiable information to the public, with the
exception of the Attorney of Record to their Client in this matter.
In accordance with URIP Rule VIII, there must be good cause for this Motion. The good
cause for this Motion is that the Plaintiff in this matter was a child less than the age of 14 when
she alleges the incidents of sexual assault began by the Decedent named in the caption above.
The Plaintiff through her Counsel of Record requests this Honorable Court to allow the
Assented to Motion for Nondisclosure and Impound the Plaintiff's Identity of the Plaintiff to the
Public in this matter.
Respectfully submitted,
The Plaintiff, Jennifer Doe,
by her Attorney,
P
4S),
VP en Greenwood, Esq Date: - Apr tejn00y
Kristen Greenwood, Esq. BBO#: 678189
Law Office of Kristen Greenwood, PLLC.
349 Old Plymouth Rd, First Floor
Sagamore Beach, MA 02562
P: 508-299-3965
F: 508-815-1620
E: Kristen@attykg.com
Assented to by:
Defendants together,
Estate of Arnold F. Lett, Sr.,
by its personal representatives,
Scott Gowen and Alan Ligouri
By its Attorney,
Us Scott J. Tucker Date: “yp [.2Y
Scott J. Tucker |
BBO# 503940
Ann M. Donovan
BBO# 552819
Tucker, Dyer & O’Connell, LLP
199 Wells Avenue
Newton, MA 02459
Main (617) 986-6220
tucker@tdolaw.com
donovan@tdolaw.com
COMMONWEALTH OF MASSACHUSETTS
TRIAL COURT
BARNSTABLE, SS BARNSTABLE SUPERIOR COURT
C.A. NO. 2272CV00495
Jennifer Doe,
Plaintiff,
Vv.
The Estate of Arnold F. Lett, Sr.
by its Personal Representatives,
Scott Gowen and Alan Ligouri,
Defendants.
ATTORNEY AFFIDAVIT IN SUPPORT OF ASSENTED TO MOTION FOR
NONDISCLOSURE AND IMPOUND OF PLAINTIFF’S IDENTITY
AND BIOGRAPHICAL INFORMATION TO THE PUBLIC
I, Plaintiff's Attorney of Record, for the Plaintiff, Kristen Greenwood, Esq., duly sworn, depose
and say:
1 I am an Attorney licensed to practice law in the Commonwealth of Massachusetts;
2. The grounds for this Assented to Motion is due to the sensitive nature of the
allegations by the Plaintiff that she was sexually assaulted numerous times by the
Decedent named in the above caption when she was under the age of fourteen (14)
years old, which makes her a minor, and the physical, emotional and psychological
harm, shame, embarrassment, etc., she has experienced that comes with sexual abuse;
lam requesting the Assented to Motion for Nondisclosure and Impound the
Plaintiff's Identity of the Plaintiff to the Public.
Signed under the pains and penalties of perjury,
/8/Kristen Greenwood Date: 4 |ofay
Kristen Greenwood, Esq.
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COMMONWEALTH OF MASSACHUSETTS TRIAL COURT BARNSTABLE, SS BARNSTABLE SUPERIOR COURT C.A. NO. 2272CV00495 Jennifer Doe, Plaintiff, Vv. The Estate of Arnold F. Lett, Sr. by its Personal Representatives, Scott Gowen and Alan Ligouri, Defendants panne i PLAINTIFF’S MOTION FOR NONDISCLOSURE AND TO IMPOUND PLAINTIFF'S IDENTITY AND BIOGRAPHICAL INFORMATION TO THE PUBLIC — ASSENTED TO NOW COMES the Plaintiff, in the above captioned matter, pursuant to-Trial Court Rule VIII (Uniform Rules on Impoundment Procedure (“URIP”)), Mass. R. Sup. Ct. 18, A & B, which states Trial Court Rule VIII Rule 18. Impoundment and Personal Identifying Information (Applicable in all counties) A Impoundment 1. Impoundment in the Superior Court shall be governed by Trial Court Rule VIII 1 (Uniform Rules on Impoundment Procedure (“URIP”)), as supplemented by paragraph 2(b), below. 2. a. Purpose. Paragraph 2(b) of this Rule makes exceptions to the notice requirement of URIP Rule 13(b), which ordinarily requires that when a person files impounded material he or she also must file a notice alerting the clerk to that material. b. Exceptions to Notice Requirement of URIP Rule 13(b). Because the following materials are impounded by law, and the clerks! offices impound them in the normal course, no Rule 13(b) notice is necessary when filing any of them: 1, an Affidavit of Indigency and Request for Waiver, Substitution or State Payment of Fees & Costs, on the form prescribed by the Chief Justice of the Supreme Judicial Court under G.L. ¢. 261, § 27B 2. a Petition for Abortion Authorization under G.L. c. 112, § 12S, or any materials in such matter; 3. an action for judicial review of a decision of the Sex Offender Registry Board, under GL. c. 6, § 178M, or any materials in such matter; or 4. any confidential document or other material prepared especially for a pre-indictment judicial hearing concerning a grand jury proceeding. c. Duty of the Clerk. The clerk shall maintain the impounded material described above in accordance with the clerk’s duties prescribed in URIP Rule 9. B. Personal Identifying Information 3. Redaction and treatment of personal identifying information shall be governed by Supreme Judicial Court Rule 1:24, as supplemented by paragraph 4 below. 4. Pursuant to Section 5(c) of Supreme Judicial Court 1:24, personal identifying information contained in administrative records filed by agencies shall be treated as may be provided in Standing Order 1-96, as amended from time to time. Who have filed this Assented to Mzsti=s=keiat Motion for Nondisclosure and Impound the Plaintiff's Identity of the Plaintiff to the Public with respect to the above captioned matter to prevent the dissemination of, the impound of and the nondisclosure and of the Plaintiff, Jennifer Doe’s personal identity, including but not limited to, her name, address, social security number, birthdate, and any and all other biographical, and identifiable information to the public, with the exception of the Attorney of Record to their Client in this matter. In accordance with URIP Rule VIII, there must be good cause for this Motion. The good cause for this Motion is that the Plaintiff in this matter was a child less than the age of 14 when she alleges the incidents of sexual assault began by the Decedent named in the caption above. The Plaintiff through her Counsel of Record requests this Honorable Court to allow the Assented to Motion for Nondisclosure and Impound the Plaintiff's Identity of the Plaintiff to the Public in this matter. Respectfully submitted, The Plaintiff, Jennifer Doe, by her Attorney, P 4S), VP en Greenwood, Esq Date: - Apr tejn00y Kristen Greenwood, Esq. BBO#: 678189 Law Office of Kristen Greenwood, PLLC. 349 Old Plymouth Rd, First Floor Sagamore Beach, MA 02562 P: 508-299-3965 F: 508-815-1620 E: Kristen@attykg.com Assented to by: Defendants together, Estate of Arnold F. Lett, Sr., by its personal representatives, Scott Gowen and Alan Ligouri By its Attorney, Us Scott J. Tucker Date: “yp [.2Y Scott J. Tucker | BBO# 503940 Ann M. Donovan BBO# 552819 Tucker, Dyer & O’Connell, LLP 199 Wells Avenue Newton, MA 02459 Main (617) 986-6220 tucker@tdolaw.com donovan@tdolaw.com COMMONWEALTH OF MASSACHUSETTS TRIAL COURT BARNSTABLE, SS BARNSTABLE SUPERIOR COURT C.A. NO. 2272CV00495 Jennifer Doe, Plaintiff, Vv. The Estate of Arnold F. Lett, Sr. by its Personal Representatives, Scott Gowen and Alan Ligouri, Defendants. ATTORNEY AFFIDAVIT IN SUPPORT OF ASSENTED TO MOTION FOR NONDISCLOSURE AND IMPOUND OF PLAINTIFF’S IDENTITY AND BIOGRAPHICAL INFORMATION TO THE PUBLIC I, Plaintiff's Attorney of Record, for the Plaintiff, Kristen Greenwood, Esq., duly sworn, depose and say: 1 I am an Attorney licensed to practice law in the Commonwealth of Massachusetts; 2. The grounds for this Assented to Motion is due to the sensitive nature of the allegations by the Plaintiff that she was sexually assaulted numerous times by the Decedent named in the above caption when she was under the age of fourteen (14) years old, which makes her a minor, and the physical, emotional and psychological harm, shame, embarrassment, etc., she has experienced that comes with sexual abuse; lam requesting the Assented to Motion for Nondisclosure and Impound the Plaintiff's Identity of the Plaintiff to the Public. Signed under the pains and penalties of perjury, /8/Kristen Greenwood Date: 4 |ofay Kristen Greenwood, Esq.