Motion,Ex Parte: Doe, Jennifer vs. Lett, Sr., Arnold F. et al

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                                SUPERIOR COURT
                                                                              BARNSTABLE, SS

                                                                                 JUN    4 2024

                      COMMONWEALTH           OF MASSACHUSETTS                      |
                                                                        Scott W. Nickerson, Clerk
BARNSTABLE, ss.                                                 SUPERIOR COURT
                                                                C.A. NO. 2272CV00495

JENNIFER DOE,                                               UAL 4,     2024
     Plaintiff,                                            ArLoutol, ar fui al epefaverte (
v.                                                         to ere       Led i He
ESTATE OF ARNOLD F. LETT, SR.,
By its Personal Representatives, Scott Gowen
                                                            Fol. 20259427! on
and Alan Liguori,
       Defendants.
                                                                          *    Figgst- Clave
                   JOINT MOTION       TO AMEND      TRACKING ORDER

      Now come the parties to this action and jointly move to amend the Tracking
Order to provide additional time to complete discovery, This is the second request to
amend the Tracking Order. The Complaint was filed in December 2022 and the Answer
was filed in January 2023.

       As required by Superior Court Rule 9(f) the parties submit that:

       1) The plaintiff alleges that the Estate’s decedent, her grandfather, sexually
          molested her over a number of years beginning when she was six years old;
       2) Suit was filed after her grandfather died;
       3)   This is the second time the parties have moved to amend the Tracking Order;
       4)   The parties have exchanged written discovery;
       5)   The plaintiff has agreed to provide authorizations for the release of treatment
            records from two mental health professionals with whom she has treated
            within the last 3 years; and
       6)   The parties have noticed the depositions of the plaintiff (completion), her
            mother, her father (whose deposition was delayed as he filed a Motion to
            Quash that was denied earlier this month), several persons to whom the
            plaintiff reportedly communicated about the decedent's conduct and the
            personal representatives of the Estate.

        As grounds for this Motion the parties submit that this case involves allegations
of sexual abuse made by a grandchild against the estate of her now-deceased
grandfather. The alleged abuse occurred almost 20 years ago and the decedent died in
January 2022. These circumstances create significant discovery issues for the parties,
and although they have exchanged written discovery responses, the necessary
depositions have not been conducted. It is anticipated at least 6 depositions will be