Saba Hashem Individually and as a member of And derivatively on behalf of D'Angelo and Hashem, LLC's Memorandum in support of Motion To Compel Disclosure And Discovery (filed 1/28/2019) - Saba Hashem Individually and as a member of And derivatively on behalf of D'Angelo and Hashem, LLC vs. D'Angelo, Stephen L. et al

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On September 16, 2016 an accounting case was filed by Carrion, Jennifer M, and Hashem, Saba, represented by Farrah, Jr., Esq., Albert L, Kaplan, Esq., Wendy Anne, Pro Se, and Rivera-Bujosa, Esq., Mernaysa, against D'Angelo And Hashem, Llc, D'Angelo Law Group Llc And Nominally, D'Angelo And Hashem, Llc, and D'Angelo, Stephen L., represented by Amann, Esq., William James, Andrade, Esq., Matthew, Cossingham, Esq., Kenneth, D'Angelo, Esq., Stephen Lawrence, and Laporte, Esq., Thomas C, in the jurisdiction of Essex County. Judge Timothy Q. Feeley presiding.

                        
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                          Case 1:16-cv-12383-IT Document 36 Filed 07/25/17 Page 1 of 4

VOTH NOLHY FE Zl
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UNITED STATES DISTRICT COURT

 

DISTRICT OF MASSACHUSETTS
EASTERN DIVISION

)
Saba Hashem, Individually, and as a )
Member of, and derivatively on behalf of, )
D’Angelo and Hashem, LLC )
)
Plaintiff y

Vv. ) Civil Action No: 1:16-cv-12383-IT
)
Stephen L. D’Angelo, )
D’ Angelo and Hashem, LLC )
and D’Angelo Law Group LLC )
)
Defendants )
)

 

PLAINTIFF’S MEMORANDUM IN SUPPORT OF MOTION TO COMPEL
DISCLOSURE AND DISCOVERY

Plaintiff Saba Hashem, individually and as a member of, and derivatively on behalf of,
D’Angelo and Hashem, LLC, pursuant to the provisions of Fed. R. Civ. P. 37(a) and Mass. Fed.
Dist. Ct. Local Rule 37.1, seeks an order compelling defendants Stephen L. D’Angelo, D’ Angelo
and Hashem, LLC and D’Angelo Law Group LLC to make their respective mandatory disclo-
sures as required by Fed. R. Civ. P, 26(a) and Local Rule 26,2(a), and an order compelling Mr.
D’Angelo to respond to discovery re…