Hearing: 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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COMMONWEALTH OF MASSACHUSETS

ESSEX, SS SUPERIOR COURT

i
SABA HASHEM, individually, and as a
Member of, and derivatively on behalf of,
D’ANGELO and HASHEM, LILC.

Plaintiff Civil Action No. 16CV1419

v.

STEPHEN L. D’ANGELO, D/ANGELO

LAW GROUP, LLC, and DPANGELO

AND HASHEM, LLC.
Defendants

ee

DEFENDANT D’ANGELO LAW GROUP, LLC’S and
DEFENDANT STEPHEN D‘ANGELO’S POSITION STATEMENT,
MOTION FOR GUIDANCE, AND FOR OTHER RELIEF

 

NOW COMES, Defendants, through counsel and respectfully moves this Honorable
Court to Guidance regarding a/Motion for Trustee Process, to Reach and Apply, and Motion for
Attorney’s Fees served via mall per Superior Court Rule 9A on June 12, 2020, and was received
on June 15, 2020.

Intervenor Counsel’s Counsel has stated in Paragraph 20 (page 5) of her Emergency
Motion to Reach and Apply (styled as “for Trustee Process”), which is being heard Tuesday,
June 14, 2020 at 2 p.m. via Zoom teleconference, that she intends to file that Motion(s) with this
Court tomorrow, June 14, 2020. This comes as a surprise to Defendants Counsel, who has
reached out to Intervenor-Counsel about same without success. Defendants’ counsel believes
she is out of the country on petsonal matters.

Specifically, Defendants’ Counsel have emailed Counsel for Intervenor Plaintiff advising

its position that under Superior Court Standing Order 8-20, Section F, that an Opposition, which

 

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