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  • 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 Accounting document preview
  • 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 Accounting document preview
						
                                

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. 4) | A COMMONWEALTH OF MASSACHUSETTS ESSEX, SS : SUPERIOR COURT C.A. No, 1667CV01419 | 1-27-2020 1 ‘ SABA HASHEM, individual and as Manager of D’Angelo & Hashem, LLC Plaintiff/Defendant-Intervenor v. STEPHEN D’ANGELO, individually and as a Manager of D’Angelo & Hashem, LLC, and D’Angelo Law Group, LLC, Defendants/Defendant Intervenor, Reach and Apply Defendant, v. JENNIFER M. CARRION, Plaintiff-Intervenor. SJ. 12/2020 lewadunan / Caste, tured viaema PLAINTIFF-INTERVENOR’S EMERGENCY MOTION TO EXTEND RESPONSE DATE TO PROCEDURAL ORDER RE PLAINTIFF-INTERVENOR’S PETITION FOR ATTO) YS FEES AND COSTS, DATED 11/16/2020 h NOW COMES the Plaintiff-Intervenor, Jennifer M. Carrion, who hereby through So ounse, respectfully requests that this Honorable Court extend time by one week to respond to Honorable Judge Deakin’s Order, dated November 16, 2020 and sent via email on November 18, 2020, from today, November 27, 2020 (Day after Thanksgiving) to Friday, December 4, 2020. As Grounds Therefore, Counsel for Plaintiff-Intervenor is out of state for the Thanksgiving holiday until December 2, 2020 without access to Ms. Carrion’s voluminous files. Further, Ms. Carrion submits that granting brief extension would cause little to no prejudice to Brother counsels, or alternatively any prejudice caused to brothers’ counsels, if any, would be vastly outweighed by prejudice to Ms. Carrion.