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  • Watling, Richard H vs. Brannan-Nunez, Alexandra Other Tortious Action document preview
  • Watling, Richard H vs. Brannan-Nunez, Alexandra Other Tortious Action document preview
						
                                

Preview

as 16 145 4 COMMONWEALTH OF MASSACHUSETTS HAMPSHIRE, SS. DEPARTMENT OF THE TRIAL COURT SUPERIOR COURT DIVISION CIVIL ACTION #1680CV00145 RICHARD H. WATLING, Plaintiff v. ALEXANDRA BRANNAN-NUNEZ Defendant NOTICE OF MOTION TO DISMISS PURSUANT TO MASS. R. CIV. P. 12(b)(10) Now comes the Defendant, by her attorney, and pursuant to Mass. R. Civ. P.12(b)(10) move this Honorable Court to dismiss the above captioned matter for improper amount of damages in the Superior Court as set forth in M.G.L. ¢.212 §3. This Motion is being served and filed pursuant to Superior Court Rule 9A and Attorney Patrick M. Toney’s Affidavit of Compliance will be filed together with the complete motion package, once opposition, if any, has been served under Rule 9A. The grounds for this Motion to Dismiss are fully set out below. As Reason therefore, Defendant states as follows: Plaintiff claims the value of diamond ring allegedly converted for Defendant’s own use has been appraised for sixty thousand dollars and no cents ($60,000.00) and therefore seeks money damages in the amount of sixty thousand dollars and no cents ($60,000.00). The diamond ring allegedly converted for Defendant’s own use was purchased on January 17, 2016 in the amount of twenty three thousand dollars ($23,000.00). ‘Jal Oend yd De Clond4ts cyecrrh — _ HAMPSHIRESUPERO COURT R Qpads r Ne 3 renaSe For $0, 900 awe so shy of, F23,000 --7 42) 280-7 dares NOV 3 2016 TS OK PEASOL Ver edt Senet > Math A be T2S usw, HARRY JEKANOWSK(, JR, 4, recor lisp Te ar OYE CLERK/ MAGISTRATE (Ndon dS)