On August 31, 2016 a
Order
was filed
involving a dispute between
Watling, Richard H,
and
Brannan-Nunez, Alexandra,
for Torts
in the District Court of Hampshire County.
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)
Document Filed Date
January 10, 2017
Case Filing Date
August 31, 2016
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