On June 05, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Stevens, Robert C.,
and
Commerce Insurance Company,
for Torts
in the District Court of Hampshire County.
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Rs y-
COMMONWEALTH OF MASSACHUSETTS
47 093
HAMPSHIRE, SS SUPERIOR COURT DEPARTMENT
Docket No. 1780CV00093
ROBERT STEVENS, HAMPSHIRE SUPERIOR
Plaintiff, COURT
Vv. JUN 1 4 2018
COMMERCE INSURANCE COMPANY,
HARRY JEKANOWSKI, JR.
Defendant
CLERK/MAGISTRATE
ASSENTED TO MOTION TO ENLARGE DISCOVERY
Now come counsel for the respective parties and hereby jointly move to enlarge the time for
discovery by 60 days to August 31, 2018 and enlarge the tracking order accordingly. In support
thereof, the parties submit the following:
1 A 30(b)(6) deposition was conducted but not completed and has been continued by
agreement of counsel for the parties.
2 Plaintiff’s counsel received voluminous documents, over 1800 pages, from defendant
with some redactions.
3 Defense counsel has served a Motion for Protective Order Pursuant to 9A related to
some of the documents.
4 The parties wish to complete additional discovery and due to summer schedules may
require brief additional time.
5 The discovery deadline is currently July 2, 2018 and the parties are requesting an
additional 60 days to August 31 2018 to complete discovery in this matter.
Ww
MAY
me a
ms,
NA
WHEREFORE, the partics respectfully request the Court enlarge the time for discovery in
this matter by 60 days to August 31, 2018 and enlarge the tracking order accordingly.
, Respectfully submitted,
Respectfully submitted COMMERCE INSURANCE COMPANY,
ROBERT C. STEVENS, The Defendant,
The Plaintiff, By Its Attorney,
By His Attomeys,
y
Shinpsow Hubha
50) Stimpson B. Hubbard, Esq. (B
s, Bs a. @ BO NC5360 Finnegan, Underwood, Rya
n & Tiemey
Stella Ke nt he ko RO 9. 315870)
i c h a e l M a l k o v ich, Esq. 101 Federal Street, Suite
1900
‘Wi ie Boston, MA 02110
& Malkov
Kanth aks - Suite Tel. (617) 342-7035
43 Center 060
ypto!
gh-2764
Teh (413) ® 0 (ls _—_
___—
Date:_—YI
wll
pate ClR he =
\\
\
\
Document Filed Date
June 14, 2018
Case Filing Date
June 05, 2017
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Rs y- COMMONWEALTH OF MASSACHUSETTS 47 093 HAMPSHIRE, SS SUPERIOR COURT DEPARTMENT Docket No. 1780CV00093 ROBERT STEVENS, HAMPSHIRE SUPERIOR Plaintiff, COURT Vv. JUN 1 4 2018 COMMERCE INSURANCE COMPANY, HARRY JEKANOWSKI, JR. Defendant CLERK/MAGISTRATE ASSENTED TO MOTION TO ENLARGE DISCOVERY Now come counsel for the respective parties and hereby jointly move to enlarge the time for discovery by 60 days to August 31, 2018 and enlarge the tracking order accordingly. In support thereof, the parties submit the following: 1 A 30(b)(6) deposition was conducted but not completed and has been continued by agreement of counsel for the parties. 2 Plaintiff’s counsel received voluminous documents, over 1800 pages, from defendant with some redactions. 3 Defense counsel has served a Motion for Protective Order Pursuant to 9A related to some of the documents. 4 The parties wish to complete additional discovery and due to summer schedules may require brief additional time. 5 The discovery deadline is currently July 2, 2018 and the parties are requesting an additional 60 days to August 31 2018 to complete discovery in this matter. Ww MAY me a ms, NA WHEREFORE, the partics respectfully request the Court enlarge the time for discovery in this matter by 60 days to August 31, 2018 and enlarge the tracking order accordingly. , Respectfully submitted, Respectfully submitted COMMERCE INSURANCE COMPANY, ROBERT C. STEVENS, The Defendant, The Plaintiff, By Its Attorney, By His Attomeys, y Shinpsow Hubha 50) Stimpson B. Hubbard, Esq. (B s, Bs a. @ BO NC5360 Finnegan, Underwood, Rya n & Tiemey Stella Ke nt he ko RO 9. 315870) i c h a e l M a l k o v ich, Esq. 101 Federal Street, Suite 1900 ‘Wi ie Boston, MA 02110 & Malkov Kanth aks - Suite Tel. (617) 342-7035 43 Center 060 ypto! gh-2764 Teh (413) ® 0 (ls _—_ ___— Date:_—YI wll pate ClR he = \\ \ \