Commerce Insurance Company's Memorandum in support of Commerce Insurance Company's motion for protective order.

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On June 5, 2017 an other tortious action case was filed by Stevens, Robert C., represented by Malkovich, Esq., Michael G, and Xanthakos, Esq., Stella Electra, against Commerce Insurance Company, represented by Hubbard, Esq., Stimpson B, and Tierney, Esq., Philip T, in the jurisdiction of Hampshire County. Judge Richard J. Carey presiding.

                        
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                          COMMONWEALTH OF MASSACHUSETTS

HAMPSHIRE, SS.                                                   SUPERIOR COURT
                                                                 C.A.NO: 1780CV00093

ROBERT STEVENS,

        Plaintiff                                                HAMPSHIRE SUPERIOR COURT
VS.
                                                                            JUN 2 8 2018
COMMERCE INSURANCE COMPANY,
                                                                      HARRY JEKANOWSKI, JR.
        Defendant                                                       CLERK/MAGISTRATE

             MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT
      COMMERCE INSURANCE COMPANY’S MOTION FOR PROTECTIVE ORDER

        Now comes the defendant Commerce Insurance Company and respectfully requests this

Honorable Court issue an Order protecting the defendant from the plaintiffs request to produce

certain documents at a deposition, and to protect the de…