On June 05, 2017 a
Order
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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IIJIH]I8 De MEMO OF LELISION Ha LIGeI “5. DY the Loum (Liatey, J.) AHESt: Ras ‘
KA Oli
a7 083 7]
COMMONWEALTH OF MASSACHUSETTS
HAMPSHIRE, SS. SUPERIOR COURT
: C.A.NO: 1780CV00093
ROBERT STEVENS, } HAMPSHIRE SUPERIOR COURT
Plaintiff )
) JUN 2 8 2018
VS. )
) HARRY JEKANOWSKI, JR.
COMMERCE INSURANCE COMPANY, ) CLERK/MAGISTRATE
)
Defendant )
MOTION OF DEFENDANT
COMMERCE INSURANCE COMPANY FOR PROTECTIVE ORDER
Now comes the defendant Commerce Insurance Company and respectfully requests this
Honorable Court issue an Order protecting the defendant from the plaintiff's request to produce
certain documents at a deposition, and to protect the defendant from inquiry of information at
deposition, that are privileged and/or wholly irrelevant to any issue in this case. Specifically, the
plaintiff has noticed the deposition of Commerce Insurance Company pursuant to Massachusetts
Rule of Civil Procedure 30(b)(6). The plaintiff in the deposition notice identifies certain topics
of inquiry, and has requested the production of certain documents, that constitute privileged
attorney- client communications and/or were prepared in anticipation of litigation.
Additionally, the plaintiff is seeking information and documents at the deposition that
relate to claim files other than the claim file that is the subject of this action in which the plaintiff
alleges violations of General Laws c. 93A/176D. Any such claim files are irrelevant, immaterial,
not reasonably calculated to lead to the discovery of admissible evidence at trial.
Document Filed Date
November 14, 2018
Case Filing Date
June 05, 2017
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IIJIH]I8 De MEMO OF LELISION Ha LIGeI “5. DY the Loum (Liatey, J.) AHESt: Ras ‘ KA Oli a7 083 7] COMMONWEALTH OF MASSACHUSETTS HAMPSHIRE, SS. SUPERIOR COURT : C.A.NO: 1780CV00093 ROBERT STEVENS, } HAMPSHIRE SUPERIOR COURT Plaintiff ) ) JUN 2 8 2018 VS. ) ) HARRY JEKANOWSKI, JR. COMMERCE INSURANCE COMPANY, ) CLERK/MAGISTRATE ) Defendant ) MOTION OF DEFENDANT COMMERCE INSURANCE COMPANY FOR PROTECTIVE ORDER Now comes the defendant Commerce Insurance Company and respectfully requests this Honorable Court issue an Order protecting the defendant from the plaintiff's request to produce certain documents at a deposition, and to protect the defendant from inquiry of information at deposition, that are privileged and/or wholly irrelevant to any issue in this case. Specifically, the plaintiff has noticed the deposition of Commerce Insurance Company pursuant to Massachusetts Rule of Civil Procedure 30(b)(6). The plaintiff in the deposition notice identifies certain topics of inquiry, and has requested the production of certain documents, that constitute privileged attorney- client communications and/or were prepared in anticipation of litigation. Additionally, the plaintiff is seeking information and documents at the deposition that relate to claim files other than the claim file that is the subject of this action in which the plaintiff alleges violations of General Laws c. 93A/176D. Any such claim files are irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence at trial.