On October 17, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Woods, David A,
Woods, Kelly,
and
Aquadro & Cerruti, Inc.,
Daniel O' Connell'S Sons, Inc.,
Manafort Precision, Llc,
T & M Equipment Corporation,
T&M Equipment Corporation,
for Torts
in the District Court of Hampshire County.
Preview
46 167° 4
COMMONWEALTH OF MASSACHUSETTS
SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
HAMPSHIRE, ss. CIVIL ACTION NO. 1680CV00167
DAVID A. WOODS,
Plaintiff
Vv.
AQUADRO & CERRUTI, INC.,
Defendant
™ and
DANIEL O’CONNELL’S SONS, INC., HAMPSHIRE SUPERIOR COURT
Defendant and Third-Party Plaintiff
ON Vv.
JAN 17 2018
. MANAFORT PRECISION, LLC,
Third-Party Defendant
HARRY JEKANOWSKI, JR.
CLERK/MAGISTRATE
JOINT MOTION TO EXTEND TRACKING ORDER DEADLINES
Now come the parties in the above-referenced matter and hereby request this Honorable
Court to extend the tracking order deadlines in the above matter for six (6) months from the date
of this Court’s order.
I As grounds therefore, the parties state the following:
The discovery deadline under the current tracking order was August 14, 2017.
The parties in this action have been working diligently to complete written discovery and
depositions within the tracking order deadline.
The Third Amended Standing Order 1-88 of the Superior Court specifically allows for
amendments to the scheduling orders. Section D states that “[t]his Standing Order anticipates that
674073v. 1
N -
there will be instances when the designation of a case to a particular track is inappropriate or the
tracking deadlines cannot reasonably be met. The court recognizes that there are cases which by
their very nature require special tracking deadlines, and the system is sufficiently flexible to
accommodate these cases” upon motion and for good cause shown. Superior Court Standing Order
1-88, Section D (effective September 1, 2017). The parties respectfully submit that the current
matter requires such accommodation and that good cause exists to extend the tracking order
deadlines.
This is the parties’ first request for an extension of the tracking order deadlines.
The parties believe a six-month extension of the tracking order deadlines from the date of
this Court’s order would be an appropriate time frame to conduct the necessary pre-trial discovery
required in this case.
None of the parties will be prejudiced by the extension of the tracking order deadlines in
this case since a trial date has not been set.
WHEREFORE, the parties respectfully request that this Honorable Court extend the
tracking order deadlines for six (6) months from the date of this Court’s order.
674073v.1
x-
The Plaintiff, The Defendant.
DAVID A. WOODS DANIEL O0’CONNELL’S SONS, INC
By His Attorneys, By Its Attorneys.
laura@alekmanditusa.com jbagley@morrisonmahoney.com
Robert A. DiTusa, BBO #649218 Denise M. Tremblay, BBO #561238
ALEKMAN DITUSA, LLC dtremblay@morrisonmahoney.com
1550 Main Street, Suite 401 MORRISON MAHONEY LLP
Springfield, MA 01103 1500 Main Street, Suite 2400
Phone: 413-781-0000 Post Office Box 15387
Fax. 413-827-0266 Springfield, MA 01115-5387
Phone: 413-737-4373
Fax 413-739-3125
The Defendant, The Defendant,
AQUADRO & CERRUTI, INC. MANAFORT PRECISION, LLC
By Its Attorneys, By Its Attorneys,
LebrieDt VMGloce.
Patricia M. Vachereau, BBO sSseR”
tschuler@travelers.com patricia. vachereau-hassett@libertymutual.com
LAW OFFICES OF STEVEN B. STEIN SHERRY, GELLER, CAIN & VACHEREAU
P.O. Box 2903 1 Federal Street, Building 111-4
Hartford CT 06104-2903 Springfield, MA 01105
Phone: 413-730-6350 Phone: 413-788-0200
Fax 413-730-6361 Fax: 413-788-7526
Dated: January 10,2018
674073y.1
Document Filed Date
January 17, 2018
Case Filing Date
October 17, 2016
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