On September 19, 2016 a
Order
was filed
involving a dispute between
Gifford, Karisa M,
Gifford, Ryan,
and
Abraham, Ellen,
Burning Heart Llc,
Stempel, Ashli V,
for Torts
in the District Court of Hampshire County.
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46 153
§ COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT DEPARTMENT
HAMPSHIRE, ss. OF THE TRIAL COURT
a CIVIL ACTION NO.1680CV00153
KARISA M. GIFFORD, RYAN GIFFORD,
ir RYAN A. GIFFORD, p.p.a. Ryan Gifford,
GRAYDEN GIFFORD, p.p.a. Ryan Gifford, and
)
.
& CALLI GIFFORD, p.p.a. Ryan Gifford, Plaintiffs)
)
v. )
DS )
)
)
)
)
AUG 2 8 2917
os
% BURNING HEART, LLC, d.b.a. Burning Heart
~ Hot Yoga Pilates & Indoor Cycling, ELLEN
g Og ABRAHAM, and ASHLI V. STEMPEL,
Defendants.
PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER
A> NOW COME the plaintiffs (“Plaintiffs”) in the above-captioned matter, and hereby move
Court for an order that the depositions of the Plaintiffs’ minor children noticed by the
Defendants for August 29, 2017 not be taken. (Copies of the deposition notices are attached as
FACTS
{ Exhibit A.) As grounds in support thereof, the Plaintiffs state as follows.
The Plaintiff Karisa M. Gifford (“Karisa”) was severely injured while participating in a
IQ spinning class at the gym owned and operated by the defendant Burning Heart, LLC (the
“Gym”) on November 19, 2013. The Defendant Ellen Abraham was the manager of the Gym
and Defendant Ashli Stempel was the spinning class instructor, The Plaintiff, together with her
husband and minor children, filed suit on September 19, 2016, seeking compensation for the
damages they suffered as a result of the Gym’s negligence.
Interrogatories and document requests were propounded by the Defendants to all the
Plaintiffs and responses have been served. As described in her Answers to Interrogatories
(Exhibit B, attached hereto), Karisa, the mother, had not previously taken a spinning class. At
/0 Ph? oc. (odes
Oe Cha
Ottets~ Bde lod oq BSL, Se 3
Nbr
4u V18/)7 APM. ~
Document Filed Date
October 24, 2017
Case Filing Date
September 19, 2016
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| /0 46 153 § COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT DEPARTMENT HAMPSHIRE, ss. OF THE TRIAL COURT a CIVIL ACTION NO.1680CV00153 KARISA M. GIFFORD, RYAN GIFFORD, ir RYAN A. GIFFORD, p.p.a. Ryan Gifford, GRAYDEN GIFFORD, p.p.a. Ryan Gifford, and ) . & CALLI GIFFORD, p.p.a. Ryan Gifford, Plaintiffs) ) v. ) DS ) ) ) ) ) AUG 2 8 2917 os % BURNING HEART, LLC, d.b.a. Burning Heart ~ Hot Yoga Pilates & Indoor Cycling, ELLEN g Og ABRAHAM, and ASHLI V. STEMPEL, Defendants. PLAINTIFFS’ MOTION FOR PROTECTIVE ORDER A> NOW COME the plaintiffs (“Plaintiffs”) in the above-captioned matter, and hereby move Court for an order that the depositions of the Plaintiffs’ minor children noticed by the Defendants for August 29, 2017 not be taken. (Copies of the deposition notices are attached as FACTS { Exhibit A.) As grounds in support thereof, the Plaintiffs state as follows. The Plaintiff Karisa M. Gifford (“Karisa”) was severely injured while participating in a IQ spinning class at the gym owned and operated by the defendant Burning Heart, LLC (the “Gym”) on November 19, 2013. The Defendant Ellen Abraham was the manager of the Gym and Defendant Ashli Stempel was the spinning class instructor, The Plaintiff, together with her husband and minor children, filed suit on September 19, 2016, seeking compensation for the damages they suffered as a result of the Gym’s negligence. Interrogatories and document requests were propounded by the Defendants to all the Plaintiffs and responses have been served. As described in her Answers to Interrogatories (Exhibit B, attached hereto), Karisa, the mother, had not previously taken a spinning class. At /0 Ph? oc. (odes Oe Cha Ottets~ Bde lod oq BSL, Se 3 Nbr 4u V18/)7 APM. ~