On June 29, 2017 a
Motion-Secondary
was filed
involving a dispute between
Gilbert, Jennifer Lee,
and
Allard'S Farms, Inc.,
for Torts
in the District Court of Hampshire County.
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af
i? 106
COMMONWEALTH OF MASSACHUSETTS
SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
HAMPSHIRE, ss. CIVIL ACTION NO. 1780CV00106
JENNIFER LEE GILBERT,
Plaintiff HAMPSHIRE SUPERIOR COURT
Vv.
MAY 24 2018
ALLARD’S FARMS, INC.,
Defendant HARRY JEKANOWSKI, JR.
CLERK/MAGISTRATE
DEFENDANT, ALLARD FARMS, INC.’S MOTION FOR ORDER TO INSPECT
STATUTORILY PROTECTED MEDICAL AND PSYCHOLOGICAL RECORDS OF
THE PLAINTIFF, JENNIFER LEE GILBERT
NOW COMES the defendant, Allard Farms, Inc., by and through their attorneys and
respectfully moves this Honorable Court to grant an order to inspect the complete medical and ,
psychological records of Maryann Paleologopoulos, LICSW, including, but not limited to, any
records pertaining to psychiatric notes, and social service consultations kept pursuant to M.G.L.
c. 112, §135 (social workers); M.G.L. c. 233, §20B (psychotherapists); 21 U.S.C., §1175; and 42
U.S.C., §4582 (drug and alcohol abuse); and any other records that may be kept under the
Department of Mental Health relative to the plaintiff, Jennifer Lee Gilbert (DOB: 9/9/1990), and
that copics of all records be furnished on payment of a reasonable fee therefor.
WHEREFORE, the defendant, Allard Farms, Inc., respectfully requests this Honorable
Court grant an order to inspect medical and psychological records from Maryann Paleologopoulos,
LICSW. The defendant references and incorporates by reference the accompanying Memorandum
in Support of this motion as grounds for the instant motion.
Nout aan Wu baud © Sebel arcal,
ane Ah : paial Xs cg mM
Spa ke
682584v.1
Document Filed Date
May 24, 2018
Case Filing Date
June 29, 2017
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” ie af i? 106 COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT HAMPSHIRE, ss. CIVIL ACTION NO. 1780CV00106 JENNIFER LEE GILBERT, Plaintiff HAMPSHIRE SUPERIOR COURT Vv. MAY 24 2018 ALLARD’S FARMS, INC., Defendant HARRY JEKANOWSKI, JR. CLERK/MAGISTRATE DEFENDANT, ALLARD FARMS, INC.’S MOTION FOR ORDER TO INSPECT STATUTORILY PROTECTED MEDICAL AND PSYCHOLOGICAL RECORDS OF THE PLAINTIFF, JENNIFER LEE GILBERT NOW COMES the defendant, Allard Farms, Inc., by and through their attorneys and respectfully moves this Honorable Court to grant an order to inspect the complete medical and , psychological records of Maryann Paleologopoulos, LICSW, including, but not limited to, any records pertaining to psychiatric notes, and social service consultations kept pursuant to M.G.L. c. 112, §135 (social workers); M.G.L. c. 233, §20B (psychotherapists); 21 U.S.C., §1175; and 42 U.S.C., §4582 (drug and alcohol abuse); and any other records that may be kept under the Department of Mental Health relative to the plaintiff, Jennifer Lee Gilbert (DOB: 9/9/1990), and that copics of all records be furnished on payment of a reasonable fee therefor. WHEREFORE, the defendant, Allard Farms, Inc., respectfully requests this Honorable Court grant an order to inspect medical and psychological records from Maryann Paleologopoulos, LICSW. The defendant references and incorporates by reference the accompanying Memorandum in Support of this motion as grounds for the instant motion. Nout aan Wu baud © Sebel arcal, ane Ah : paial Xs cg mM Spa ke 682584v.1