On December 24, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Granger, Charlotte,
and
Trinity Health Of New England Corporation, Inc.,
for Equitable Remedies
in the District Court of Hampden County.
Preview
\ COMMONWEALTH OF MASSACHUSETTS
HAMPDEN. SS. SUPERIOR COURT
DEPARTMENT
CIVIL ACTIONNO.: 23 OS84
CHARLOTTE GRANGER,
Plaintiff Hamp, D
SUPERIN, Couns
v. FILE ROK °
TRINITY HEALTH OF NEW ENGLAND DEC 24 2
CORPORATION, INC. a
Defendant ee Fag
VERIFIED PETITION FOR AN ORDER TO CONDUCT DISCOVERY
Application
I, Charlotte Granger, hereby depose and state that this Petition is being brought in order
to perpetuate review essential to a potential tort claim; that I retained Dunn & Phillips, P.C. to
investigate a personal injury tort claim, and that I have requested records and documents from ,
Trinity Health of New England Corporation, Inc., which owns the facility in which I sustained a
person injury on May 6, 2020, Mercy Medical Center.
The records identified herein have been requested from Trinity Health of New England
Corporation, Inc. and Mercy Medical Center, but, to date, have not been produced, including but
not limited to documents relating to Mercy Medical Center’s Policies and Procedures, including
all guidelines for the facility’s fall policy, guidelines for high fall risk, and a copy of the facility’s
fall risk tool used, scoring outlined, and a copy of the incident report, variance report, or
occurrence report for the fall sustained on May 6, 2020. I reasonably believe that I have a viable
12-94-2020 ny acRin . Ms Grarpu mprerted trnrel,
SS [Zi st 2e2 eo ‘y 4
we
Any gvel mehr mecther waeta by wound, bon RLGA, why
pha th Oc hadect:
Adel 3
Document Filed Date
January 08, 2021
Case Filing Date
December 24, 2020
Category
Equitable Remedies
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\ COMMONWEALTH OF MASSACHUSETTS HAMPDEN. SS. SUPERIOR COURT DEPARTMENT CIVIL ACTIONNO.: 23 OS84 CHARLOTTE GRANGER, Plaintiff Hamp, D SUPERIN, Couns v. FILE ROK ° TRINITY HEALTH OF NEW ENGLAND DEC 24 2 CORPORATION, INC. a Defendant ee Fag VERIFIED PETITION FOR AN ORDER TO CONDUCT DISCOVERY Application I, Charlotte Granger, hereby depose and state that this Petition is being brought in order to perpetuate review essential to a potential tort claim; that I retained Dunn & Phillips, P.C. to investigate a personal injury tort claim, and that I have requested records and documents from , Trinity Health of New England Corporation, Inc., which owns the facility in which I sustained a person injury on May 6, 2020, Mercy Medical Center. The records identified herein have been requested from Trinity Health of New England Corporation, Inc. and Mercy Medical Center, but, to date, have not been produced, including but not limited to documents relating to Mercy Medical Center’s Policies and Procedures, including all guidelines for the facility’s fall policy, guidelines for high fall risk, and a copy of the facility’s fall risk tool used, scoring outlined, and a copy of the incident report, variance report, or occurrence report for the fall sustained on May 6, 2020. I reasonably believe that I have a viable 12-94-2020 ny acRin . Ms Grarpu mprerted trnrel, SS [Zi st 2e2 eo ‘y 4 we Any gvel mehr mecther waeta by wound, bon RLGA, why pha th Oc hadect: Adel 3