Party Statement: Dias, Maria F vs. Torres, Milton C

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                           COMMONWEALTH OF MASSACHUSETTS

BRISTOL, ss.                                          SUPERIOR COURT DEPARTMENT
                                                      CANO.: 1673CV01211

MARIA F. DIAS,                                                                                    COURT
     Plaintiff                                                               BRISTOL. 8s SUPERIOR

Vv.                                                                                 SEP 1.0 2018
                                                                                                     Q.
MILTON C. TORRES,                                                                 MARC J. SANTOS. £S
                                                                                   CLERK/MAGISTRA TE
     Defendant

                    AFFIDAVIT OF COUNSEL IN ACCORDANCE                     WITH
                             SUPERIOR COURT RULE 9A

         I, Joseph A. Merlino, attorney for the Defendant, Milton C. Torres in this action, under
the pains and penalties of perjury depose and say that:

 1    lam an attorney licensed to practice law in the Commonwealth of Massachusetts and I am
      the attorney for defendant, Milton C. Torres.

      On August 27, 2018, a copy of the following Motions were served on the Plaintiff in
      accordance with Superior Court Rule 9A:

         e   Motion in Limine of the Defendant to Exclude Evidence and/or Reference to Liability
             Insurance of the Defendant;

             Motion in Limine of the Defendant to Preclude Plaintiff From Offering Any Opinion
             as to Cause of Heart Palpitations and Anxiety; and

             Motion in Limine of the Defendant to Preclude Plaintiff from Calling Anne Marie
             Treadup, M.D. as Expert Witness.

      On September 4, 2018, the defendant received the plaintiff's oppositions and supporting
      memoranda to Defendant’s Motion in Limine to Preclude Plaintiff from Offering Any
      Opinion as to Cause of Heart Palpitations and Anxiety and Motion in Limine of Defendant to
      Preclude Plaintiff From Calling Anne Marie Treadup, M.D. as Expert Witness.

      The defendant did not receive any opposition to his Motion in Limine to Exclude Evidence
      and/or Reference to Liability Insurance.

      The Motions and Oppositions are filed herewith according to Superior Court Rule 9A for the
      Court’s consideration.
6.   Copies of this Affidavit are being served on all parties of record in this action this day.




Ae
               th
        this 5 Nhothus,             2018.

      Ons   L
Joseph A? Merlino
COMMONWEALTH OF MASSACHUSETTS

BRISTOL, ss.                                           SUPERIOR COURT DEPARTMENT
                                                       CANO.: 1673CV01211

MARIA F. DIAS,
     Plaintiff

Vv.

MILTON C. TORRES,
     Defendant

                                       LIST OF 9A DOCUMENTS

           Motion in Limine of the Defendant to Exclude Evidence and/or Reference to Liability
           Insurance of the Defendant;

           Motion in Limine of the Defendant to Preclude Plaintiff From Offering Any Opinion as
           to Cause of Heart Palpitations and Anxiety;

           Motion in Limine of the Defendant to Preclude Plaintiff from Calling Anne Marie
           Treadup, M.D. as Expert Witness;

           Plaintiff's Opposition and Memorandum in Support of Opposition to Motion in Limine of
           the Defendant to Preclude Plaintiff from Offering Any Opinion as to cause of Heart
           Palpitations and Anxiety;

           Plaintiff's Opposition and Memorandum in Support of Opposition to Motion in Limine of
           the Defendant to Preclude Plaintiff from Calling Anne Marie Treadup, M.D., as Expert
           Witness;
                           ’
      6    Affidavit of Joseph A. Merlino in accordance with Superior Court Rule 9A; and

      7.   Certificate of Service.

Dated: September 5, 2018                               Defer ndant, Milton Torres
                                                       By     ‘S      attorne:




                                                            seph A.         erlino
                                                       BBO#: 648647
                                                       Mazzocca & Associates
                                                       211 Main Street
                                                       Webster, MA 01570
                                                       Telephone: (508) 949-4869
CERTIFICATE OF SERVICE

        I, Joseph A. Merlino, attorney for the above-named defendant, do hereby certify that I
caused a copy of the within Affidavit and List of Attached Documents to be served upon each
named party by mailing a copy of same, postage prepaid, to each party’s counsel of record,
namely:


Kathleen Horan McLean, Esquire
Law Offices of Horan, McLean & Associates
17 Orchard Street
New Bedford, MA     02740



Signed this 5“ day of September, 2018.




                                             Feat                     i
                                             Jostph A. Merlino, Esquire
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