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COMMONWEALTH OF MASSACHUSETTS
ESSEX, ss. SUPERIOR COURT DEPARTMENT
CIVIL ACTION NO.: 1677-CV-01587 A
PHILIP J. MAZZOLA, as
TRUSTEE OF THE SEVENTEEN
WINGAERSHEEK REALTY TRUST,
Plaintiff
Vv.
JOHN F. O’BRIEN, and
BONITA J. O'BRIEN,
Defendants
PARTIES’ JOINT MOTION TO EXTEND
DISCOVERY DEADLINE AND OTHER TRACKING ORDER DEADLINES
NOW COME the Parties, by and through their attorneys, and jointly move the Court to
extend the discovery deadline, as well as all other tracking order deadlines, two (2) months.
As grounds for this Motion, the Parties state the following:
(1) The discovery deadline is currently August 14, 2017. The Parties have exchanged
written discovery requests and responses to those requests. The Plaintiff has
provided supplemental responses to the Defendants’ requests for documents.
Q) The Defendants intend to notice the deposition of the Plaintiff for September 18,
2017. The Parties are communicating amicably about a convenient date to notice
the deposition of one or more of the Defendants.
GB) In order to allow the Parties’ counsel to fully prepare for and conduct said
depositions, the Parties request that the discovery deadline be extended two (2)
months to October 13, 2017 and that the other tracking order deadlines be extended
accordingly.
@) No trial date has been set for this Action and the requested extensions will not
Prejudice either Party.
WHEREFORE, the Parties respectfully request that the Court (1) extend the discovery
deadline two (2) months to October 13, 2017; and (2) extend the other tracking order deadlines
accordingly.
Respectfully submitted,
Philip J. Mi la, Trustee,
By his attorn Sy
William H. hheehan III, BBO #457060
Alex J. Hartington, BBO #693512
MacLean Hi lloway Doherty & Sheehan, P.C
8 Essex Center Drive
Peabody, MA 01960
(978) 774-7123
wsheehan@mbhdpc.com
aharrington@mhdpc.com
Respectfully submitted,
John F. O’Brien and Bonita J. O’Brien,
By their attorney,
Pore? wes
Mus I”
Meredith Fine, BBO #669248
46 Middle Street, Suite 2
Gloucester, MA 01930
(978) 515-7224
m eredith@attorneymeredithfine.com
Dated: August ' , 2017
CERTIFICATE OF SERVICE
I, Alex Hartington, attorney for Philip J. Mazzola, hereby certify that I have served a copy of the above
document upon all parties or counsel of record, by electronic mail and by mailing the same, first class mail, postage
prepaid, to the following attorneys:
Meredith A. Fine, Esq.
Law Office of Meredith A. Fine
46 Middle Street, Suite 2
Gloucester, MA 01930
Alex Haringt in
Dated: August >t 52017
MACLEAN HOLLOWAY
’ DOHERTY & SHEEHAN, P.C.
ATTORNEYS AT LAW
8 Essex CENTER DRIVE, PEABODY, MA 01960
TEL: (978) 774-7123 FAX (978) 774-7164
wivw.mhdpc.com
ALEX J. HARRINGTON
Direct Dial: (978) 762-5866
Email: ahastington@mbdpe.com
August 1, 2017
Essex County Superior Court — Salem
Office of the Civil Clerk
56 Federal Street
Salem, MA 01970
Re: Mazzola v. O’Brien et ux.
Docket No.: 1677-CV-01587
Dear Sir or Madam:
Enclosed for filing, please find the following document:
Parties’ Joint Motion to Extend Discovery Deadline and Other Tracking Order Deadlines.
Thank you for your attention.
Very tru Ours,
th Alex J. ington
co: Meredith Fine, Esq.
Preview
la COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. SUPERIOR COURT DEPARTMENT CIVIL ACTION NO.: 1677-CV-01587 A PHILIP J. MAZZOLA, as TRUSTEE OF THE SEVENTEEN WINGAERSHEEK REALTY TRUST, Plaintiff Vv. JOHN F. O’BRIEN, and BONITA J. O'BRIEN, Defendants PARTIES’ JOINT MOTION TO EXTEND DISCOVERY DEADLINE AND OTHER TRACKING ORDER DEADLINES NOW COME the Parties, by and through their attorneys, and jointly move the Court to extend the discovery deadline, as well as all other tracking order deadlines, two (2) months. As grounds for this Motion, the Parties state the following: (1) The discovery deadline is currently August 14, 2017. The Parties have exchanged written discovery requests and responses to those requests. The Plaintiff has provided supplemental responses to the Defendants’ requests for documents. Q) The Defendants intend to notice the deposition of the Plaintiff for September 18, 2017. The Parties are communicating amicably about a convenient date to notice the deposition of one or more of the Defendants. GB) In order to allow the Parties’ counsel to fully prepare for and conduct said depositions, the Parties request that the discovery deadline be extended two (2) months to October 13, 2017 and that the other tracking order deadlines be extended accordingly. @) No trial date has been set for this Action and the requested extensions will not Prejudice either Party. WHEREFORE, the Parties respectfully request that the Court (1) extend the discovery deadline two (2) months to October 13, 2017; and (2) extend the other tracking order deadlines accordingly. Respectfully submitted, Philip J. Mi la, Trustee, By his attorn Sy William H. hheehan III, BBO #457060 Alex J. Hartington, BBO #693512 MacLean Hi lloway Doherty & Sheehan, P.C 8 Essex Center Drive Peabody, MA 01960 (978) 774-7123 wsheehan@mbhdpc.com aharrington@mhdpc.com Respectfully submitted, John F. O’Brien and Bonita J. O’Brien, By their attorney, Pore? wes Mus I” Meredith Fine, BBO #669248 46 Middle Street, Suite 2 Gloucester, MA 01930 (978) 515-7224 m eredith@attorneymeredithfine.com Dated: August ' , 2017 CERTIFICATE OF SERVICE I, Alex Hartington, attorney for Philip J. Mazzola, hereby certify that I have served a copy of the above document upon all parties or counsel of record, by electronic mail and by mailing the same, first class mail, postage prepaid, to the following attorneys: Meredith A. Fine, Esq. Law Office of Meredith A. Fine 46 Middle Street, Suite 2 Gloucester, MA 01930 Alex Haringt in Dated: August >t 52017 MACLEAN HOLLOWAY ’ DOHERTY & SHEEHAN, P.C. ATTORNEYS AT LAW 8 Essex CENTER DRIVE, PEABODY, MA 01960 TEL: (978) 774-7123 FAX (978) 774-7164 wivw.mhdpc.com ALEX J. HARRINGTON Direct Dial: (978) 762-5866 Email: ahastington@mbdpe.com August 1, 2017 Essex County Superior Court — Salem Office of the Civil Clerk 56 Federal Street Salem, MA 01970 Re: Mazzola v. O’Brien et ux. Docket No.: 1677-CV-01587 Dear Sir or Madam: Enclosed for filing, please find the following document: Parties’ Joint Motion to Extend Discovery Deadline and Other Tracking Order Deadlines. Thank you for your attention. Very tru Ours, th Alex J. ington co: Meredith Fine, Esq.