Order: Paul, Linda vs. Fern Realty Company, LLC et al

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                                  COMMONWEALTH OF MASSACHUSETTTS

             BRISTOL, SS                                                     SUPERIOR COURT
                                                                             CIVIL ACTION
                                                                             NO. BRCV 1673CV00614

XS           LINDA PAUL.
                                                                                       BRISTOL. SS SUPERIOR COURT
                                                                                                   FILED

xs
                    vs.

                                                                                                AUG - 4 2017
ki           FERN REALTY COMPANY, LLC;
             FAXON HEIGHTS REALTY COMPANY, LLC;                                           MARC J. SANTOS. ESQ.

S            BELRIDGE REALTY COMPANY, LLC;                                                 CLERK/MAGISTRATE
             JIANTOSCA REALTY COMPANY, LLC;
             and D.A.I. PROPERTY MANAGEMENT
             COMPANY, INC.

                 PLAINTIFF’S ASSENTED TO MOTION FOR THE ISSUANCE OF A
                          COMMISSION PURSUANT TO M.G.L.A. c. 223A,                        §10




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                    Now comes the plaintiff, and with the consent of defendants, hereby moves this

             honorable Court pursuant to M.G.L.A.          c. 223A,   §10, for an order directing that a

             Commission of this Court issue authorizing a notary public of the State of Rhode Island
x
             and Providence Plantations or such other individual authorized in Rhode                   Island to



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             administer an oath to Phillip Barrett, Manager              of Family     Sweeping,     LLC,      112

             Rosemere Road, Pawtucket, RI 02861, and to record stenographically and later produce

             in transcript form questions, answers, and other proceedings            of the deposition and to
Ss
v            make exhibits and make part of the records of the deposition the documents and materials

             specified in the subpoena to be issued.

                    As grounds therefore, plaintiff states that this is an action wherein plaintiff alleges

             personal injury against defendants resulting in severe and permanent injuries to the

             plaintiff. The   record(s) of Family      Sweeping,   LLC    contain    relevant     information to

             plaintiff's claims, and to defendants’ defense of those claims.
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           For the reasons set forth above, the parties hereby request that their motion be

    granted. A proposed order is attached hereto as Exhibit A.


                                                 Plaintiff, Linda Paul
                                                 By her Attorneys,



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                                                           ee
                                                 Peter J. CeriJJi      .B.O. 4079770)
                                                 FOLEYC              LI, P.C.
                                                 56 Pine Si       , Suite 200
                                                 Providence, RI 02903
                                                 Tel: (401) 272-7800
                                                 Fax: (401) 274-2780
                                                 E-mail:   peter@foleycerilli.com
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                        COMMONWEALTH            OF MASSACHUSETTTS

    BRISTOL, SS                                                 SUPERIOR COURT
                                                                CIVIL ACTION
                                                                NO. BRCV 1673CV00614

    LINDA PAUL

           vs.


    FERN REALTY COMPANY, LLC;
    FAXON HEIGHTS REALTY COMPANY, LLC;
    BELRIDGE REALTY COMPANY, LLC;
    IANTOSCA REALTY COMPANY, LLC;
    and D.A.I. PROPERTY MANAGEMENT
    COMPANY, INC.

                                        CERTIFICATION

           I hereby certify that a true and accurate copy of following document:

            Plaintiff's Assented to Motion for Issuance of Commission Pursuant to M.G.L.A.
                                            c. 223, $10
    was sent on this 2"4 day of August, 2017 to the following counsel of record:

    Martin S. Cosgrove, Esq.
    Cosgrove, Eisenberg and Kiley, PC
    803 Hancock Street



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    PO Box 189
    Quincy, MA 02170-0997