Motion,Ex Parte: Duda, M.D., Francis J. vs. Baystate Medical Practices, Inc. Formerly Known As Baystate Medical Education and Research Foundation, Inc.

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                                COMMONWEALTH OF MASSACHUSETTS

Hampden, ss. Superior Court Department
of the Trial Court
Civil Action No. 15-679

ffk/a BAYSTATE MEDICAL EDUCATION
AND RESEARCH FOUNDATION, INC.
Defendant

FRANCIS J. DUDA, M.D., )
Plaintiff )
)
vs. ) MOTION OF DEFENDANT FOR
) ADIRECTED VERDICT AT THE
BAYSTATE MEDICAL PRACTICES, INC., ) CLOSE OF ALL THE EVIDENCE
)
)
)

Defendant, Baystate Medical Practices, Inc., f/k/a Baystate Medical Education and
Research Foundation, Inc. (“BMP”), pursuant to Mass. R. Civ. P. 50(a), respectfully moves, at
the close of all the evidence that this Court direct a verdict in its favor on both claims asserted
against it on the grounds that plaintiff, Francis J. Duda, has failed to introduce evidence
sufficient to support either of his claims against BMP.

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Awe eh (o-/5 78 U4The Defendant

BAYSTATE MEDICAL PRACTICES,
INC. f/k/a BAYSTATE MEDICAL
EDUCATION AND RESEARCH
FOUNDATION, INC.

By Its Attorney:

—_—— .
One,
Dated: June 15, 2018 Mary J. Kennedy { BBO No. 552345

Jennifer K. Cannon — BBO No. 664431
Bulkley, Richardson and Gelinas, LLP
1500 Main Street - Suite 2700

P.O. Box 15507

Springfield, MA 01115

Tel: (413) 272-6242; Fax: (413) 272-6803
mkennedy@pbulkley.com
jcannon@bulkley.com

Certificate of Service

I, Jennifer K. Cannon, attorney for the defendant, Baystate Medical Practices, Inc., f/k/a
Baystate Medical Education and Research Foundation, Inc., in this above matter, hereby certify
that a true copy of the above document was served upon the attorney of record for each party by

hand on June 15, 2018.
—_— 5

Jennifer K. C: n

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