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EQ)
COMMONWEALTH OF MASSACHUSETTS BRISTOL. SS SUPERIOR COURT
, SUPERIOR COURT FILED
Nov #2 2020
BRISTOL, SS.
MARC J SANTOS, ESQ.
George French and CLERK/MAGISTRATE
Theresa French
Plaintiffs,
ve
C.A.No. 1773CV00974
Government Employees Insurance Co.
d/b/a GEICO
Defendant.
EMERGENCY MOTION TO CONTINUE HEARING
Plaintiff, George and Theresa French, respectfully request
that the Hearing scheduled for November is, 2020 Bt. 2:00 P.m, at
the Bristol County Superior Court — New Bedford be continued to
another date and time that the Court deems appropriate.
As grounds for the continuance, Pro Se Plaintiffs state as
follows:
1, On October 6, 2020, an Order entered granting the Motion
to Withdraw as Counsel filed by attorneys representing Plaintiffs.
2. On October 6, 2020, ‘contact information was shared
between Pro Se Plaintiffs and counsel for Geico, Ronald Harding,
Esq.
3. Sometime during the week of October 12, 2020, Plaintiff,
Theresa French, contacted Attorney Harding to discuss the draftingof the pretrial memorandum and requested certain documents for
Plaintiffs’ file,
4, On October 19, 2020, Attorney Harding responded via
email with copies of documents: and offered to draft the pretrial
memorandum and forward to Plaintiffs.
5S. On November 3, 2020, Plaintiffs had not received the
draft pretrial memorandum as offered, and forwarded an email to
Attorney Harding requesting a JOINT MOTION TO CONTINUE THE PRETRIAL
HEARING in order to discuss a potential settlement, stating that,
in the alternative, if Defendant is not amenable to settlement
negotiations, Plaintiffs will look for the draft pretrial
memorandum.
6. On November 3, 2020, Attorney Harding responded to
Plaintiffs’ email stating that Geico would not agree to a motion
to continue under the circumstances because Geico made a $16,000
offer six (6) months ago. That offer has a deadline of November
16, 2020; Geico wilt consider the offer rejected if Plaintiffs do
not respond by the deadline.
7. ‘On November 11, 2020, Plaintiffs received a draft copy
of Defendant, Geico’s draft pretrial memorandum. While Plaintiffs
appreciate Defendant's offer to draft the pretrial memorandum,
after review of same, it “appears that the memorandum is strongly
advantageous for Defendants and Plaintiffs find themselves at a
disadvantage without legal assistance, Plaintiffs spent theentire ‘evening and all morning attempting to complete the pretrial
memorandum given the time constraints and with just a few days
until the November 16, 2020 hearing.
8. On November 12, 2020, Plaintiffs contacted the Clerk’s
office for filing information.
Plaintiffs would like to respectfully request an Emergency
Motion to Continue Hearing as Plaintiffs will need more time to
seek counsel to assist with the pending matter befere the Court.
Wherefore, Plaintiffs, George and Theresa French, pray that
this Honorable Court grant their Emergency Moticn to Continue
Hearing to a new date and time that the Couxt deems appropriate.
November 12, 2020 Respectfully submitted,
Pro Se Plaintiff;
pap LEDS Les fe
George R. French
1685 Fall River. Ave.
Seekonk, MA 02771
508.336.3257
“hgonstreect@dol'c
Sellttswatn fer
Theresa S. French
1685 Fall River Ave,
Seekonk, MA 02771
508.336.3257 -
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EQ) COMMONWEALTH OF MASSACHUSETTS BRISTOL. SS SUPERIOR COURT , SUPERIOR COURT FILED Nov #2 2020 BRISTOL, SS. MARC J SANTOS, ESQ. George French and CLERK/MAGISTRATE Theresa French Plaintiffs, ve C.A.No. 1773CV00974 Government Employees Insurance Co. d/b/a GEICO Defendant. EMERGENCY MOTION TO CONTINUE HEARING Plaintiff, George and Theresa French, respectfully request that the Hearing scheduled for November is, 2020 Bt. 2:00 P.m, at the Bristol County Superior Court — New Bedford be continued to another date and time that the Court deems appropriate. As grounds for the continuance, Pro Se Plaintiffs state as follows: 1, On October 6, 2020, an Order entered granting the Motion to Withdraw as Counsel filed by attorneys representing Plaintiffs. 2. On October 6, 2020, ‘contact information was shared between Pro Se Plaintiffs and counsel for Geico, Ronald Harding, Esq. 3. Sometime during the week of October 12, 2020, Plaintiff, Theresa French, contacted Attorney Harding to discuss the draftingof the pretrial memorandum and requested certain documents for Plaintiffs’ file, 4, On October 19, 2020, Attorney Harding responded via email with copies of documents: and offered to draft the pretrial memorandum and forward to Plaintiffs. 5S. On November 3, 2020, Plaintiffs had not received the draft pretrial memorandum as offered, and forwarded an email to Attorney Harding requesting a JOINT MOTION TO CONTINUE THE PRETRIAL HEARING in order to discuss a potential settlement, stating that, in the alternative, if Defendant is not amenable to settlement negotiations, Plaintiffs will look for the draft pretrial memorandum. 6. On November 3, 2020, Attorney Harding responded to Plaintiffs’ email stating that Geico would not agree to a motion to continue under the circumstances because Geico made a $16,000 offer six (6) months ago. That offer has a deadline of November 16, 2020; Geico wilt consider the offer rejected if Plaintiffs do not respond by the deadline. 7. ‘On November 11, 2020, Plaintiffs received a draft copy of Defendant, Geico’s draft pretrial memorandum. While Plaintiffs appreciate Defendant's offer to draft the pretrial memorandum, after review of same, it “appears that the memorandum is strongly advantageous for Defendants and Plaintiffs find themselves at a disadvantage without legal assistance, Plaintiffs spent theentire ‘evening and all morning attempting to complete the pretrial memorandum given the time constraints and with just a few days until the November 16, 2020 hearing. 8. On November 12, 2020, Plaintiffs contacted the Clerk’s office for filing information. Plaintiffs would like to respectfully request an Emergency Motion to Continue Hearing as Plaintiffs will need more time to seek counsel to assist with the pending matter befere the Court. Wherefore, Plaintiffs, George and Theresa French, pray that this Honorable Court grant their Emergency Moticn to Continue Hearing to a new date and time that the Couxt deems appropriate. November 12, 2020 Respectfully submitted, Pro Se Plaintiff; pap LEDS Les fe George R. French 1685 Fall River. Ave. Seekonk, MA 02771 508.336.3257 “hgonstreect@dol'c Sellttswatn fer Theresa S. French 1685 Fall River Ave, Seekonk, MA 02771 508.336.3257 -