On February 26, 2016 a
Party Discovery
was filed
involving a dispute between
Merrigan, Richard C,
and
Richard Howe Insurance Agency, Inc.,
for Contract / Business Cases
in the District Court of Middlesex County.
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COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, ss. SUPERIOR COURT DEPARTMENT
q OF THE TRIAL COURT TT
XO CIVIL ACTION NO. 1681-Cv-0566
RICHARD C. MERRIGAN, 9 | uli
Plaintiff, .
vs.
RICHARD HOWE INSURANCE AGENCY, INC.,
wees SL
Defendant.
PLAINTIFE’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS
Pursuant to Massachusetts Rules. of Civil Procedure 34 and 37, the Plaintiff, Richard
Merrigan, (“Plaintiff”), hereby moves the Court for an order conipelling the Defendant to respond
to Plaintiff's Request for Production of Documents served November 6, 2017.
The Plaintiff's statement of reasons for this Motion are set forth in the brief filed herewith
in support of this Motion.
WHEREFORE, the Plaintiff in this action respectfully requests that this Court enter an
Order: .
(H : Compelling the Defendant to respond to the Plaintiff's Request for Production of
: Documents;
(2) Award the Plaintiff his costs and any expenses in bringing this motion; and
(3) Grant such other relief and make such further Orders as this Court deems proper.Richard Merrigan.
By his attorney
Thomas W. Fothergil
Law Office of Thomas
80 Maple Street
Stoneham, Massachusetts 02180
Tele: (781) 438-1122
E-mail: thomasfothergill@msn.com
BBO # 546135
othergill
Dated: July 30, 2018
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on July 30, 2018 the foregoing was served on the Defendant
by mailing a copy thereof via overnight delivery, postage prepaid, to Defendant’s attorney of
record:
Michael J. Fencer, Esquire
Casner & Edwards, LLP
303 Congress Street
Boston, Massachusetts 02210
Signed under the pains and penalties of perjury:
Thomas W. Fothergill, Esquire
Dated: July 30, 2018
Document Filed Date
September 04, 2018
Case Filing Date
February 26, 2016
Category
Contract / Business Cases
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COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, ss. SUPERIOR COURT DEPARTMENT q OF THE TRIAL COURT TT XO CIVIL ACTION NO. 1681-Cv-0566 RICHARD C. MERRIGAN, 9 | uli Plaintiff, . vs. RICHARD HOWE INSURANCE AGENCY, INC., wees SL Defendant. PLAINTIFE’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS Pursuant to Massachusetts Rules. of Civil Procedure 34 and 37, the Plaintiff, Richard Merrigan, (“Plaintiff”), hereby moves the Court for an order conipelling the Defendant to respond to Plaintiff's Request for Production of Documents served November 6, 2017. The Plaintiff's statement of reasons for this Motion are set forth in the brief filed herewith in support of this Motion. WHEREFORE, the Plaintiff in this action respectfully requests that this Court enter an Order: . (H : Compelling the Defendant to respond to the Plaintiff's Request for Production of : Documents; (2) Award the Plaintiff his costs and any expenses in bringing this motion; and (3) Grant such other relief and make such further Orders as this Court deems proper.Richard Merrigan. By his attorney Thomas W. Fothergil Law Office of Thomas 80 Maple Street Stoneham, Massachusetts 02180 Tele: (781) 438-1122 E-mail: thomasfothergill@msn.com BBO # 546135 othergill Dated: July 30, 2018 CERTIFICATE OF SERVICE The undersigned hereby certifies that on July 30, 2018 the foregoing was served on the Defendant by mailing a copy thereof via overnight delivery, postage prepaid, to Defendant’s attorney of record: Michael J. Fencer, Esquire Casner & Edwards, LLP 303 Congress Street Boston, Massachusetts 02210 Signed under the pains and penalties of perjury: Thomas W. Fothergill, Esquire Dated: July 30, 2018