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Â¥ Wa
Commonwealth of Massachusetts
Sutfolk, ss. SUPERIOR COURT
DEPARTMENT OF THE TRIAL COURT
CIVIL ACTION NO. 1984CV02032A
TREVOR BLAKE, as Trustee of Blake &
Sydney Realty Trust,
=
Ss
Plaintiff,
v.
R&R SALES, INC. formerly known as
R-R SALES, INCORPORATED, successor by merger to
NEW ENGLAND LUMBER SALES COMPANY, INC.
now known as NEW ENGLAND LUMBER, INC.
ANNE J. RAIMONDI as Director, and
PAUL MCCORMACK as Director, the ESTATE OF
ROBERT A. RAIMONDI, SR., and the HEIRS OF
ROBERT A. RAIMONDI, SR.
Defendants.
IO
PLAINTIFE’S MOTION TO EXTEND TRACKING ORDER fiofi uw
The Plaintiff, Trevor Blake, as Trustee of Blake & Sydney Realty Trust (the “Plaintiff), moves to
extend the Tracking Order dates in this case for a period of six (6) months. As grounds for this motion, the { f C4 / /
Plaintiff states that he has experienced difficulty in locating and serving the Complaint upon the Defendants D
R&R Sales, Inc., New England Lumber, Inc. and the Heirs of Robert Raimondi, Sr. The Plaintiff DAA
specifically states: Tam F
J. On June 25, 2019, the Plaintiff filed this action to obtain an order decreeing and declaring that wt
a certain Mortgage allegedly given by him to R&R Sales, Inc. (n/k/a New England Lumber, Inc.) and Pe
encumbering his real property located in Dorchester, Suffolk County, Massachusetts has been rendered -+
invalid and ineffective, and that said Mortgage should be discharged from the records at the Suffolk County MKD
Oo
Registry of Deeds.
2. On June 26, 2019, the Plaintiff attempted to serve the Complaint upon R&R Sales, Inc. via
the Norfolk County Sheriff's Department because in its most recent Annual Report filed with the
Massachusetts Secretary of the Commonwealth Corporations Division, R & R Sales, Inc. listed its principal
place of business at c/o New England Lumber, Inc., 219 Gardiner Road, Quincy, MA 02169, The Norfolk
County Sheriff was unable to complete service.
3. On June 26, 2019, the Plaintiff also attempted to serve the Complaint upon R & R Sales, Inc.
via the Suffolk County Sheriff's Department because according to the Massachusetts Secretary of the
Commonwealth Corporations Division, R & R Sales’ most recent address is c/o New England Lumber, Inc.
174 Hampden Street, Roxbury (Boston), MA 02119. The Suffolk Con eriff aimee getter
service.
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¥ Wa Commonwealth of Massachusetts Sutfolk, ss. SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT CIVIL ACTION NO. 1984CV02032A TREVOR BLAKE, as Trustee of Blake & Sydney Realty Trust, = Ss Plaintiff, v. R&R SALES, INC. formerly known as R-R SALES, INCORPORATED, successor by merger to NEW ENGLAND LUMBER SALES COMPANY, INC. now known as NEW ENGLAND LUMBER, INC. ANNE J. RAIMONDI as Director, and PAUL MCCORMACK as Director, the ESTATE OF ROBERT A. RAIMONDI, SR., and the HEIRS OF ROBERT A. RAIMONDI, SR. Defendants. IO PLAINTIFE’S MOTION TO EXTEND TRACKING ORDER fiofi uw The Plaintiff, Trevor Blake, as Trustee of Blake & Sydney Realty Trust (the “Plaintiff), moves to extend the Tracking Order dates in this case for a period of six (6) months. As grounds for this motion, the { f C4 / / Plaintiff states that he has experienced difficulty in locating and serving the Complaint upon the Defendants D R&R Sales, Inc., New England Lumber, Inc. and the Heirs of Robert Raimondi, Sr. The Plaintiff DAA specifically states: Tam F J. On June 25, 2019, the Plaintiff filed this action to obtain an order decreeing and declaring that wt a certain Mortgage allegedly given by him to R&R Sales, Inc. (n/k/a New England Lumber, Inc.) and Pe encumbering his real property located in Dorchester, Suffolk County, Massachusetts has been rendered -+ invalid and ineffective, and that said Mortgage should be discharged from the records at the Suffolk County MKD Oo Registry of Deeds. 2. On June 26, 2019, the Plaintiff attempted to serve the Complaint upon R&R Sales, Inc. via the Norfolk County Sheriff's Department because in its most recent Annual Report filed with the Massachusetts Secretary of the Commonwealth Corporations Division, R & R Sales, Inc. listed its principal place of business at c/o New England Lumber, Inc., 219 Gardiner Road, Quincy, MA 02169, The Norfolk County Sheriff was unable to complete service. 3. On June 26, 2019, the Plaintiff also attempted to serve the Complaint upon R & R Sales, Inc. via the Suffolk County Sheriff's Department because according to the Massachusetts Secretary of the Commonwealth Corporations Division, R & R Sales’ most recent address is c/o New England Lumber, Inc. 174 Hampden Street, Roxbury (Boston), MA 02119. The Suffolk Con eriff aimee getter service.