On October 16, 2020 a
Miscellaneous
was filed
involving a dispute between
Fallon Ambulance Service Llc,
Transformative Healthcare Inc,
and
Randseco Llc,
Tyler, Patrick Sean,
for Business Litigation
in the District Court of Suffolk County.
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CIVIL ACTION COVER vocxernow B. LS.
SHEET “)
Trial Court Of Massachusetts Superior Court Department County:
Faye) a 7 | SUFFOLK
PLAINTIFFS)
DEFENDANT ()
TRANSFORMATIVE HEALTHCARE, INC. AND FALLON PATRICK SEAN TYLER AND RANDSECO, LLC
AMBULANCE SERVICE, LLC
"ATTORNEY, FIRM NAME, ADDRESS AND TELEPHONE Board of Bar Overseers number ATTORNEY (if known)
ERIN J. OLESEN (BBO#696168)
Foley Hoag LLP :
155 Seaport Boulevard
, | Boston, MA 02210
(617) 832-1000
Origin Code Original Complaint
N/A
Type of Action
TYPE OF ACTION AND TRACK DESIGNATION (See reverse side) CODE NO. TYPE OF ACTION (specify) TRACK IS THIS A JURY CASE? *
Code No.
Track _ Is this ajury case?
BE.1
Claim involving violation of business relationship B
Yes
‘The following is a full and detailed statement of the facts on which plaintiff relies to determine eligibility in to The Business Litigation Session.
Plaintiffs seek damages, injunctive and other relief for defendants’ breach of fiduciary duty, misappropriation of
confidential information, and threats to interfere with plaintiffs’ business by disabling its operational software, which
lis necessary to operate an ambulance service in Eastern Massachusetts, among other claims. Plaintiffs also seek
tedress for defendants’ defamation. Defendants are the former CEO of plaintiff Transformative Healthcare, Inc. and
la separate company he operates, respectively.
a)
GG Z% cl q\ 130 quit
* A Special Tracking Order shall be created by the Presiding Justice of the Business Litigation Session at the Rule 16 Conference.
PLEASE IDENTIFY, BY CASE NUMBER, NAME AND COUNTY, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT. N/A
7] hereby certify that I have complied with the requirements of Rule 5 of the Supreme Judicial Cow
requiring that I provide my clients with information about court-connected dj
disadvantages of the various methods.” Signature of Attorney of Record.
DATE: October 16, 2020
irt Uniform Rules on Dispute Resolution (SJC Rule 1:18)
ute resolution ices and discuss with them the advantages and
BS5195119.1
Document Filed Date
October 16, 2020
Case Filing Date
October 16, 2020
Category
Business Litigation
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CIVIL ACTION COVER vocxernow B. LS. SHEET “) Trial Court Of Massachusetts Superior Court Department County: Faye) a 7 | SUFFOLK PLAINTIFFS) DEFENDANT () TRANSFORMATIVE HEALTHCARE, INC. AND FALLON PATRICK SEAN TYLER AND RANDSECO, LLC AMBULANCE SERVICE, LLC "ATTORNEY, FIRM NAME, ADDRESS AND TELEPHONE Board of Bar Overseers number ATTORNEY (if known) ERIN J. OLESEN (BBO#696168) Foley Hoag LLP : 155 Seaport Boulevard , | Boston, MA 02210 (617) 832-1000 Origin Code Original Complaint N/A Type of Action TYPE OF ACTION AND TRACK DESIGNATION (See reverse side) CODE NO. TYPE OF ACTION (specify) TRACK IS THIS A JURY CASE? * Code No. Track _ Is this ajury case? BE.1 Claim involving violation of business relationship B Yes ‘The following is a full and detailed statement of the facts on which plaintiff relies to determine eligibility in to The Business Litigation Session. Plaintiffs seek damages, injunctive and other relief for defendants’ breach of fiduciary duty, misappropriation of confidential information, and threats to interfere with plaintiffs’ business by disabling its operational software, which lis necessary to operate an ambulance service in Eastern Massachusetts, among other claims. Plaintiffs also seek tedress for defendants’ defamation. Defendants are the former CEO of plaintiff Transformative Healthcare, Inc. and la separate company he operates, respectively. a) GG Z% cl q\ 130 quit * A Special Tracking Order shall be created by the Presiding Justice of the Business Litigation Session at the Rule 16 Conference. PLEASE IDENTIFY, BY CASE NUMBER, NAME AND COUNTY, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT. N/A 7] hereby certify that I have complied with the requirements of Rule 5 of the Supreme Judicial Cow requiring that I provide my clients with information about court-connected dj disadvantages of the various methods.” Signature of Attorney of Record. DATE: October 16, 2020 irt Uniform Rules on Dispute Resolution (SJC Rule 1:18) ute resolution ices and discuss with them the advantages and BS5195119.1