Party Notice: Transformative Healthcare Inc vs. Tyler, Patrick Sean

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                                NOTIFY.

COMMONWEALTH OF MASSACHUSETTS

 

 

SUFFOLK, ss. SUPERIOR COURT
CIVIL ACTION
NO. 2084-CV-02375-BLS1
wondé Sar
63-08
— Bah.
TRANSFORMATIVE HEALTHCARE, INC, ) thm
and FALL IN AMBULANCE SERVICES, LLC, ) = ;
y FH
Plaintiffs, JEN.
) Meo.
v. ) N.C
)
PATRICK SEAN TYLER and RANDSECO, LLC, ) (A)
‘ )
Defendants. )
)

 

|
JOINEERORSSED. TRACKING ORDER
As a result of the Rule 16 Conference, at which all parties to this action were afforded the
opportunity to be heard, IT IS HEREBY ORDERED that the following initial tracking order
deadlines re established for this case going forward, and shall henceforth be binding on all
parties:
1. On or before March 30, 2021, the parties shall complete all Amendments to
i

Pleadings and Addition of Parties.
2. Remote depositions are permitted. If aay remote deposition is taken, the deponent
and couns::] must remain visible at all times on their video screen. Anyone Present in the room
with the duponent must be visible at all times on their ‘video screen. Except during breaks, while
any deponent is testifying, they are prohibited from communicating with anyone, through text,

private chit, or in any other manner. A witness is prohibited from holding, having, referring to‘

or using any notes, paperwork or other aids while they are testifying, unless the witness discloses
that they hold, have, are referring to, or are using such materials; and such materials have been
made avail able to counsel for all parties prior to trial. Videotaping of depositions shall be

| : permitted zt the expense of the party seeking to videotape, except that if any of the other parties

: | wish to reczive a copy of the videotape, it shall obtain it directly from the videographer at its
expense. T 1e transcript of a remote deposition may be used in the same manner at a hearing or
trial as any other transcript.

3. The parties may serve subpoenas duces tecum or their equivalent, at any time
/ while discovery is open, but shall contemporaneously serve copies of any such requests, and of
| any records produced in response thereto, on the other, party regardless of whether such service is

: " required by law. The receiving party shall pay the reasonable copying charges for its copies of
/ any such r:cords provided to it by the other party, but shall not be required to pay any share of
' ,

any other jees charged by the producing non-party to the requesting or subpoenaing party.

—~_.

 
   
 
  
  

i
e parties shall propound no more than twenty-five (25) interro,

5. [[The parties shall pr id no more than t separate sets of requests for the

 

productior of documents, electronical]; informatt d tangible things. The amount of

   
  
 

requests ir each set (ot be limited by number, but shall be subject to eneral limitations
| | ondistove ry set forth in Rule 26 of the Massachusetts Rules of Civil Procedure.]]
6. On or before September 30, 2021 all fact discovery shall be completed (by which

is meant tliat all fact depositions shall be noticed to be taken by such date, and all written

discovery shall have been served sufficiently in advance of that date for the answers to it be due

by that date).7.’ Onoor before October 30, 2021, each party shall disclose the identity of any
witnesses «xpected to offer expert testimony at trial with respect to issues on which the
disclosing party bears the burden of proof. In the case of any expert witnesses who are retained
or speciall:” employed to provide expert testimony, the disclosure shall be accompanied by a

written rey ort, prepared and signed by the witness, setting forth the subject matter on which the

 

expert is e::pected to testify, the substance of the facts and opinions to which the expert is
expected to testify and the grounds for each opinion.
8. On or before December 31, 2021, the Parties shall disclose the identity of any
rebuttal or other expert witnesses. In the case of any such expert witnesses who are retained or
" specially employed to provide expert testimony, the disclosure shall be accompanied by a written
report, setling forth the subject matter on which the expert is expected to testify, the substance of
the facts aid opinions to which the expert is expected to testify and the grounds for each opinion.
9. Any expert witness designated to provide expert testimony may be deposed
without le:ve of court so long as notice of deposition for such deposition is served on or before
January 3(, 2022 and the deposition is scheduled to be taken on or before February 15, 2022.
10. .On or before March 30, 2022, or within 45 days of the last expert deposed,
/ whichever is later, any and all motions for summary judgment shall be served in compliance with
Superior C ourt Rule 9(A).
11 Based on availability of the Court, on cr about March 15, 2022, or at least 30 days
after a decision on all motions for summary judgment has been issued (if one or more motions

for summ: ry judgment have been served), whichever js later, the Final Pre-trial Conference shall

an AAU LL
be held. ‘The Joint Pre-Trial Memorandum shall be filed with the Court notes Seewrit. The Cowes. Cen ait Lap Tle pachiee £

Triat Orde: shatl-be those set forth in the Appendix A “Pi

 

DSTI MEE Owes

SO ORDERED:

   

Dated: 22) : C 2
at Rhee 26, Assodiate J

istice, Superidr Court