On September 16, 2016 a
Party Statement
was filed
involving a dispute between
Carrion, Jennifer M,
Hashem, Saba,
and
D'Angelo And Hashem, Llc,
D'Angelo Law Group Llc And Nominally, D'Angelo And Hashem, Llc,
D'Angelo, Stephen L.,
for Equitable Remedies
in the District Court of Essex County.
Preview
us
COMMONWEALTH OF MASSACHUSETS
ESSEX, SS . SUPERIOR COURT
SABA HASHEM, individually, and as a
Member of, and derivatively on behalf of, *
D’ANGELO and HASHEM, LLC.
Plaintiff Civil Action No. 16CV1419
v.
STEPHEN L. D’ANGELO, D’ ANGELO
LAW GROUP, LLC, and D’ANGELO
AND HASHEM, LLC.
Defendants
eee ee HH HH
STATEMENT REGARDING SUPERIOR COURT RULE 9C
NOW COMES counsel for Defendants, Cossingham Law Office, P.C Thomas C.
LaPorte, Esq. and respectfully states the following. On January 16, 2021, the Defendants
through their counsel filed its Motion for Reconsideration, Rule 11 Sanctions, Release of Escrow
to Defendants and for a Stay on an Emergency Basis. That Motion(s) was denied by the Court
without Prejudice on January 20, 2021. As Defendants’ was preparing the documents to be
served under Rule 9A, Intervenor-Plaintiff’s counsel filed a Motion to Strike the Motion for Rule
11 Sanctions and for an extension to extend response date to respond to all of the motions, on
January 29, 2021, which Defendants’ counsel became aware of on or about February 3, 2021.
(The docket was updated on February 1, 2021.) Defendants’ counsel does not recall any specific
phone conversation with counsel but does believe he did try contacting her by phone prior to re-
serving the Motions per Rule 9A. Additionally, after service, Defendants’ counsel does recall
not knowing at that time whether counsel’s Motion to Strike, she had filed, would be heard, but
that said Motion set forth counsel’s position. Subsequent emails between counsel and
Defendants’ counsel regarding the Gas Explosion settlements monies being held, made clear the
parties could not agree on any issues or to narrow any issues.
Due to the that and the continued denial of income to Defendant DLG, while the
pandemic continued, adversely affecting its revenues, no further contact made, except for the
receipt of counsel’s Opposition Papers, which are filed herewith.SG
Date: March 2, 2021
Respectfully Submitted,
Counsel for Defendants
Sl,
homas C. LaPorte, Esq.
BBO #634194
COSSINGHAM LAW OFFICE, PC
30 Massachusetts Ave., Suite 404
N. Andover, MA 01845
Tel: 978-685-5686
Fax: 978-794-0985
tlaporte@cossinghamlaw.com
Document Filed Date
March 04, 2021
Case Filing Date
September 16, 2016
Category
Equitable Remedies
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us COMMONWEALTH OF MASSACHUSETS ESSEX, SS . SUPERIOR COURT SABA HASHEM, individually, and as a Member of, and derivatively on behalf of, * D’ANGELO and HASHEM, LLC. Plaintiff Civil Action No. 16CV1419 v. STEPHEN L. D’ANGELO, D’ ANGELO LAW GROUP, LLC, and D’ANGELO AND HASHEM, LLC. Defendants eee ee HH HH STATEMENT REGARDING SUPERIOR COURT RULE 9C NOW COMES counsel for Defendants, Cossingham Law Office, P.C Thomas C. LaPorte, Esq. and respectfully states the following. On January 16, 2021, the Defendants through their counsel filed its Motion for Reconsideration, Rule 11 Sanctions, Release of Escrow to Defendants and for a Stay on an Emergency Basis. That Motion(s) was denied by the Court without Prejudice on January 20, 2021. As Defendants’ was preparing the documents to be served under Rule 9A, Intervenor-Plaintiff’s counsel filed a Motion to Strike the Motion for Rule 11 Sanctions and for an extension to extend response date to respond to all of the motions, on January 29, 2021, which Defendants’ counsel became aware of on or about February 3, 2021. (The docket was updated on February 1, 2021.) Defendants’ counsel does not recall any specific phone conversation with counsel but does believe he did try contacting her by phone prior to re- serving the Motions per Rule 9A. Additionally, after service, Defendants’ counsel does recall not knowing at that time whether counsel’s Motion to Strike, she had filed, would be heard, but that said Motion set forth counsel’s position. Subsequent emails between counsel and Defendants’ counsel regarding the Gas Explosion settlements monies being held, made clear the parties could not agree on any issues or to narrow any issues. Due to the that and the continued denial of income to Defendant DLG, while the pandemic continued, adversely affecting its revenues, no further contact made, except for the receipt of counsel’s Opposition Papers, which are filed herewith.SG Date: March 2, 2021 Respectfully Submitted, Counsel for Defendants Sl, homas C. LaPorte, Esq. BBO #634194 COSSINGHAM LAW OFFICE, PC 30 Massachusetts Ave., Suite 404 N. Andover, MA 01845 Tel: 978-685-5686 Fax: 978-794-0985 tlaporte@cossinghamlaw.com