Preview
184
4/22/2021
COMMONWEALTH OF MASSACHUSETTS
ESSEX, SS SUPERIOR COURT C.A. No. 1667CV01419
SABA HASHEM, individual and as Manager of
D'Angelo & Hashem, LLC
Plaintiff/Defendant-Intervenor
STEPHEN D'ANGELO, individually and as a
Manager of D'Angelo & Hashem, LLC, and
D'Angelo Law Group, LLC,
Defendants/Defendant Intervenor,
Reach and Apply Defendant,
JENNIFER M. CARRION,
Plaintiff-Intervenor.
PLAINTIFF-INTERVENOR’S OPPOSITION TO DEFENDANTS’ EMERGENCY MOTION
FOR AN ORDER RELEASING RETAINER AMOUNT REQUIRED BY THE DEFENDANTS’S
EXPERT WITNESS IN THE AMOUNT OF TEN THOUSAND DOLLARS FROM FEES
ORDERED HELD IN ESCROW TO DEFENDANTS’ COUNSEL
NOW COMES the Plaintiff-Intervenor, Jennifer M. Carrion, through her counsel, who hereby
respectfully opposes the Defendants’ motion for an order releasing $10,000.00 from monies ordered held
in escrow to Defendants’ counsel to pay for expert witness. Justice so requires that this Honorable Court
deny the Defendants’ Motion. AS GROUNDS THEREFORE, Ms. Carrion avers that (1) the Defendants,
D’Angelo Law Group LLC (“DLG”) & Mr. D’Angelo, have a long history of hindering funds away from
her M.G.L. Ch. 151 B Judgment’s reach (Paper # 97 at pg. 1 (07/09/2020), # 71 at pgs. 9-10 (12/06/2018,
1/29/2019), Suffolk Sup. Ct Docket 0784CV02073 at #54 (07/17/2012)), (2) the Escrow order was set up
upon Ms. Carrion Motion after she was awarded Summary Judgment on Successor Liability against
Defendant, DLG (Paper # 97.) and (3) the Defendants have already moved this Court that the sum of
$12,500 be paid for their expert witness (Paper #177 at pg. 2), which is subject to opposition by Ms.
Carrion due on April 28, 2021.
“The History of Carrion’s litigation, which spans nine years, indicates that there is a high
likelihood, if not a certainty, that, once in receipt of the funds that are subject of the Emergency Motion,
the D’Angelo Law Group will not use any of them to satisfy Carrion’s judgment against it, and may, in
fact, divert the funds to other purposes to avoid having sufficient funds to pay the judgment.” Paper # 97
at pg. 1.
Page 1 of 5
Examples of this Court’s holding above include, without limitation, DLG’s failure to follow this
Court’s injunction (Paper # 71), and its predecessor, D’Angelo & Hashem, LLC’s (“D&H”) failure to
follow Preliminary Injunction Order of July 17, 2012 to ensure Ms. Carrion’s Judgments are collected
(Suffolk Sup. Ct Docket 0784CV02073 at #54 – See paper # 76 at Ex. D). On November 22, 2011, a jury
returned a verdict awarding Carrion $109,000.00 and on attorney fees and costs $142,215.00 and $115,
954.00, totaling $252,742.54. These were entered against DLG’s predecessor D&H. (Id. at Paper # 41,
42, 50). On July 12, 2012, Carrion obtained preliminary Injunction against D&H where the Suffolk
Superior Court, after notice and hearing, ordered:
“Defendants, their associates, their partners, members, employees, and agents are prohibited from: 1.
Taking any unlawful action to hinder, or delay, or defraud the plaintiff from collecting the plaintiff’s
judgment in this action, 2. Transferring, alienating or encumbering any assets of the Defendants other than
in the ordinary course of business.” (Id at Number 54).
On December 6, 2018, the Federal Court ordered inter alia in its Memorandum and Order on Page 9:
“Court concludes that Ms. Carrion has met her burden to show that a preliminary Injunction is warranted
in this matter to avoid an otherwise irreparable harm. Accordingly, the Defendants Stephen D’Angelo and
the D’Angelo Law Group, LLC are hereby ordered to:
a. Promptly provide Intervention Plaintiff with an accounting relating to the settlement in
Lopez-Maldonando et al. v. Toll Brothers Inc, Suffolk Superior Court Case No. 1484-CV-
01440-G (…)
b. Hold the balance of attorney’s fees and costs in Lopez-Maldonando et al. v. Toll Brothers
Inc, Suffolk Superior Court Case No. 1484-CV-01440-G in an escrow account;
c. Hold the balance and attorneys’ fees and costs from all other cases that originated with
D’Angelo & Hashem LLC, still held by or received by D’Angelo Law Group LLC, or Stephen
D’Angelo, while this Injunction remains in effect, in a escrow account
d. Defendants, Stephen D’Angelo and D’Angelo Law Group, LLC, are enjoined, directly, or
indirectly, alone or in concert with others, effective immediately, from making any
distributions of amounts from such escrow accounts or obtained from any cases originating
from D’Angelo & Hashem LLC, except that D’Angelo Law Group LLC maintains the right to
pay normal and customary expenses occurred in the normal course of business. Such
expenses may not include distributions to Stephen D’Angelo, payments toward credit card
balances, or for car leases.
“The above-restrictions shall remain in place pending further order of this Court, or if the matter is
remanded, of the Superior Court for the Commonwealth of Massachusetts. This order is subject to
modification by order of the Court upon Motion by any party. IT IS SO ORDERED.” Paper #71 - Memo
& Order PI at pg. 9-10.
Notwithstanding the above injunctions, DLG and D’Angelo admittedly failed to hold the amounts in
escrow as ordered by the Federal Court and continued to receive six figure incomes in 2016, 2017, 2018 &
2019 without compensating the Judgment Creditor, Ms. Carrion. (Paper 96 at Ex. E). Further, Defendant Mr.
D’Angelo took home personally net six figures from D&H & DLG 2014, 2015, 2016, 2018, 2019. Id. Seven
years after her verdict, only the Plaintiff Hashem has made payments to Ms. Carrion & her counsels in the
Page 2 of 5
amount of $160,187.50 to date, still owing Plaintiff-Intervenor $102,312.50 on his individual settlement only.
At the time of Mr. Hashem’s partial settlement on 11.30.2018, Ms. Carrion’s civil rights judgment totaled
$581,707.70 with statutory interest. Thereafter, Ms. Carrion prevailed on the merits on her Successor
Liability claim against the Defendant DLG in the amount of $672,995.92 on April 8, 2020. For all these
reasons, this Honorable Court issued temporary restraining order and preliminary injunction to escrow “any
form of payment for the firm’s work – including but not limited to the work of any of its principals, attorney,
and/or personnel- in Acosta et al. v. Bay State Gas Company d/b/a Columbia Gas of Mass. et al,
187CV01343.” (Paper # 97 at pg. 2, see also Paper #105).1
This Honorable Court then balanced “the threatened harm that an injunction will cause the opposing
party” (Paper # 105 at pg. 2 citing Packaging Indus.Group, Inc. v. Cheney, 380 Mass. 609, 616 (1980)). “The
Court may issue a preliminary injunction on if ’the balance between the risks cuts in favor of the moving
party.’” (Id.) In the face of this success on the merits and dissipation that Ms. Carrion set forth, the Court
has balanced the equities in favor of Ms. Carrion to enjoin escrow funds since July 16, 2020. Id. The Court
issued order on 08/07/2020 after review of submissions to allow Defendants to pay counsel. Defendants
submitted to the docket Paper # 139 on 10/05/2021, Paper # 163 on February 3, 2021 and Paper # 177 on
April 7, 2021, entitled Third, Fourth and Fifth Affidavit. No order has yet been entered to pay Defendant’s
attorneys’ fees. Plaintiff-Intervenor has until April 28, 2021 to oppose counsel fees sought to be paid from
the escrow.
Defendants claim that the escrow agent holds $240,000.00. Even assuming arguendo that the
Plaintiff paid his partial settlement to Ms. Carrion and even after not counting statutory interest that has
accrued since11/28/2018 in arguendo, this escrow amount does not satisfy the balance of Ms. Carrion’s
judgment - $319, 207.70 -as of 11/30/2018.
Most importantly, the Court cannot reward the Defendants for not paying a judgment.
Defendants’ attorneys state on 10/05/2020 in paper # 139 that they gave credit to the Defendants in the
amount $8,539.65 and that the Defendants supposedly paid them $2,717.20 from 11/13/2018 to 08/20/2020.
However, on February 3, 2021, Defendants’ attorneys submitted in Paper # 163 that the Defendants paid
them $20,000.00 from 1/16/2020 to 03/16/2020, which is during the same period as their prior submission.
The $8,539.65 credit given on 08/20/2020 in Paper 139 disappears in Paper #163 and payment #3505 on
03/16/2020 changed from $307.50 in #139 to $10,000 in Paper #163. Paper 163 also added Inv# 47339
1
This Honorable Court has set that Ms. Carrion “almost certainly will prevail on the merits of her claim. Even if
she does not prevail on her remaining claims – at least one of which seeks to hold D’Angelo personally liable – the
Court has concluded that the D’Angelo Law Group, against which Carrion seeks injunctive relief, is liable for her
judgment against D’Angelo and Hashem with interest.” (Paper 105 at pg. 3) Further, this Court has held that “Ms.
Carrion has established irreparable harm,” and her “frustrating odyssey to recover damages awarded to her by jury
from the law firm that discriminated against her establishes that, in this case at least, justice delayed is, indeed,
justice denied.” (Id at pg. 3 & FN5)
Page 3 of 5
dated 01/16/2020 that was not in Paper #139, despite being billed in the same period. It is unclear whether
the discrepancy was a grave bookkeeper error or intentional omission, since the Attorney’s Affidavit is silent
on the prior missing payments and invoices. Therefore, there is grave uncertainty on amounts paid and billed.
What is most irreconcilable is that the Defendants sought to fight the collection of Ms. Carrion’s
M.G.L. Ch. 151b Judgment for which they had duty to pay since 2011, for which they were enjoined from
dissipating funds since July 17, 2012 and ordered to hold escrow since December 6, 2018. The Defendants
refused, failed and neglected to follow court orders, but kept incurring their attorney’s fees to not pay Ms.
Carrion’s judgment. When DLG lost by Summary Judgment on April 8, 2020, which was foreseeable in
light of the 2018 injunction (Paper #71), the Defendants continued billing thereafter and increasing counsel
fees from $62,997.81 in 08/20/2020 to $104, 602.12 on 02/3/2021 to now $120,523.87. Such amount is more
than double of this Court’s award of attorney’s fees in favor of Ms. Carrion from prevailing on Summary
Judgment in Paper 159.
It would defy justice to enable the Defendants to disregard a known judgment by incurring counsel
fees, for which there is no viable defense, and having them paid from Ms. Carrion’s escrow, which she had
to set aside because “there is a high likelihood, if not a certainty, that, once in receipt of the funds that are
subject of the Emergency Motion, the D’Angelo Law Group will not use any of them to satisfy Carrion’s
judgment against it.” (Paper 97 at pg. 1). Avoiding costs & counsel fees is a main reason to resolve litigation
especially of a known liability,such as Judgment. Even though they are in the business of winning
Judgments, Defendants made an intentional choice to “divert the funds to other purposes to avoid having
sufficient funds to pay the (Ms. Carrion’s) judgment.” Paper # 97 at pg.1. That is not equity, defies basic
principles of fairness, and must be denied.
Ms. Carrion counsel are collecting her civil rights judgment on a contingency basis and expending out
of pocket expert costs. Ms. Carrion and counsel has herself paid out of pocket $4,500 for her expert. She
has 3 minor children and does not own her home. Mr. D’Angelo owns a home, boat, & fancy cars, leases
fancy cars, enjoys fancy lifestyle, and pocketed net six figure income from 2014 -2019. (Paper 80.9 at pg. 5)
It defies common sense that Mr. D’Angelo cannot afford $10,000 to pay their expert. Further, the
Defendants’ expert testimony has nothing to do with Plaintiff-Intervenor, but the Plaintiff. (Paper # 93)
WHEREFORE, the Plaintiff -Intervenor respectfully moves this Honorable Court to Deny the relief
sought by the Defendants, protect her escrow account, and her right to be fully paid her discrimination
judgment in light of Ms. Carrion’s success on the merits, outstanding Judgment balance, and Defendants’
long-term dissipation of funds. This is what justice so requires, what MG.L. Ch. 151 B requires, and what
the judiciary was made to do enforcing Judgments.
Page 4 of 5
Respectfully Submitted,
The Plaintiff-Intervenor,
Jennifer M. Carrion
By her Counsel,
/s Mernaysa Rivera-Bujosa
___________________________________
Mernaysa Rivera-Bujosa, Esquire
Rivera-Bujosa Law, PC
Shipway Place, Suite C2
Charlestown Navy Yard
Boston, Massachusetts 02129
Telephone: (617) 398 – 6728
Facsimile: (617) 398 - 6730
E-mail: Mernaysa@riverabujosalaw.com
BBO no.: 665965
CERTIFICATE OF SERVICE
I, Mernaysa Rivera-Bujosa, Esq., do herewith certify that I have on this 22 day of April 2021, I
served a copy of the within document by email upon parties and counsel appeared in this action, to
wit: via email and electronic filing upon -
Thomas C. LaPorte, Esq.
Cossingham Law Office, PC
30 Massachusetts Avenue, Suite 404
North Andover, MA 01845
tlaporte@cossinghamlaw.com
Saba Hashem,
shceh@yahoo.com
318 Broadway Methuen MA 01844
/s Mernaysa Rivera-Bujosa
___________________________________
Mernaysa Rivera-Bujosa, Esquire
Page 5 of 5
Preview
184 4/22/2021 COMMONWEALTH OF MASSACHUSETTS ESSEX, SS SUPERIOR COURT C.A. No. 1667CV01419 SABA HASHEM, individual and as Manager of D'Angelo & Hashem, LLC Plaintiff/Defendant-Intervenor STEPHEN D'ANGELO, individually and as a Manager of D'Angelo & Hashem, LLC, and D'Angelo Law Group, LLC, Defendants/Defendant Intervenor, Reach and Apply Defendant, JENNIFER M. CARRION, Plaintiff-Intervenor. PLAINTIFF-INTERVENOR’S OPPOSITION TO DEFENDANTS’ EMERGENCY MOTION FOR AN ORDER RELEASING RETAINER AMOUNT REQUIRED BY THE DEFENDANTS’S EXPERT WITNESS IN THE AMOUNT OF TEN THOUSAND DOLLARS FROM FEES ORDERED HELD IN ESCROW TO DEFENDANTS’ COUNSEL NOW COMES the Plaintiff-Intervenor, Jennifer M. Carrion, through her counsel, who hereby respectfully opposes the Defendants’ motion for an order releasing $10,000.00 from monies ordered held in escrow to Defendants’ counsel to pay for expert witness. Justice so requires that this Honorable Court deny the Defendants’ Motion. AS GROUNDS THEREFORE, Ms. Carrion avers that (1) the Defendants, D’Angelo Law Group LLC (“DLG”) & Mr. D’Angelo, have a long history of hindering funds away from her M.G.L. Ch. 151 B Judgment’s reach (Paper # 97 at pg. 1 (07/09/2020), # 71 at pgs. 9-10 (12/06/2018, 1/29/2019), Suffolk Sup. Ct Docket 0784CV02073 at #54 (07/17/2012)), (2) the Escrow order was set up upon Ms. Carrion Motion after she was awarded Summary Judgment on Successor Liability against Defendant, DLG (Paper # 97.) and (3) the Defendants have already moved this Court that the sum of $12,500 be paid for their expert witness (Paper #177 at pg. 2), which is subject to opposition by Ms. Carrion due on April 28, 2021. “The History of Carrion’s litigation, which spans nine years, indicates that there is a high likelihood, if not a certainty, that, once in receipt of the funds that are subject of the Emergency Motion, the D’Angelo Law Group will not use any of them to satisfy Carrion’s judgment against it, and may, in fact, divert the funds to other purposes to avoid having sufficient funds to pay the judgment.” Paper # 97 at pg. 1. Page 1 of 5 Examples of this Court’s holding above include, without limitation, DLG’s failure to follow this Court’s injunction (Paper # 71), and its predecessor, D’Angelo & Hashem, LLC’s (“D&H”) failure to follow Preliminary Injunction Order of July 17, 2012 to ensure Ms. Carrion’s Judgments are collected (Suffolk Sup. Ct Docket 0784CV02073 at #54 – See paper # 76 at Ex. D). On November 22, 2011, a jury returned a verdict awarding Carrion $109,000.00 and on attorney fees and costs $142,215.00 and $115, 954.00, totaling $252,742.54. These were entered against DLG’s predecessor D&H. (Id. at Paper # 41, 42, 50). On July 12, 2012, Carrion obtained preliminary Injunction against D&H where the Suffolk Superior Court, after notice and hearing, ordered: “Defendants, their associates, their partners, members, employees, and agents are prohibited from: 1. Taking any unlawful action to hinder, or delay, or defraud the plaintiff from collecting the plaintiff’s judgment in this action, 2. Transferring, alienating or encumbering any assets of the Defendants other than in the ordinary course of business.” (Id at Number 54). On December 6, 2018, the Federal Court ordered inter alia in its Memorandum and Order on Page 9: “Court concludes that Ms. Carrion has met her burden to show that a preliminary Injunction is warranted in this matter to avoid an otherwise irreparable harm. Accordingly, the Defendants Stephen D’Angelo and the D’Angelo Law Group, LLC are hereby ordered to: a. Promptly provide Intervention Plaintiff with an accounting relating to the settlement in Lopez-Maldonando et al. v. Toll Brothers Inc, Suffolk Superior Court Case No. 1484-CV- 01440-G (…) b. Hold the balance of attorney’s fees and costs in Lopez-Maldonando et al. v. Toll Brothers Inc, Suffolk Superior Court Case No. 1484-CV-01440-G in an escrow account; c. Hold the balance and attorneys’ fees and costs from all other cases that originated with D’Angelo & Hashem LLC, still held by or received by D’Angelo Law Group LLC, or Stephen D’Angelo, while this Injunction remains in effect, in a escrow account d. Defendants, Stephen D’Angelo and D’Angelo Law Group, LLC, are enjoined, directly, or indirectly, alone or in concert with others, effective immediately, from making any distributions of amounts from such escrow accounts or obtained from any cases originating from D’Angelo & Hashem LLC, except that D’Angelo Law Group LLC maintains the right to pay normal and customary expenses occurred in the normal course of business. Such expenses may not include distributions to Stephen D’Angelo, payments toward credit card balances, or for car leases. “The above-restrictions shall remain in place pending further order of this Court, or if the matter is remanded, of the Superior Court for the Commonwealth of Massachusetts. This order is subject to modification by order of the Court upon Motion by any party. IT IS SO ORDERED.” Paper #71 - Memo & Order PI at pg. 9-10. Notwithstanding the above injunctions, DLG and D’Angelo admittedly failed to hold the amounts in escrow as ordered by the Federal Court and continued to receive six figure incomes in 2016, 2017, 2018 & 2019 without compensating the Judgment Creditor, Ms. Carrion. (Paper 96 at Ex. E). Further, Defendant Mr. D’Angelo took home personally net six figures from D&H & DLG 2014, 2015, 2016, 2018, 2019. Id. Seven years after her verdict, only the Plaintiff Hashem has made payments to Ms. Carrion & her counsels in the Page 2 of 5 amount of $160,187.50 to date, still owing Plaintiff-Intervenor $102,312.50 on his individual settlement only. At the time of Mr. Hashem’s partial settlement on 11.30.2018, Ms. Carrion’s civil rights judgment totaled $581,707.70 with statutory interest. Thereafter, Ms. Carrion prevailed on the merits on her Successor Liability claim against the Defendant DLG in the amount of $672,995.92 on April 8, 2020. For all these reasons, this Honorable Court issued temporary restraining order and preliminary injunction to escrow “any form of payment for the firm’s work – including but not limited to the work of any of its principals, attorney, and/or personnel- in Acosta et al. v. Bay State Gas Company d/b/a Columbia Gas of Mass. et al, 187CV01343.” (Paper # 97 at pg. 2, see also Paper #105).1 This Honorable Court then balanced “the threatened harm that an injunction will cause the opposing party” (Paper # 105 at pg. 2 citing Packaging Indus.Group, Inc. v. Cheney, 380 Mass. 609, 616 (1980)). “The Court may issue a preliminary injunction on if ’the balance between the risks cuts in favor of the moving party.’” (Id.) In the face of this success on the merits and dissipation that Ms. Carrion set forth, the Court has balanced the equities in favor of Ms. Carrion to enjoin escrow funds since July 16, 2020. Id. The Court issued order on 08/07/2020 after review of submissions to allow Defendants to pay counsel. Defendants submitted to the docket Paper # 139 on 10/05/2021, Paper # 163 on February 3, 2021 and Paper # 177 on April 7, 2021, entitled Third, Fourth and Fifth Affidavit. No order has yet been entered to pay Defendant’s attorneys’ fees. Plaintiff-Intervenor has until April 28, 2021 to oppose counsel fees sought to be paid from the escrow. Defendants claim that the escrow agent holds $240,000.00. Even assuming arguendo that the Plaintiff paid his partial settlement to Ms. Carrion and even after not counting statutory interest that has accrued since11/28/2018 in arguendo, this escrow amount does not satisfy the balance of Ms. Carrion’s judgment - $319, 207.70 -as of 11/30/2018. Most importantly, the Court cannot reward the Defendants for not paying a judgment. Defendants’ attorneys state on 10/05/2020 in paper # 139 that they gave credit to the Defendants in the amount $8,539.65 and that the Defendants supposedly paid them $2,717.20 from 11/13/2018 to 08/20/2020. However, on February 3, 2021, Defendants’ attorneys submitted in Paper # 163 that the Defendants paid them $20,000.00 from 1/16/2020 to 03/16/2020, which is during the same period as their prior submission. The $8,539.65 credit given on 08/20/2020 in Paper 139 disappears in Paper #163 and payment #3505 on 03/16/2020 changed from $307.50 in #139 to $10,000 in Paper #163. Paper 163 also added Inv# 47339 1 This Honorable Court has set that Ms. Carrion “almost certainly will prevail on the merits of her claim. Even if she does not prevail on her remaining claims – at least one of which seeks to hold D’Angelo personally liable – the Court has concluded that the D’Angelo Law Group, against which Carrion seeks injunctive relief, is liable for her judgment against D’Angelo and Hashem with interest.” (Paper 105 at pg. 3) Further, this Court has held that “Ms. Carrion has established irreparable harm,” and her “frustrating odyssey to recover damages awarded to her by jury from the law firm that discriminated against her establishes that, in this case at least, justice delayed is, indeed, justice denied.” (Id at pg. 3 & FN5) Page 3 of 5 dated 01/16/2020 that was not in Paper #139, despite being billed in the same period. It is unclear whether the discrepancy was a grave bookkeeper error or intentional omission, since the Attorney’s Affidavit is silent on the prior missing payments and invoices. Therefore, there is grave uncertainty on amounts paid and billed. What is most irreconcilable is that the Defendants sought to fight the collection of Ms. Carrion’s M.G.L. Ch. 151b Judgment for which they had duty to pay since 2011, for which they were enjoined from dissipating funds since July 17, 2012 and ordered to hold escrow since December 6, 2018. The Defendants refused, failed and neglected to follow court orders, but kept incurring their attorney’s fees to not pay Ms. Carrion’s judgment. When DLG lost by Summary Judgment on April 8, 2020, which was foreseeable in light of the 2018 injunction (Paper #71), the Defendants continued billing thereafter and increasing counsel fees from $62,997.81 in 08/20/2020 to $104, 602.12 on 02/3/2021 to now $120,523.87. Such amount is more than double of this Court’s award of attorney’s fees in favor of Ms. Carrion from prevailing on Summary Judgment in Paper 159. It would defy justice to enable the Defendants to disregard a known judgment by incurring counsel fees, for which there is no viable defense, and having them paid from Ms. Carrion’s escrow, which she had to set aside because “there is a high likelihood, if not a certainty, that, once in receipt of the funds that are subject of the Emergency Motion, the D’Angelo Law Group will not use any of them to satisfy Carrion’s judgment against it.” (Paper 97 at pg. 1). Avoiding costs & counsel fees is a main reason to resolve litigation especially of a known liability,such as Judgment. Even though they are in the business of winning Judgments, Defendants made an intentional choice to “divert the funds to other purposes to avoid having sufficient funds to pay the (Ms. Carrion’s) judgment.” Paper # 97 at pg.1. That is not equity, defies basic principles of fairness, and must be denied. Ms. Carrion counsel are collecting her civil rights judgment on a contingency basis and expending out of pocket expert costs. Ms. Carrion and counsel has herself paid out of pocket $4,500 for her expert. She has 3 minor children and does not own her home. Mr. D’Angelo owns a home, boat, & fancy cars, leases fancy cars, enjoys fancy lifestyle, and pocketed net six figure income from 2014 -2019. (Paper 80.9 at pg. 5) It defies common sense that Mr. D’Angelo cannot afford $10,000 to pay their expert. Further, the Defendants’ expert testimony has nothing to do with Plaintiff-Intervenor, but the Plaintiff. (Paper # 93) WHEREFORE, the Plaintiff -Intervenor respectfully moves this Honorable Court to Deny the relief sought by the Defendants, protect her escrow account, and her right to be fully paid her discrimination judgment in light of Ms. Carrion’s success on the merits, outstanding Judgment balance, and Defendants’ long-term dissipation of funds. This is what justice so requires, what MG.L. Ch. 151 B requires, and what the judiciary was made to do enforcing Judgments. Page 4 of 5 Respectfully Submitted, The Plaintiff-Intervenor, Jennifer M. Carrion By her Counsel, /s Mernaysa Rivera-Bujosa ___________________________________ Mernaysa Rivera-Bujosa, Esquire Rivera-Bujosa Law, PC Shipway Place, Suite C2 Charlestown Navy Yard Boston, Massachusetts 02129 Telephone: (617) 398 – 6728 Facsimile: (617) 398 - 6730 E-mail: Mernaysa@riverabujosalaw.com BBO no.: 665965 CERTIFICATE OF SERVICE I, Mernaysa Rivera-Bujosa, Esq., do herewith certify that I have on this 22 day of April 2021, I served a copy of the within document by email upon parties and counsel appeared in this action, to wit: via email and electronic filing upon - Thomas C. LaPorte, Esq. Cossingham Law Office, PC 30 Massachusetts Avenue, Suite 404 North Andover, MA 01845 tlaporte@cossinghamlaw.com Saba Hashem, shceh@yahoo.com 318 Broadway Methuen MA 01844 /s Mernaysa Rivera-Bujosa ___________________________________ Mernaysa Rivera-Bujosa, Esquire Page 5 of 5