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190
4/22/2021
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. 1677CV1419
*
v. *
*
STEPHEN L. D’ANGELO, D’ANGELO *
LAW GROUP, LLC, and D’ANGELO *
AND HASHEM, LLC. *
Defendants *
*
v. *
*
JENNIFER M. CARRION *
Plaintiff-Intervenor
DEFENDANT’S OPPOSITION TO PLAINTIFF-INTERVENOR’S MOTION IN LIMINE
NO. IV. RE: CHARACTER ASSASSINATIONS OF COUNSEL MUST BE EXCLUDED
AS A WASTE OF TIME.
Now come the Defendants, Stephen D’Angelo, individually and as a Manager of
D’Angelo Law Group, LLC in opposition to The Plaintiff-Intervenor’s Motion in Limine No. IV.
Re: Character Assassinations of Counsel Must Be Excluded As A Waste Of Time.
As reasons therefore, it is simply beyond the scope of a motion in limine to allege that
unethical conduct will take place at trial by opposing counsel. It is within the province of the
trial judge to control the introduction of evidence and the entire flow of the trial. It is completely
unnecessary, disrespectful and inappropriate to suggest to the trial judge an opinion that a fellow
member of the bar was anticipated to act in contravention of the Rules of Professional Conduct at
trial.
WHEREFORE, the Defendants respectfully moves this Honorable Court to deny the
Plaintiff-Intervenor’s Motion to Plaintiff-Intervenor’s Motion in Limine No. IV. Re: Character
Assassinations of Counsel Must Be Excluded as a Waste of Time, filed April 5, 2021, Docket
No. 167.
Respectfully Submitted,
Defendants, Stephen L. D’Angelo, Individually, and
D’Angelo Law Group, LLC
By their Attorney
Date: April 22, 2021 /s/Thomas C. LaPorte_____
Thomas C. LaPorte, Esquire
BBO #634194
COSSINGHAM LAW OFFICE, PC
30 Massachusetts Ave., Suite 404
North Andover, MA 01845
Tel: 978-685-5686
kcossingham@cossinghamlaw.com
tlaporte@cossinghamlaw.com
CERTIFICATE OF SERVICE
I state that on this day a copy of the foregoing Opposition to Plaintiff-Intervenor’s Motion to
Plaintiff-Intervenor’s Motion in Limine No. IV. Re: Character Assassinations of Counsel Must
Be Excluded As A Waste Of Time, filed April 5, 2021, Docket No. 167, has been e-filed with
Essex Superior Court and served on the following via email through the court’s electronic filing
system to all attorneys and to all other parties who have entered electronic service contacts
(email addresses) in this case. I am mailing or hand delivering copies to all other interested
parties.
Mernaysa Rivera-Bujosa, Esq.
Rivera Bujosa Law, PC
Shipway Place, Unit C2
The Charlestown Navy Yard
Charlestown, MA 02129
mernaysa@riverabujosalaw.com
Saba Hashem
318 Broadway
Methuen, MA 01844
shceh@yahoo.com
Dated: April 22, 2021 /s/ Thomas C. LaPorte_________________
Thomas C. LaPorte, Esquire
espectfully Submitted,
Defendants, Stephen L. D’Angelo,
Individually, and D’Angelo Law Group,
LLC
By their Attorney
Date: April 21, 2021 /s/Thomas C. LaPorte_____
Thomas C. LaPorte, Esquire
BBO #634194
COSSINGHAM LAW OFFICE, PC
30 Massachusetts Ave., Suite 404
North Andover, MA 01845
Tel: 978-685-5686
kcossinghama@cossinghamlaw.com
tlaporte@cossinghamlaw.com
CERTIFICATE OF SERVICE
I state that on this day a copy of the foregoing Opposition to Motion in Limine
___________
has been e-filed with Essex Superior Court and served on the following via email through the
court’s electronic filing system to all attorneys and to all other parties who have entered
electronic service contacts (email addresses) in this case. I am mailing or hand delivering copies
to all other interested parties.
Mernaysa Rivera-Bujosa, Esq.
Rivera Bujosa Law, PC
Shipway Place, Unit C2
The Charlestown Navy Yard
Charlestown, MA 02129
mernaysa@riverabujosalaw.com
Saba Hashem
318 Broadway
Methuen, MA 01844
shceh@yahoo.com
Dated: April 22, 2021 /s/ Thomas C. LaPorte_________________
Thomas C. LaPorte, Esquire
Preview
190 4/22/2021 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. 1677CV1419 * v. * * STEPHEN L. D’ANGELO, D’ANGELO * LAW GROUP, LLC, and D’ANGELO * AND HASHEM, LLC. * Defendants * * v. * * JENNIFER M. CARRION * Plaintiff-Intervenor DEFENDANT’S OPPOSITION TO PLAINTIFF-INTERVENOR’S MOTION IN LIMINE NO. IV. RE: CHARACTER ASSASSINATIONS OF COUNSEL MUST BE EXCLUDED AS A WASTE OF TIME. Now come the Defendants, Stephen D’Angelo, individually and as a Manager of D’Angelo Law Group, LLC in opposition to The Plaintiff-Intervenor’s Motion in Limine No. IV. Re: Character Assassinations of Counsel Must Be Excluded As A Waste Of Time. As reasons therefore, it is simply beyond the scope of a motion in limine to allege that unethical conduct will take place at trial by opposing counsel. It is within the province of the trial judge to control the introduction of evidence and the entire flow of the trial. It is completely unnecessary, disrespectful and inappropriate to suggest to the trial judge an opinion that a fellow member of the bar was anticipated to act in contravention of the Rules of Professional Conduct at trial. WHEREFORE, the Defendants respectfully moves this Honorable Court to deny the Plaintiff-Intervenor’s Motion to Plaintiff-Intervenor’s Motion in Limine No. IV. Re: Character Assassinations of Counsel Must Be Excluded as a Waste of Time, filed April 5, 2021, Docket No. 167. Respectfully Submitted, Defendants, Stephen L. D’Angelo, Individually, and D’Angelo Law Group, LLC By their Attorney Date: April 22, 2021 /s/Thomas C. LaPorte_____ Thomas C. LaPorte, Esquire BBO #634194 COSSINGHAM LAW OFFICE, PC 30 Massachusetts Ave., Suite 404 North Andover, MA 01845 Tel: 978-685-5686 kcossingham@cossinghamlaw.com tlaporte@cossinghamlaw.com CERTIFICATE OF SERVICE I state that on this day a copy of the foregoing Opposition to Plaintiff-Intervenor’s Motion to Plaintiff-Intervenor’s Motion in Limine No. IV. Re: Character Assassinations of Counsel Must Be Excluded As A Waste Of Time, filed April 5, 2021, Docket No. 167, has been e-filed with Essex Superior Court and served on the following via email through the court’s electronic filing system to all attorneys and to all other parties who have entered electronic service contacts (email addresses) in this case. I am mailing or hand delivering copies to all other interested parties. Mernaysa Rivera-Bujosa, Esq. Rivera Bujosa Law, PC Shipway Place, Unit C2 The Charlestown Navy Yard Charlestown, MA 02129 mernaysa@riverabujosalaw.com Saba Hashem 318 Broadway Methuen, MA 01844 shceh@yahoo.com Dated: April 22, 2021 /s/ Thomas C. LaPorte_________________ Thomas C. LaPorte, Esquire espectfully Submitted, Defendants, Stephen L. D’Angelo, Individually, and D’Angelo Law Group, LLC By their Attorney Date: April 21, 2021 /s/Thomas C. LaPorte_____ Thomas C. LaPorte, Esquire BBO #634194 COSSINGHAM LAW OFFICE, PC 30 Massachusetts Ave., Suite 404 North Andover, MA 01845 Tel: 978-685-5686 kcossinghama@cossinghamlaw.com tlaporte@cossinghamlaw.com CERTIFICATE OF SERVICE I state that on this day a copy of the foregoing Opposition to Motion in Limine ___________ has been e-filed with Essex Superior Court and served on the following via email through the court’s electronic filing system to all attorneys and to all other parties who have entered electronic service contacts (email addresses) in this case. I am mailing or hand delivering copies to all other interested parties. Mernaysa Rivera-Bujosa, Esq. Rivera Bujosa Law, PC Shipway Place, Unit C2 The Charlestown Navy Yard Charlestown, MA 02129 mernaysa@riverabujosalaw.com Saba Hashem 318 Broadway Methuen, MA 01844 shceh@yahoo.com Dated: April 22, 2021 /s/ Thomas C. LaPorte_________________ Thomas C. LaPorte, Esquire