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ESSEX, SS
SABA HASHEM, ihaividval and as
Manager of D'Angelo & Hashem, LLC 1
Plaintiff/Defendant-Intervenor
v.
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,
Vv.
JENNIFER M. CARRION,
COMMONWEALTH OF MASSACHUSETTS
SUPERIOR COURT
C.A. No. 1667CV01419
Plaintiff-Intervenor.
PLAINTIFF-INTER VE] 7 ‘0 EXTEND RESPONSE DATE TO
PAPER # 1
NOW COMES the Plaintiff-Intervenor, Jennifer M. Carrion, who hereby through
Counsel, respectfully;
28, 2021, to respond
requests that this Honorable Court extend time from tomorrow, April
‘o Paper # 177, Affidavit regarding Attorney’s Fees to be paid from
escrow, to after the Trial by Jury scheduled to start May 17, 2021, or alternatively at the
earliest, to next Friday May 7, 2021. AS GROUNDS THEREFORE, Counsel for Plaintiff-
Intervenor states that
Trial Conference tom
(1) this matter is scheduled for Jury Trial on May 17, 2021 with Final
orrow 04/28/2021 at 9:00 am, for which all parties are preparing, (2)
Defendants filed Paper # 180 on April 15, 2021 an Emergency Motion for an order
releasing expert witness retainer in the amount of $10,000 from escrow, which Plaintiff
|
Intervenor opposed in Paper #184, and will be decided by Judge Howe, and (3) beforemaking such ee attorney’s fees and on the expert retainer, the Defendants’ counsel
should clarify to the
Defendants, as submit
For example,
paper # 139 that the
08/20/2020. Howev:
163 that the Defenda:
during the same perio
counsel state that the’
$8,539.65 credit given
‘ourt the grave uncertainty on amounts billed to, and paid by the
itted to this Court.
ithout limitation, Defendants’ attorneys state on 10/05/2020 in
om supposedly paid them $2,717.20 from 11/13/2018 to
er, on February 3, 2021, Defendants’ attorneys submitted in Paper #
nts paid them $20,000.00 from 1/16/2020 to 03/16/2020, which is
das their prior submission, Also in Paper # 139, the Defendants’
gave credit to the Defendants in the amount $8,539.65. The
nin Pape 1 139 disappears in Paper #163 and payment #3505 on
03/16/2020 changed/from $307.50 in Paper #139 to $10,000 in Paper #163. Paper 163
also added Inv# 47339 dated|01/16/2020 that was not in Paper #139, despite being billed
in the same period.
payments. These dis:
Plaintiff-Intervenor c:
C
Attomey’s Affidavit is silent on the prior missing invoices and
epancies need to be addressed respectfully before this Court and
m review. Further, Ms. Carrion submits that granting brief extension
would cause little to no prejudice to the other parties, or alternatively any prejudice caused
to the other parties, if any, would be vastly outweighed by prejudice to Ms. Carrion.
Wherefore, Pl:
DATED: April 27, 2
aintiff-Intervenor requests respectfully the relief sought.
i
Respectfully submitted,
Jennifer M. Carrion, Plaintiff-Intervenor,
By Her Attomey,
i
|
21
/s Mernaysa Rivera-Bujosa
MERNAYSA RIVERA-BUJOSA, ESQ.
Rivera-Bujosa Law, PC
C2 Shipway Place, Charlestown, MA 02129
BBO # 665965Telephone: 617 398 6726 & Facsimile: 617 398 6730
Mermaysa@riverabujosalaw.com
CERTIFICATE OF SERVICE
I, Mernaysa Rivera-Bujosa, Esq., counsel to the Plaintiff-Intervenor, hereby certify that on
this 29" day of January 2021, a copy of the foregoing was served via email to Counsels, to
wit:
.
Thomas C. LaPorte, Esq. Cossingham Law Office, PC, 30 Massachusetts Avenue,
Suite 404, North Andover, MA 01845
Saba Hashem,
shceh@yahoo.com, 318 Broadway Methuen MA 01844
I
7s Memaysa Rivera-Bujosa
Mernaysa Rivera-Bujosa, Esq.
Preview
ESSEX, SS SABA HASHEM, ihaividval and as Manager of D'Angelo & Hashem, LLC 1 Plaintiff/Defendant-Intervenor v. 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, Vv. JENNIFER M. CARRION, COMMONWEALTH OF MASSACHUSETTS SUPERIOR COURT C.A. No. 1667CV01419 Plaintiff-Intervenor. PLAINTIFF-INTER VE] 7 ‘0 EXTEND RESPONSE DATE TO PAPER # 1 NOW COMES the Plaintiff-Intervenor, Jennifer M. Carrion, who hereby through Counsel, respectfully; 28, 2021, to respond requests that this Honorable Court extend time from tomorrow, April ‘o Paper # 177, Affidavit regarding Attorney’s Fees to be paid from escrow, to after the Trial by Jury scheduled to start May 17, 2021, or alternatively at the earliest, to next Friday May 7, 2021. AS GROUNDS THEREFORE, Counsel for Plaintiff- Intervenor states that Trial Conference tom (1) this matter is scheduled for Jury Trial on May 17, 2021 with Final orrow 04/28/2021 at 9:00 am, for which all parties are preparing, (2) Defendants filed Paper # 180 on April 15, 2021 an Emergency Motion for an order releasing expert witness retainer in the amount of $10,000 from escrow, which Plaintiff | Intervenor opposed in Paper #184, and will be decided by Judge Howe, and (3) beforemaking such ee attorney’s fees and on the expert retainer, the Defendants’ counsel should clarify to the Defendants, as submit For example, paper # 139 that the 08/20/2020. Howev: 163 that the Defenda: during the same perio counsel state that the’ $8,539.65 credit given ‘ourt the grave uncertainty on amounts billed to, and paid by the itted to this Court. ithout limitation, Defendants’ attorneys state on 10/05/2020 in om supposedly paid them $2,717.20 from 11/13/2018 to er, on February 3, 2021, Defendants’ attorneys submitted in Paper # nts paid them $20,000.00 from 1/16/2020 to 03/16/2020, which is das their prior submission, Also in Paper # 139, the Defendants’ gave credit to the Defendants in the amount $8,539.65. The nin Pape 1 139 disappears in Paper #163 and payment #3505 on 03/16/2020 changed/from $307.50 in Paper #139 to $10,000 in Paper #163. Paper 163 also added Inv# 47339 dated|01/16/2020 that was not in Paper #139, despite being billed in the same period. payments. These dis: Plaintiff-Intervenor c: C Attomey’s Affidavit is silent on the prior missing invoices and epancies need to be addressed respectfully before this Court and m review. Further, Ms. Carrion submits that granting brief extension would cause little to no prejudice to the other parties, or alternatively any prejudice caused to the other parties, if any, would be vastly outweighed by prejudice to Ms. Carrion. Wherefore, Pl: DATED: April 27, 2 aintiff-Intervenor requests respectfully the relief sought. i Respectfully submitted, Jennifer M. Carrion, Plaintiff-Intervenor, By Her Attomey, i | 21 /s Mernaysa Rivera-Bujosa MERNAYSA RIVERA-BUJOSA, ESQ. Rivera-Bujosa Law, PC C2 Shipway Place, Charlestown, MA 02129 BBO # 665965Telephone: 617 398 6726 & Facsimile: 617 398 6730 Mermaysa@riverabujosalaw.com CERTIFICATE OF SERVICE I, Mernaysa Rivera-Bujosa, Esq., counsel to the Plaintiff-Intervenor, hereby certify that on this 29" day of January 2021, a copy of the foregoing was served via email to Counsels, to wit: . Thomas C. LaPorte, Esq. Cossingham Law Office, PC, 30 Massachusetts Avenue, Suite 404, North Andover, MA 01845 Saba Hashem, shceh@yahoo.com, 318 Broadway Methuen MA 01844 I 7s Memaysa Rivera-Bujosa Mernaysa Rivera-Bujosa, Esq.