Jury Demand in Rodriguez, Felix vs. Fathers and Sons, Inc. et al| Trellis.Law

On January 11, 2021 a Answer was filed involving a dispute between Rodriguez, Felix, and Dore, Susan, Fathers And Sons, Inc., for Torts in the District Court of Hampden County.

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COMMONWEALTH OF MASSACHUSETTS

HAMPDEN, SS SUPERIOR COURT DEPT.
C.A. NO. 2021-0015

FELIX RODRIGUEZ, TY
HAMP. DEN_COUNRT
Plaintiff, SUPE RIOR_GOU
ED

Vv. APR 22 2821
FATHERS AND SONS, INC. and
SUSAN DORE,
Defendants,

ANSWER AND JURY CLAIM OF DEFENDANT, FATHERS & SONS, INC..
TO PLAINTIFF’S COMPLAINT

Defendant, Fathers & Sons, Inc. (incorrectly identified in Plaintiff's Complaint as

Fathers and Sons, Inc.), responds to Plaintiff's Complaint as follows:

Nature of Action

1 Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If

this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are

denied. Further, Fathers & Sons, Inc. moves to strike the improper ad damnum contained in

this Paragraph, in violation of M.G.L. c. 231, § 13B.

2. Fathers & Sons, Inc, states that this paragraph contains conclusions of law. If

this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are

denied.

Jurisdiction and Venue

3 Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If

KEYES AND this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are
DONNELLAN. RC.
ATTORNEYS AT LAW denied.
293 BRIDGE STREET
SUITE 600
SPRINGFIELD, MA 01103
(413) 781-6540

In
--

The Parties

4 Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 4
to form a
of Plaintiff's Complaint because it is without knowledge or information sufficient
allegations
belief as to the truth of the allegations. If this paragraph is construed to contain any

against Fathers & Sons, Inc., they are denied.

5 Fathers & Sons, Inc. admits that it is a Massachusetts corporation with a

Fathers
principal place of business at 434 Memorial Avenue, West Springfield, Massachusetts.
Complaint.
& Sons, Inc. denies the remaining allegations contained in paragraph 5 of Plaintiffs

6 Fathers & Sons, Inc. admits that Susan Dore is a resident of Massachusetts and

dealership
that Susan Dore is currently employed by Fathers & Sons, Inc. at its Volkswagen
Inc. denies
located at 434 Memorial Avenue, West Springfield, Massachusetts. Fathers & Sons,

the remaining allegations contained in paragraph 6 of Plaintiff's Complaint.

7 Fathers & Sons, Inc. admits that it services vehicles at its Volkswagen dealership
Inc. denies
located at 434 Memorial Avenue, West Springfield, Massachusetts. Fathers & Sons,

the remaining allegations contained in paragraph 7 of Plaintiff's Complaint.

8 Fathers & Sons, Inc. states that, to the extent that paragraph 8 of Plaintiff's
paragraph
Complaint refers to a document or documents, the document speaks for itself. If this
are denied.
is construed to contain any additional allegations against Fathers & Sons, Inc., they

& Sons, Inc. admits that, on October 20, 2020, Susan Dore was
9 Fathers

Memorial
employed by Fathers & Sons, Inc. at its Volkswagen dealership located at 434

Avenue, West Springfield, Massachusetts. Fathers & Sons, Inc. denies the remaining

KEYES AND allegations contained in paragraph 9 of Plaintiff's Complaint.
DONNELLAN, RC.
ATTORNEYS AT LAW
293 BRIDGE STREET.
SUITE 600
SPRINGFIELD, MA 01103
(13) 781-6540
-

10. Fathers & Sons, Inc. admits that, during the specified period of time from

October 20, 2020 through October 23, 2020, Susan Dore was employed by Fathers & Sons, Inc.

as a Service Advisor at its Volkswagen dealership located at 434 Memorial Avenue, West

Springfield, Massachusetts, Fathers & Sons, Inc. denies the remaining allegations contained in

paragraph 10 of Plaintiff's Complaint.

11. Fathers & Sons, Inc. admits that it hired Susan Dore. Fathers & Sons, Inc. denies

the remaining allegations contained in paragraph 11 of Plaintiff's Complaint.

12. Fathers & Sons, Inc. denies the allegations contained in paragraph 12 of

Plaintiff's Complaint.

13. Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If

this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are

denied.

14. Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If

this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are

denied.

15. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 15

of Plaintiff's Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

16. Fathers & Sons, Inc. admits that Susan Dore was the Service Advisor for the

vehicle described in Exhibit A (hereinafter the “vehicle”) when it was brought to the Fathers &

KEYES AND Sons, Inc. Volkswagen dealership located at 434 Memorial Avenue, West Springfield,
DONNELLAN, Pc.
ATTORNEYS AT LAW
298 BRIDGE STREET
SUITE 600
SPRINGFIELD, MA 01103
(413) 781
IMassachusetts on or about October 19, 2020. Fathers & Sons, Inc. denies the remaining

lallegations contained in paragraph 16 of Plaintiff's Complaint.

Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If
17.

& Sons, Inc., they are
this paragraph is construed to contain any allegations against Fathers

denied.
law. If
18. Fathers & Sons, Inc. states that this paragraph contains conclusions of

& Sons, Inc., they are
this paragraph is construed to contain any allegations against Fathers

denied.
Dore
19. Fathers & Sons, Inc. admits that, on or about October 20, 2000, Susan

ual about the vehicle,
called the phone number provided by the customer, spoke to an individ
installed in the vehicle
and conveyed the recommendation that an OEM starter be ordered and
the remaining
once the part was received by Fathers & Sons, Inc. Fathers & Sons, Inc. denies

allegations contained in paragraph 19 of Plaintiff's Complaint.
individual
20. Fathers & Sons, Inc. admits that, on or about October 20, 2000, the

recommendation that
speaking with Susan Dore on the phone about the vehicle agreed to the
d by Fathers &
an OEM starter be ordered and installed in the vehicle once the part was receive
of
Sons, Inc. Fathers & Sons, Inc. denies the remaining allegations contained in paragraph 20

Plaintiff's Complaint.

21. Fathers & Sons, Inc. admits that, on or about October 20, 2000, Susan Dore

the installation
informed the individual speaking with her on the phone about the vehicle that

of an OEM starter in the vehicle was estimated to cost $640.67. Fathers & Sons, Inc. denies

KEYES AND the remaining allegations contained in paragraph 21 of Plaintiff's Complaint.
DONNELLAN, Pc.
ATTORNEYS AT LAW
293 BRIDGE STREET.
SUITE 600
SPRINGFIELD, MA 01103
«ata 781-6540
22. Fathers & Sons, Inc. admits that, on or about October 21, 2000, it placed the

order for the OEM starter for the vehicle, which was estimated to arrive the morning of October

23, 2020. Fathers & Sons, Inc. denies the remaining allegations contained in paragraph 22 of

Plaintiff's Complaint.

23. Fathers & Sons, Inc. admits that an individual subsequently made a request to

Susan Dore that the starter be installed in the vehicle by an earlier date than was possible for it

to be installed. Fathers & Sons, Inc. denies the remaining allegations contained in paragraph

23 of Plaintiff's Complaint.

24. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 24

of Plaintiff's Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

25. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 25
a
of Plaintiffs Complaint because it is without knowledge or information sufficient to form

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

26. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 26
form a
of Plaintiff's Complaint because it is without knowledge or information sufficient to

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

27. Fathers & Sons, Inc. admits that the OEM starter for the vehicle did not arrive

in the
KEYES AND at Fathers & Sons, Inc. on the morning of October 23, 2020, and was thus not installed
DONNELLAN, RC.
ATTORNEYS AT LAW
293 BRIDGE STREET
SUITE 600
SPRINGFIELD, MA 01103
«a13) 781-6540
vehicle on that date. Fathers & Sons, Inc. denies the remaining allegations contained in

paragraph 27 of Plaintiff's Complaint.

28. Fathers & Sons, Inc. denies the allegations contained in paragraph 28 of

Plaintiff's Complaint.

29. Fathers & Sons, Inc. denies the allegations contained in paragraph 29 of

Plaintiff's Complaint.

30. Fathers & Sons, Inc. admits that Susan Dore spoke to an individual on the phone

and was informed that the vehicle would be picked up on October 23, 2020, without installation

of the OEM starter. Fathers & Sons, Inc. denies the remaining allegations contained in

paragraph 30 of Plaintiff's Complaint.

31. Fathers & Sons, Inc. admits that Susan Dore informed an individual via phone

that $194.94, which included the originally quoted diagnostic fee and restocking charge, was

owed for the services on the vehicle performed by Fathers & Sons, Inc. after cancellation of the

installation of the OEM starter in the vehicle, Fathers & Sons, Inc. denies the remaining

allegations contained in paragraph 31 of Plaintiff's Complaint.

32. Fathers & Sons, Inc. admits that an individual indicated to Susan Dore on or

about October 23, 2020 that a court action would be filed against her regarding the vehicle.

Fathers & Sons, Inc. denies the remaining allegations contained in paragraph 32 of Plaintiff's

Complaint.

33. Fathers & Sons, Inc. denies the allegations contained in paragraph 33 of

Plaintiff's Complaint.

34, Fathers & Sons, Inc. admits that individuals who identified themselves as
KEYES AND
DONNELLAN, RC.
ATTORNEYS AT LAW Plaintiff's family members arrived at the Fathers & Sons, Inc. Volkswagen dealership located
293 BRIDGE STREET
SUITE 600
SPRINGFIELD, MA 01103
(413) 781
and
lat 434 Memorial Avenue, West Springfield, Massachusetts on or about October 23, 2020

met with Susan Dore regarding picking up the vehicle. Fathers & Sons, Inc. denies the

remaining allegations contained in paragraph 34 of Plaintiff's Complaint.

35. Fathers & Sons, Inc. denies the allegations contained in paragraph 35 of

Plaintiff's Complaint.

36. Fathers & Sons, Inc. states that, to the extent that paragraph 36 of Plaintiff's

Complaint refers to a document or documents, the document speaks for itself. If this paragraph
are denied.
is construed to contain any additional allegations against Fathers & Sons, Inc., they

37. Fathers & Sons, Inc. admits that individuals who identified themselves as

The
Plaintiff's family members were directed by Susan Dore to where the vehicle was parked.
Dore had the
individual(s) later reported to Susan Dore that the yehicle did not start, and Susan

service manager for the dealership arrange to have the vehicle jumped. Fathers & Sons, Inc.

denies the remaining allegations contained in paragraph 37 of Plaintiff's Complaint.

38. Fathers & Sons, Inc. denies the allegations contained in paragraph 38 of

Plaintiff's Complaint.

39. Fathers & Sons, Inc. denies the allegations contained in paragraph 39 of

Plaintiff's Complaint.

40. Fathers & Sons, Inc. denies the allegations contained in paragraph 40 of

Plaintiff's Complaint.

41. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 41
t to form a
of Plaintiff's Complaint because it is without knowledge or information sufficien
ns
KEYES AND belief as to the truth of the allegations. If this paragraph is construed to contain any allegatio
DONNELLAN, RC.
ATTORNEYS AT LAW against Fathers & Sons, Inc., they are denied.
293 BRIDGE STREET
SUITE 600
SPRINGFIELD, MA 01103
(413 781-6540
42. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 42

of Plaintiff's Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

43. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 43

of Plaintiffs Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

44. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 44

of Plaintiffs Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

45. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 45

of Plaintiff's Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

46. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 46

of Plaintiff's Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

47. Fathers & Sons, Inc. denies the allegations contained in paragraph 47 of

KEYES AND Plaintiff's Complaint.
DONNELLAN, RC.
ATTORNEYS AT LAW
293 BRIDGE STREET
SUITE 600
SPRINGFIELD, MA 01103
(413) 781-6540
-

48. Fathers & Sons, Inc. denies the allegations contained in paragraph 48 of

Plaintiff's Complaint.

49. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 49

of Plaintiff's Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

50. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 50

of Plaintiff's Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

51. Fathers & Sons, Inc. can neither admit nor deny the allegations of paragraph 51

of Plaintiff's Complaint because it is without knowledge or information sufficient to form a

belief as to the truth of the allegations. If this paragraph is construed to contain any allegations

against Fathers & Sons, Inc., they are denied.

COUNT I
(Negligence Against Fathers & Sons, Inc.)

52. Fathers & Sons, Inc. repeats and restates its answers to the allegations of

paragraph nos. 1 through 51 of Plaintiff's Complaint as if expressly rewritten and set forth

herein.

53. Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If

this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are

denied.
KEYES AND
DONNELLAN, PC. 34. Fathers & Sons, Inc. denies the allegations contained in paragraph 54 of
ATTORNEYS AT LAW
293 BRIDGE STREET Plaintiff's Complaint.
SUITE 600
SPRINGFIELD, MA 01103
(413) 781-6540
Fathers & Sons, Inc. denies the allegations contained in paragraph 55 of
55.

Plaintiff’s Complaint.

56. Fathers & Sons, Inc. denies the allegations contained in paragraph 56 of

Plaintiff's Complaint.

57. Fathers & Sons, Inc. denies the allegations contained in paragraph 57 of

Plaintiff's Complaint.

38. Fathers & Sons, Inc. denies the allegations contained in paragraph 58 of

Plaintiff's Complaint.

59. Fathers & Sons, Inc. denies the allegations contained in paragraph 59 of

Plaintiff's Complaint.

Fathers & Sons, Inc. . denies the allegations contained in paragraph 60
of
60.

Plaintiff's Complaint.

COUNT IT
(Respondent (sic) Superior Against Fathers & Sons, Inc.)

61. Fathers & Sons, Inc. repeats and restates its answers to the allegations of

rewritten and set forth
paragraph nos. 1 through 51 of Plaintiffs Complaint as if expressly

herein.
62 of
62. Fathers & Sons, Inc. denies the allegations contained in paragraph

Plaintiff's Complaint.
63 of
63. Fathers & Sons, Inc. denies the allegations contained in paragraph

Plaintiffs Complaint.
If
64. Fathers & Sons, Inc. states that this paragraph contains conclusions of law.
KEYES AND
Fathers & Sons, Inc., they are
DONNELLAN, PC. this paragraph is construed to contain any allegations against
ATTORNEYS AT LAW
293 BRIDGE STREET
denied.
SUITE 600
SPRINGFIELD, MA 01103
(413) 781-6540 10
65. Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If

this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are

denied.

66. Fathers & Sons, Inc. . denies the allegations contained in paragraph 66 of

Plaintiff's Complaint.

67. Fathers & Sons, Inc. . denies the allegations contained in paragraph 67 of

Plaintiff's Complaint.

68. Fathers & Sons, Inc. . denies the allegations contained in paragraph 68 of

Plaintiff's Complaint.

69. Fathers & Sons, Inc. . denies the allegations contained in paragraph 69 of

Plaintiff's Complaint.

70. Fathers & Sons, Inc. . denies the allegations contained in paragraph 70 of

Plaintiffs Complaint.

COUNTUT
(Negligent Entrustment Against Fathers & Sons, Inc.)

71. Fathers & Sons, Inc. repeats and restates its answers to the allegations of

paragraph nos. | through 51 of Plaintiffs Complaint as if expressly rewritten and set forth

herein.

72. Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If

this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are

denied.

73. Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If
KEYES AND
DONNELLAN, RC. this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are
ATTORNEYS AT LAW
293 BRIDGE STREET denied.
SUITE 600
SPRINGFIELD, MA 01103
(at3) 761-6540 11
74. Fathers & Sons, Inc. denies the allegations contained in paragraph 74 of

Plaintiff's Complaint.

75. Fathers & Sons, Inc. denies the allegations contained in paragraph 75 of

Plaintiff's Complaint.

COUNT IV
(Negligent Supervision Against Fathers & Sons, Inc.)

76. Fathers & Sons, Inc. repeats and restates its answers to the allegations of

paragraph nos. 1 through 51 of Plaintiffs Complaint as if expressly rewritten and set forth

herein.

77. Fathers & Sons, Inc. denies the allegations contained in paragraph 77 of

Plaintiff's Complaint.

BB. Fathers & Sons, Inc. states that this paragraph contains conclusions of law. If

this paragraph is construed to contain any allegations against Fathers & Sons, Inc., they are

denied.

79. Fathers & Sons, Inc. denies the allegations contained in paragraph 79 of

Plaintiff's Complaint.

80. Fathers & Sons, Inc. denies the allegations contained in paragraph 80 of

Plaintiff's Complaint.

81. Fathers & Sons, Inc. denies the allegations contained in paragraph 81 of

Plaintiff's Complaint.

KEYES AND
DONNELLAN, RC.
ATTORNEYS AT LAW
293 BRIDGE STREET
SUITE 600
SPRINGFIELD, Ma 01103
(418) 781-6540 12
COUNT V
(Negligence Against Susan Dore)

82. Fathers & Sons, Inc. repeats and restates its answers to the allegations of

paragraph nos. 1 through 51 of Plaintiffs Complaint as if expressly rewritten and set forth

herein.

83. This paragraph contains allegations regarding another defendant, and as such

does not require a response from Fathers & Sons, Inc. If the paragraph is construed to contain

any allegations against Fathers & Sons, Inc., they are denied.

84. This paragraph contains allegations regarding another defendant, and as such

does not require a response from Fathers & Sons, Inc. If the paragraph is construed to contain

any allegations against Fathers & Sons, Inc., they are denied.

85. This paragraph contains allegations regarding another defendant, and as such

does not require a response from Fathers & Sons, Inc. If the paragraph is construed to contain

any allegations against Fathers & Sons, Inc., they are denied.

86. This paragraph contains allegations regarding another defendant, and as such

does not require a response from Fathers & Sons, Inc. If the paragraph is construed to contain

any allegations against Fathers & Sons, Inc., they are denied.

First Defense

Defendant denies any and all remaining and heretofore unanswered allegations

contained in Plaintiff's Complaint.

Second Defense
KEYES AND
DONNELLAN, RC. Defendant expressly denies that Plaintiff is currently entitled to judgment against it for
ATTORNEYS AT LAW
293 BRIDGE STREET any reason or cause.
SUITE 600
SPRINGFIELD, MA 01103
13) 781-6540 13
Third Defense

Plaintiff fails to allege a claim upon which relief can be granted. Wherefore, Defendant

moves pursuant to Mass. R. Civ. P. 12(b)(6) that Plaintiff's Complaint be dismissed, with costs

to Defendant.

Fourth Defense

Plaintiff has failed to exhaust, or allow to be exhausted, all available administrative

remedies and/or otherwise failed to comply with the statutory prerequisites for the bringing of

his claims.

Fifth Defense

Plaintiffs Complaint fails for insufficiency of process and insufficiency of service of

process upon Defendant in accordance with the applicable provisions of law. Wherefore,

Defendant moves that Plaintiffs Complaint be dismissed under the provisions of Mass. R. Civ.

P. 12(b)(4) and 12(b)(5) due to the insufficiency of process and insufficiency of service of

process.

Sixth Defense

Plaintiff breached his agreement with Defendant and is thereby barred from recovery in

this action.

Seventh Defense

The damages alleged were caused in whole or in part by Plaintiff's own negligence, or

by the negligence of person for whose conduct Plaintiff was legally responsible.

Eighth Defense

KEYES AND The damages alleged were not caused by the acts of any person for whose conduct
DONNELLAN, RC.
ATTORNEYS AT LAW Defendant was legally responsible.
293 BRIOGE STREET
SUITE 600
SPRINGFIELD, Ma 01103
(13) 781-6540 14
-

Ninth Defense

The acts or omissions complained of by Plaintiff were not within the scope of any

contractual obligations undertaken by Defendant.

Tenth Defense

Plaintiffs Complaint in the above action fails on the basis of misnomer of a party.

Wherefore, Defendant moves that Plaintiff's Complaint be dismissed under the provisions of

Mass. R. Civ. P. 12(b) (8).

Eleventh Defense

Plaintiff's claims against Defendant are insubstantial and frivolous and, pursuant to G.

L. c, 231, § 6F, Defendant moves for an award of the reasonable counsel fees and other costs

and expenses incurred in defending against Plaintiff's claims.

JURY DEMAND

Defendant, Fathers & Sons, Inc., requests a trial by jury.

WHEREFORE, Defendant, Fathers & Sons, Inc., requests that judgment be entering

dismissing Plaintiff's Complaint with prejudice and awarding Fathers & Sons, Inc. all costs,

disbursements and attorneys’ fees associated with this litigation.

Respectfully submitted,

Fathers & Sons, Inc.,
By Its Attorneys,

Dated: April 20, 2021
Michael B. Doherty, Esquire
293 Bridge Street, Suite 600
Springfield, MA 01103
(413) 781-6540
(413) 739-3502 FAX
mdoherty@keyesanddonnellan.com

CERTIFICATE OF SERVICE

I, Michael B. Doherty, Esquire, of Keyes and Donnellan, P.C., 293 Bridge Street,
Springfield, Massachusetts, hereby certify that on the 20" day of April, 2021, I caused a copy of
the foregoing document to be sent to Plaintiff by mailing, first class mail, postage prepaid, to the
following:

Felix Rodriguez (#433178)

wt
Hartford Correctional Center
177 Weston Street
Hartford, CT 06120

v Michael B. Doherty Y

KEYES AND
DONNELLAN, PC.
ATTORNEYS AT LAW
293 BRIDGE STREET
SUITE 600
SPRINGFIELD, MA 01103
«a13) 781-6540 16

Case Info

Judge

Francis E. Flannery Track Judge’s New Case

Case No.

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Document Filed Date

April 22, 2021

Case Filing Date

January 11, 2021

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Answer: Rodriguez, Felix vs. Fathers and Sons, Inc. et al

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