On October 27, 2014 a
Party Discovery
was filed
involving a dispute between
Smith, Richard N,
and
Barnstable County Sheriff'S Office,
for Actions Involving the State/Municipality
in the District Court of Barnstable County.
Preview
a.
COMMONWEALTH OF MASSACHUSETTS
BARNSTABLE, ss SUPERIOR COURT DEPARTMENT
CIVIL ACTION 2014-528
RICHARD N. SMITH, DT
Plaintiff
)
)
: ) a
v.
5 OD all
BARNSTABLE COUNTY SHERIFF’S OFFICE ) o
)
Defendant
DEFENDANTS’ MOTION FOR A COURT ORDER TO DEPOSE_ WITNESS
DAVID THRIFT AT NCCI GARDNER, STATE PRISON
The Defendants, through counsel, hereby request that the Court allow the Defendant’s
counsel leave to take the deposition of David Thrift, a fact witness in this matter pursuant to
Mass. R. Civ. PB. 30(a)(2). Under the Rules of Civil Procedure the Court must allow such
deposition.
Said deposition upon oral examination before a certified court reporter, if allowed, will
take place at the state prison in Gardner, MA on August 4, 2016 at 10:00 AM and continuing
thereafter until complete.
WHEREFORE, the Defendants respectfully request that their counsel be granted leave to
depose the Plaintiff forthwith pursuant to Mass. R. Civ. P. 30(a)(2).
Respectfully submitted,
SUPERIOR COURT For the Barnstable County Sheriff's Office Defendants,
BARNSTABLE, SS
FILED] JUN 10 2016
Set bo Ueen-Clerk Matthew I. Murphy
General Counsel
Special Assistant Attorney General
1
Document Filed Date
June 22, 2016
Case Filing Date
October 27, 2014
Category
Actions Involving the State/Municipality
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a. COMMONWEALTH OF MASSACHUSETTS BARNSTABLE, ss SUPERIOR COURT DEPARTMENT CIVIL ACTION 2014-528 RICHARD N. SMITH, DT Plaintiff ) ) : ) a v. 5 OD all BARNSTABLE COUNTY SHERIFF’S OFFICE ) o ) Defendant DEFENDANTS’ MOTION FOR A COURT ORDER TO DEPOSE_ WITNESS DAVID THRIFT AT NCCI GARDNER, STATE PRISON The Defendants, through counsel, hereby request that the Court allow the Defendant’s counsel leave to take the deposition of David Thrift, a fact witness in this matter pursuant to Mass. R. Civ. PB. 30(a)(2). Under the Rules of Civil Procedure the Court must allow such deposition. Said deposition upon oral examination before a certified court reporter, if allowed, will take place at the state prison in Gardner, MA on August 4, 2016 at 10:00 AM and continuing thereafter until complete. WHEREFORE, the Defendants respectfully request that their counsel be granted leave to depose the Plaintiff forthwith pursuant to Mass. R. Civ. P. 30(a)(2). Respectfully submitted, SUPERIOR COURT For the Barnstable County Sheriff's Office Defendants, BARNSTABLE, SS FILED] JUN 10 2016 Set bo Ueen-Clerk Matthew I. Murphy General Counsel Special Assistant Attorney General 1