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COMMONWEALTH OF MASSACHUSETTS
HAMPDEN, SS. SUPERIOR COURT DEPARTMENT
Hamp, CIVIL ACTION NO. 1779CV903
SUPER IG COUNTY
GEORGIA HENDRICKS, ) Par Byguar
Plaintiff, )
) APR 22 2919
Vv. )
ANDREW CRANE, )
Defendant. )
PLAINTIFF GEORGIA HENDRICKS’ APPLICATION FOR FINAL JUDGMENT
AGAINST THE DEFENDANT ANDREW CRANE
PURSUANT TO MASS. R. CIV. P. 33(a)(4)
Now comes the Plaintiff, Georgia Hendricks, in the above-captioned matter and
pursuant to Mass. R. Civ. P. 33(a)(4), hereby applies for final judgment for relief and
requests a Default Judgment be entered against the Defendant Andrew Crane.
On February 21, 2018, the Plaintiff first served her Interrogatories on Defendant
Andrew Crane by service of process via the Hampden County Sheriff's Department (See
Exhibit 1, Final Request for Answers to Interrogatories of the Defendant Andrew Crane, Ex.
A).
Pursuant to Pursuant to Mass. R: Civ. P. 33(a), the Defendant had 45 days to serve
his answers and/or objections. The 45-day time period for filing the answers and/or
objections has expired and the Defendant, Andrew Crane, failed to file any answers or
objections to the interrogatories.
On February 28, 2019, the Plaintiff sent to the Defendant, pursuant to Mass. R. Civ.
P. 33(a)(3), a Final Request for Answers to Interrogatories of the Defendant Andrew Crane.
The Final Request was sent via US Mail, postage prepaid to the pro se Defendant. (See
Exhibit A, Final Request for Answers to Interrogatories of the Defendant Andrew Crane).
Pursuant to Rule 33(a)(3), the Defendant had 40 days to serve his answers and/or
~,
objections after service of the Final Request. The-Defendant’s answers and/or objections to
the interrogatories were due on April 9, 2019. The 40-day time period for filing the answers
and/or objections after service of the Final Request has expired and the Defendant failed to
file any answers or objections to the interrogatories. Pursuant to Rule 33(a)(6) the clerk
upon receipt of the application for final judgment shall enter an appropriate judgment.
Wherefore application is made that final judgment for relief be entered as
appropriate for the Plaintiff against the Defendant Andrew Crane.
Plaintiff, Georgia Hendricks,
By her attorney,
u
Michael M. D’Isola, BBO No. 548279
Law Offices of Jeffrey S. Glassman, LLC
One International Place, Suite 1810
Boston, MA 02110
(617) 367-2900
mndisola@jeffreysglassman.com
Dated: April 18, 2019
COMMONWEALTH OF MASSACHUSETTS
HAMPDEN, 8S. SUPERIOR COURT DEPARTMENT
CIVIL ACTION NO. 1779CV903
GEORGIA HENDRICKS,
Plaintiff,
Vv.
ANDREW CRANE,
Defendant. )
.
AFFIDAVIT OF MICHAEL M. D’ISOLA
I, Michael M. D’Isola, under oath, hereby depose and state the following:
1 I, Michael M. D’Isola, BBO No. 548279, am a licensed Massachusetts attorney and
represent the plaintiff, Georgia Hendricks in the above-captioned matter.
1am employed by the Law Offices of Jeffrey S. Glassman, LLC.
On February 21, 2018, the Hampden County Sheriff's Office, Division of Civil Process
served the Defendant Andrew Crane with Interrogatories Propounded by the Plaintiff
Georgia Hendricks, to be Answered Under Oath by the Defendant.
Pursuant to Rule 33(a)(3) the Defendants had 45 days to serve their answers and/or
objections. The Defendants’ answer and/or objections were due on or about April 7,
2018.
The 45-day time period for filing the answers and/or objections has expired and the
Defendant , failed to file any answers or objections to the interrogatories.
On February 28, 2019, pursuant to Massachusetts Rule of Civil Procedure 33(a)(3), I sent
a Final Request for Answers to Interrogatories of the Defendant, Andrew Crane.
The Final Request was sent by US Mail postage pre-paid to the pro se Defendant at the
following address: 138 Grattan Street, Chicopee, MA 01020.
The 40-day time period for filing the answers and/or objections after service of the Final
Request has expired and the Defendant failed to file any answers or objections to the
interrogatories.
Pursuant to Rule 33(a)(4) the Plaintiff, Georgia Hendricks now applies for final judgment
for relief and requests that a default judgment be entered against the Defendant, Andrew
Crane,
SIGNED UNDER THE PAINS AND PENALTIES OF PERJURY
THIS 18™ DAY OF APRIL, 2019.
ek Michael M. D’Isola
CERTIFICATE OF SERVICE
I, Michael M. D’Isola, counsel for the plaintiff, hereby certify that on April 18, 2019,
Ihave served the foregoing document by first class mail, postage prepaid to the pro se
Defendant:
Mr. Andrew Crane
138 Grattan Street
Chicopee, MA 01020
Law Offices of Jeffrey S. Glassman, LLC
One International Place, Suite 1810
Boston, MA 02110
(617) 367-2900
mdisola@jeffreysglassman.com
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COMMONWEALTH OF MASSACHUSETTS HAMPDEN, SS. SUPERIOR COURT DEPARTMENT Hamp, CIVIL ACTION NO. 1779CV903 SUPER IG COUNTY GEORGIA HENDRICKS, ) Par Byguar Plaintiff, ) ) APR 22 2919 Vv. ) ANDREW CRANE, ) Defendant. ) PLAINTIFF GEORGIA HENDRICKS’ APPLICATION FOR FINAL JUDGMENT AGAINST THE DEFENDANT ANDREW CRANE PURSUANT TO MASS. R. CIV. P. 33(a)(4) Now comes the Plaintiff, Georgia Hendricks, in the above-captioned matter and pursuant to Mass. R. Civ. P. 33(a)(4), hereby applies for final judgment for relief and requests a Default Judgment be entered against the Defendant Andrew Crane. On February 21, 2018, the Plaintiff first served her Interrogatories on Defendant Andrew Crane by service of process via the Hampden County Sheriff's Department (See Exhibit 1, Final Request for Answers to Interrogatories of the Defendant Andrew Crane, Ex. A). Pursuant to Pursuant to Mass. R: Civ. P. 33(a), the Defendant had 45 days to serve his answers and/or objections. The 45-day time period for filing the answers and/or objections has expired and the Defendant, Andrew Crane, failed to file any answers or objections to the interrogatories. On February 28, 2019, the Plaintiff sent to the Defendant, pursuant to Mass. R. Civ. P. 33(a)(3), a Final Request for Answers to Interrogatories of the Defendant Andrew Crane. The Final Request was sent via US Mail, postage prepaid to the pro se Defendant. (See Exhibit A, Final Request for Answers to Interrogatories of the Defendant Andrew Crane). Pursuant to Rule 33(a)(3), the Defendant had 40 days to serve his answers and/or ~, objections after service of the Final Request. The-Defendant’s answers and/or objections to the interrogatories were due on April 9, 2019. The 40-day time period for filing the answers and/or objections after service of the Final Request has expired and the Defendant failed to file any answers or objections to the interrogatories. Pursuant to Rule 33(a)(6) the clerk upon receipt of the application for final judgment shall enter an appropriate judgment. Wherefore application is made that final judgment for relief be entered as appropriate for the Plaintiff against the Defendant Andrew Crane. Plaintiff, Georgia Hendricks, By her attorney, u Michael M. D’Isola, BBO No. 548279 Law Offices of Jeffrey S. Glassman, LLC One International Place, Suite 1810 Boston, MA 02110 (617) 367-2900 mndisola@jeffreysglassman.com Dated: April 18, 2019 COMMONWEALTH OF MASSACHUSETTS HAMPDEN, 8S. SUPERIOR COURT DEPARTMENT CIVIL ACTION NO. 1779CV903 GEORGIA HENDRICKS, Plaintiff, Vv. ANDREW CRANE, Defendant. ) . AFFIDAVIT OF MICHAEL M. D’ISOLA I, Michael M. D’Isola, under oath, hereby depose and state the following: 1 I, Michael M. D’Isola, BBO No. 548279, am a licensed Massachusetts attorney and represent the plaintiff, Georgia Hendricks in the above-captioned matter. 1am employed by the Law Offices of Jeffrey S. Glassman, LLC. On February 21, 2018, the Hampden County Sheriff's Office, Division of Civil Process served the Defendant Andrew Crane with Interrogatories Propounded by the Plaintiff Georgia Hendricks, to be Answered Under Oath by the Defendant. Pursuant to Rule 33(a)(3) the Defendants had 45 days to serve their answers and/or objections. The Defendants’ answer and/or objections were due on or about April 7, 2018. The 45-day time period for filing the answers and/or objections has expired and the Defendant , failed to file any answers or objections to the interrogatories. On February 28, 2019, pursuant to Massachusetts Rule of Civil Procedure 33(a)(3), I sent a Final Request for Answers to Interrogatories of the Defendant, Andrew Crane. The Final Request was sent by US Mail postage pre-paid to the pro se Defendant at the following address: 138 Grattan Street, Chicopee, MA 01020. The 40-day time period for filing the answers and/or objections after service of the Final Request has expired and the Defendant failed to file any answers or objections to the interrogatories. Pursuant to Rule 33(a)(4) the Plaintiff, Georgia Hendricks now applies for final judgment for relief and requests that a default judgment be entered against the Defendant, Andrew Crane, SIGNED UNDER THE PAINS AND PENALTIES OF PERJURY THIS 18™ DAY OF APRIL, 2019. ek Michael M. D’Isola CERTIFICATE OF SERVICE I, Michael M. D’Isola, counsel for the plaintiff, hereby certify that on April 18, 2019, Ihave served the foregoing document by first class mail, postage prepaid to the pro se Defendant: Mr. Andrew Crane 138 Grattan Street Chicopee, MA 01020 Law Offices of Jeffrey S. Glassman, LLC One International Place, Suite 1810 Boston, MA 02110 (617) 367-2900 mdisola@jeffreysglassman.com