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  • WO21D1203DR Chase, Cheryl L. vs. Chase, Gary M. Divorce 1B document preview
  • WO21D1203DR Chase, Cheryl L. vs. Chase, Gary M. Divorce 1B document preview
						
                                

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Worcester Probate and Family Court Date Filed: 6/18/2021 9:33 AM Case Number: Commonwealth of Massachusetts THE TRIAL COURT PROBATE AND FAMILY COURT DEPARTMENT WORCESTER DIVISION DOCKET NO.: NOT YET ASSIGNED CHERYL L. CHASE, PLAINTIFF Vv GARY M. CHASE, DEFENDANT. PLAINTIFF’S MOTION FOR LEAVE TO FILE MARRIAGE CERTIFICATE LATE NOW COMES Plaintiff, CHERYL CHASE, in the above-captioned matter and respectfully moves this Honorable Court to allow Plaintiff to file a Complaint for Divorce without filing a certified copy of the Marriage Certificate at this time, as the Marriage Certificate is in the process of being obtained. In support thereof, the Plaintiff states: 1 The parties were married on August 2, 1986 in Worcester, MA. 2 The marriage certificate in the Plaintiffs possession is worn and illegible and was rejected when Plaintiffs counsel attempted to e-file same with the Court. A formal request has been issued by Plaintiff's counsel to the Department of Vital Statistics to obtain an original certified copy of the marriage certificate. 3 It is necessary for the Plaintiff to proceed forthwith by filing the Complaint for Divorce and moving this matter forward, including obtaining orders as may be necessary. 4 Counsel for the Plaintiff shall immediately upon receipt of the original, certified copy of the marriage certificate file same with the Court. Respectfully submitted. CHERYL CHASE, By her Attorne Erin: apiro Esq., BBO# 637730 eshapiro(@atwoodcherny.cor Atwood & Cherny, P.C. 177 Huntington Ave., 23" Floor Boston, MA 02115 Dated: June 18, 2021 T: (617) 262-6400