As always this is not legal advice. This is a motion for a protective order to make sure that Turtleboy does not use anything I give him to harass me or my clients.
COMMONWEALTH OF MASACHUSETTS
WORCESTER, SS
SUPERIOR COURT
C.A. No. 1685CV00217 D
********************************
GORDON T. DAVIS, Plaintiff
Vs.
TURTLEBOY SPORTS INC.,
AIDEN KEARNEY, *
Defendants
********************************
PLAINTIFF’S MOTION FOR
PROTECTIVE ORDER
The Pro Se Plaintiff respectfully
requests that this Court issue a
protective order allowing the
parties to use confidential, privileged, and/or
private information in this
litigation while ensuring that such information is
kept confidential and not
disseminated into the public domain. In support of
this motion the Plaintiff states
the following:
1. The Defendants are bloggers who
own and run a Blog doing business as Turtleboy Sports. (Exhibit 1)
2. The Defendants are being sued by
the Plaintiff for defamation. The Plaintiff alleges that the Defendants wrote
in their blog that the Plaintiff is “mentally unstable”, “senile”, and “crazy”.
(Exhibit 2)
3. The Defendants’ blog and other
publications routinely subject people to annoyance,
embarrassment, and oppression in order to make money. (Exhibit 3)
4. The defense
counsel, Margaret M. Melican, also writes for the Defendants’ blog. What she
write makes fun and ridicules private people. (Exhibit 4)
5. The
Plaintiff claim is that the alleged defamation has resulted in loss clients and
income for his sole practice Advocacy. The Defendants have requested as a part
of discovery private and privileged information, including information
regarding Plaintiff’s clients.
(Exhibit 5)
6. The
dissemination of the private and privileged information to the public will
cause the Plaintiff additional loss of clients and income.
7, Some of the discovery
information requested by the Defendants’ is confidential and confidential by
statute and regulation. An example of such information is the documents such as
the complaints written for clients at the Massachusetts Commission Against
Discrimination (MCAD). (Exhibit 6)
Accordingly the Plaintiff
respectfully requests the Court to issue the
attached Protective Order to
allow the use private, privileged, and
confidential information solely
in this litigation as well as to protect such
private, privileged, and / or
confidential information from inappropriate use
or dissemination outside of this
litigation.
Respectfully submitted
Gordon T. Davis
Pro Se Plaintiff
CERTIFICATE OF
SERVICE
I, Gordon T.
Davis, pro se Plaintiff do here by certify that I have served a copy of
Plaintiff’s Motion for Protective Order to the Defendants by mean of first
class mail to their attorney at
Margaret M. Melican, Esq.
2 Foster St.
Worcester MA 01608
____________ ________
Gordon T.
Davis
Date
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