This is not legal advice. When a matter does not have time to go through the normal court process found in Rules of Superior Civil Court, a party can contact the Court by himself (ex parte). That party does not have to inform the other parties before hand of what he is asking the Court to do. The moving party does have to inform the other parties as soon as possible.
COMMONWEALTH OF MASSACHUSETTS
WORCESTER, SS
SUPERIOR COURT
C.A.
No. 1685CV00217 D
********************************
GORDON T. DAVIS, Plaintiff
Vs.
TURTLEBOY SPORTS INC.,
AIDEN KEARNEY,
Defendants
********************************
PLAINTIFF’S EMERGENCY
MOTION FOR POSTPONEMENT OF DEFENDANT’S DEPOSITION AND DUCES TACUMJ.
Background
1. The Plaintiff has filed a Motion for
Protect Order for which a Hearing is scheduled for May 17, 2016. (Exhibit 1)
2. After filing of the Motion for
Protective Order the Defendants scheduled a Deposition of the Plaintiff’s bank.
It is scheduled to take place on May 12, 2016. ( Exhibit 2)
Motion
The Plaintiff respectfully asks the Court
to postpone the Defendants’ Deposition of the Bank until after the Court has
ruled on the Plaintiff’s Motion for a Protective Order.
Argument
As evidenced in the Defendants’ publications found in the
Motion for Protective Order, the Defendants have a history of the misuse of
confidential and private information. The Protective Order is intended to prevent
the Defendants’ intentional dissemination of confidential and privileged
information t0 the public with the purpose of harassment, annoyance, and
ridicule of the Plaintiff and his family.
The ruling
by the Court will not take place until after the scheduled Deposition.
The
Defendants’ will have the opportunity to discover the same information after
the Court has ruled on the Protective Order.
Conclusion
The
Plaintiff respectfully moves for an emergency order to postpone the Deposition
of the Plaintiff bank on May 12, 2016.
Respectfully
submitted,
Gordon T.
Davis Pro
se Plaintiff
Worcester
MA 01604
CERTIFICATE OF
SERVICE
I, Gordon T.
Davis, pro se Plaintiff do here by certify that I have served the a copy of the
Emergency Motion to Postpone the Defendants’ Deposition of the Plaintiff’s Bank
by mean of email and first class mail to
their attorney
Margaret M. Melican, Esq.
2 Foster St.
Worcester MA 01608
No comments:
Post a Comment