TurtleBoy is Running for Protection
not legal advice
Turtleboy and Aiden Kearney are scheduled to be deposed on August 10, 2016. Their lawyer Margaret Meleican is seeking an emergency protective order to prevent the depostion. Below is my Memorandum of Opposition to the protective order.
___________________________________________________
COMMONWEALTH
OF MASACHUSETTS
WORCESTER,
SS SUPERIOR COURT 16-0288 B
********************************
Michael Gaffney, Plaintiff *
*
Vs. *
*
Gordon T. Davis InCity Times *
Rosalie Tirella *
Defendants *
********************************
DEFENDANT GORDON T. DAVIS’ OPPOSITION MEMORANDUM TO MATERIAL WITNESSES’, AIDEN KEARNEY AND TURTLEBOY DIGITAL
MARKETING LLC, MOTION FOR EMERGENCY PROTECTIVE ORDER.
The Pro Se Defendant Gordon T.
Davis respectfully requests this Court to Deny the Material Witnesses’ Motion
for an Emergency Protective Order. The testimonies and documents of the
Witnesses are relevant and reasonably likely to provide material evidence.
Argument
1.
On August 2,
2016 the Honorable Judge Richard T. Tucker ruled that the Plaintiff was
compelled to answer Defendant’s Interrogatory No.17 and No, 18. (Exhibit 1)
2.
Interrogatory
No. 17 deals with the Plaintiff’s relationship to the Witnesses and it
employees. Interrogatory No. 18 deals with conversations between the Witnesses
and the Plaintiff. (Exhibit 2).
3.
The inference
of Judge Tucker’s ruling is that the Witnesses, Aiden Kearney and Turtleboy
Sports have relevant and material evidence for this instant case.
Conclusion
The Defendant, Gordon T. Davis, respectfully
requests that the Court deny the movants’ Motion for an Emergency Protective
Order. The Court in a ruling by Judge Tucker has inferred the relevance of the
testimony of the Witnesses.
Respectfully submitted
Gordon T. Davis
Pro Se Plaintiff
Cc: Margaret Melican, Esq.
Robert Scott
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