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Motion to dismiss massachusetts sample3/30/2024 ![]() (See Exhibit #8.) Yet Defendant still refused to answer Plaintiff’s complaint and discovery. (See Exhibit #7.) On September 10, 2002, almost two years after this case was filed, the NEPLP filed a motion for summary judgment alleging facts that were available to it for more than 22 months. (See Exhibit #6.) NEPLP took Plaintiff’s deposition on January 18, 2002. The NEPLP did proceed, however, to serve interrogatories and requests for production of documents to seek the details of Plaintiff’s case on May 7, 2001. (See Exhibit #5.) Over two years after it was served with process, NEPLP has yet to file an answer to Plaintiff’s Complaint in this case. (See Exhibit #4.) Before the case was remanded, NEPLP filed an answer in federal court, refusing to admit or deny the allegations made against it. District Court rejected both grounds and the case was remanded to this Court. (See Exhibit #1.) The Patriots sought to remove, first on diversity and then, in a subsequent motion, claiming federal preemption. Michael Wilson, Ronald O’Neil, and the New England Patriots (“NEPLP”), alleging negligence against the individual defendants and vicarious liability against NEPLE for the negligence of Dr. Plaintiff filed this lawsuit on Novemagainst Dr. In the alternative, this Court should issue an order deeming admitted Plaintiff’s Requests for Admission served on September 27, 2002. As set forth below, this Court should grant judgment on behalf of the Plaintiff because over two years have passed and the Defendant has refused to respond to the core allegations in Plaintiff’s Complaint. Plaintiff, David Meggett, by and through his undersigned attorneys, moves for judgment against the Defendant New England Patriots Limited Partnership, under M.G.L.c.150C, §2(a). Sign up for US Legal Forms now and get access to a large number of reusable samples.Memorandum of Law in Support of Plaintiff’s Motion for Summary Judgment, or in the Alternative, Thatrequests for Admission be Deemed Admitted It’s an additional step but a necessary one for being certain you’re fully covered.
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