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UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
__________________________________________
TOGETHER EMPLOYEES, by
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individual representatives,
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ROBERTA LANCIONE
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JOYCE MILLER, MARIA DIFRONZO,
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MICHAEL SACCOCCIO,
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ELIZABETH BIGGER,
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NATASHA DICICCO,
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NICHOLAS ARNO and
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CIVIL ACTION NO.
RUBEN ALMEIDA,
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Plaintiffs
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v.
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MASS GENERAL BRIGHAM
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INCORPORATED
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Defendant
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PLAINTIFFS’ MOTION FOR LEAVE TO FILE EXCESS PAGES
Plaintiffs move, under Local Rule 7.1, for leave of Court to file excess pages.
As it stands, their Memorandum of Law in Support of their Motion to Dismiss
stands at 35 pages, including exhibits. As reasons for this request, plaintiffs assert:
1. This case involves a matter of great public importance, as it not only seeks to enforce
religious rights under Title VII and disability rights under the ADA, but it impacts
over two hundred plaintiffs and will likely have an impact on many other health
care workers throughout the Commonwealth and the country.
2. Plaintiffs state that additional pages are necessary to adequately address the
arguments supporting their claims under federal law and the irreparable harm that
they will face if their Motion is denied.
3. Included within the 35-page Memorandum are eight pages of exhibits.
Case 1:21-cv-11686 Document 4 Filed 10/17/21 Page 1 of 2
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Plaintiffs, by their attorneys,
/s/ Ryan P. McLane
Ryan P. McLane, Esq. (BBO: 697464)
Lauren Bradford, Esq. (BBO: 700084)
McLane & McLane, LLC
269 South Westfield Street
Feeding Hills, MA 01030
Ph. (413) 789-7771
Fax (413) 789-7731
ryan@mclanelaw.com
lauren@mclanelaw.com
CERTIFICATE OF SERVICE
I hereby certify that on October 17, 2021, I caused the foregoing to be
electronically filed through the Court’s ECF system. I further certify that I will
cause a true and correct copy of the foregoing, along with the Summons and Verified
Complaint (ECF 1), to be served by process server on the defendant.
/s/ Ryan P. McLane
Attorney for Plaintiffs
Case 1:21-cv-11686 Document 4 Filed 10/17/21 Page 2 of 2