Plaintiffs’ Motion for Leave to File Excess Pages
Summary
Plaintiffs' Motion for Leave to File Excess Pages, Document 4 in Case 1:21-cv-11686, filed October 17, 2021, in the United States District Court, District of Massachusetts, in an action by Together Employees, by individual representatives, against Mass General Brigham Incorporated. Plaintiffs move under Local Rule 7.1 for leave to file excess pages, stating that the Memorandum of Law in Support of Plaintiffs' Motion to Dismiss stands at 35 pages, including exhibits. Plaintiffs assert that the case seeks to enforce religious rights under Title VII and disability rights under the ADA and impacts over two hundred plaintiffs, and that additional pages are necessary to address the arguments and the irreparable harm. The motion bears the /s/ signature of Ryan P. McLane for Plaintiffs.
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- Date
- 2021-10-17
Cite this document
“Plaintiffs’ Motion for Leave to File Excess Pages.”
Original at archive.org, dated 2021-10-17. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2021-10-17-covid-era-misc-219fe772-1/
, SHA-256 219fe7729b30722846096a7f5457f092d8c6109a3a8b46281b769d1c995ad8bd.Full text
1 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS __________________________________________ TOGETHER EMPLOYEES, by ) individual representatives, ) ROBERTA LANCIONE ) JOYCE MILLER, MARIA DIFRONZO, ) MICHAEL SACCOCCIO, ) ELIZABETH BIGGER, ) NATASHA DICICCO, ) NICHOLAS ARNO and ) CIVIL ACTION NO. RUBEN ALMEIDA, ) Plaintiffs ) ) v. ) ) MASS GENERAL BRIGHAM ) INCORPORATED ) Defendant ) 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 2 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
File and source
- File
- gov.uscourts.mad.238919.4.0.pdf
- Size
- 108,984 bytes
- SHA-256
- 219fe7729b30722846096a7f5457f092d8c6109a3a8b46281b769d1c995ad8bd
- Our copy
- gov.uscourts.mad.238919.4.0.pdf
- Original
- archive.org