Motion for Preliminary Injunction and Evidentiary Hearing — Together Employees v. Mass General Brigham

Summary

Plaintiffs' Motion for Preliminary Injunction and for Evidentiary Hearing and Expedited Schedule, Document 2 filed 10/17/21 in Together Employees, by individual representatives, v. Mass General Brigham Incorporated, Case 1:21-cv-11686, in the U.S. District Court for the District of Massachusetts. Plaintiffs move for a preliminary injunction on claims of religious discrimination, disability discrimination and retaliation under Title VII and the ADA. The motion states that plaintiffs face imminent adverse action, including being placed on unpaid leave on October 20, 2021 and subsequently termination on November 5, 2021, and asks for an expedited schedule and an evidentiary hearing. A certificate of service dated October 17, 2021 follows.

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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 PRELIMINARY INJUNCTION AND

FOR AND EVIDENTIARY HEARING AND EXPEDITED SCHEDULE

Plaintiffs move, under Fed. R. Civ. P. 65 and Local Rule 7.1, for Preliminary
Injunction for their claims of religious discrimination, disability discrimination and
retaliation under Title VII and the ADA. Plaintiffs face imminent adverse action,
including being placed on unpaid leave on October 20, 2021 and subsequently
termination on November 5, 2021. Therefore, plaintiffs are seeking that this Court
issue an expedited schedule and an evidentiary hearing so that they can present
evidence, including witness testimony in support of their Motion for Preliminary
Injunction.

Case 1:21-cv-11686   Document 2   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 2   Filed 10/17/21   Page 2 of 2

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