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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