Plaintiffs' Emergency Motion for Decision on Injunction Pending Appeal — Together Employees v. Mass General Brigham (Document 37)

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Plaintiffs' Emergency Motion for Decision on Injunction Pending Appeal in Together Employees v. Mass General Brigham Incorporated, Civil Action No. 1:21-cv-11686-FDS, in the U.S. District Court for the District of Massachusetts, filed November 5, 2021 as Document 37. The motion asks the court for an expedited decision on an injunction pending appeal. It states that the court denied the plaintiffs' Motion for Preliminary Injunction, that the plaintiffs filed a Notice of Appeal, and that they will file a Motion for Injunction Pending Appeal with the First Circuit Court of Appeals. It cites Fed. R. App. P. 8(a)(1)(C) and incorporates the facts and arguments of the original motion. The two-page filing is signed by Ryan P. McLane of McLane & McLane, LLC, attorney for the plaintiffs, and includes a certificate of service.

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        Case 1:21-cv-11686-FDS Document 37 Filed 11/05/21 Page 1 of 2




                      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,                             )          1:21-cv-11686-FDS
Plaintiffs                                 )
                                           )
v.                                         )
                                           )
MASS GENERAL BRIGHAM                       )
INCORPORATED                               )
Defendant                                  )

          PLAINTIFFS’ EMERGENCY MOTION FOR DECISION ON
                   INJUNCTION PENDING APPEAL


      Plaintiffs move this Court to issue an emergency/expedited decision for

injunction pending appeal. While this Court has already denied plaintiffs’ Motion

for Preliminary Injunction, plaintiffs have filed a Notice of Appeal of the District

Court’s Order and will be subsequently filing a Motion for Injunction Pending

Appeal with the First Circuit Court of Appeals. This Motion is filed in accordance

with the requirements of Fed. R. App. P. 8(a)(1)(C), which requires that a party

move for the granting of an injunction in the District Court while an appeal is

pending. Plaintiffs incorporate the same facts, reasons and legal arguments in favor
        Case 1:21-cv-11686-FDS Document 37 Filed 11/05/21 Page 2 of 2




of its original motion in moving this Court for a decision on this Motion in

accordance with the Federal Rules of Appellate Procedure.



  /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 certify that a true and correct copy of the foregoing was filed electronically

with the Court on this November 5, 2021. Service will be effectuated by the Court’s

electronic notification system upon all counsel or parties of record.


/s/ Ryan P. McLane
Attorney for Plaintiffs


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