Joint Stipulation and Motion to Extend Deadline for Defendant to Respond to Plaintiffs' Complaint

Summary

In Together Employees v. Mass General Brigham Incorporated (District of Massachusetts, Civil Action No. 1:21-cv-11686), the parties jointly request that the Court extend the deadline for the Defendant to answer, move, or otherwise respond to the Plaintiffs' Complaint by two (2) weeks, to December 22, 2021. Plaintiffs filed the Complaint on October 17, 2021, and the response was originally due November 8, 2021. On December 6, 2021, counsel conferred, and Plaintiffs' counsel indicated an intent voluntarily to dismiss the unincorporated association (Together Employees) and to amend the Complaint by December 17, 2021. The filing is dated December 7, 2021.

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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
TOGETHER EMPLOYEES, by Individual
Representatives, ROBERTA LANCIONE,
JOYCE MILLER, MARIA DIFRONZO,
MICHAEL SACCOCCIO, ELIZABETH
BIGGER, NATASHA DICICCO, NICHOLAS
ARNO and RUBEN ALMEIDA,
Plaintiffs,
v.
MASS GENERAL BRIGHAM
INCORPORATED,
Defendant.
Civil Action No. 1:21-cv-11686

Date  Filed:  December 7, 2021
JOINT STIPULATION AND MOTION TO EXTEND DEADLINE FOR DEFENDANT
TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFFS’ COMPLAINT
Plaintiffs, Together Employees, by individual representatives Roberta Lancione, Joyce
Miller, Maria DiFronzo, Michael Saccoccio, Elizabeth Bigger, Natasha DiCicco, Nicholas Arno,
and Ruben Almeida (collectively, “Plaintiffs”) and Defendant Mass General Brigham
Incorporated (“MGB”) (collectively, the “Parties”), by and through their respective attorneys
hereby jointly request that the Court extend the current deadline for Defendant to respond to
Plaintiffs’ Complaint by two (2) weeks, to December 22, 2021.
In support of this Motion, the Parties hereby jointly stipulate to the following:
1.
On October 17, 2021, Plaintiffs filed their Complaint in the District of
Massachusetts.  Dkt. 1.
2.
MGB was served with the Complaint on or about October 18, 2021, making its
response to the complaint originally due November 8, 2021.  Dkt. 7.
Case 1:21-cv-11686-FDS   Document 51   Filed 12/07/21   Page 1 of 4

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3.
On October 25, 2021, the Parties filed a Joint Status Report in which Defendant
requested a 30-day extension of time, up to and including December 8, 2021, to respond to
Plaintiffs’ Complaint, Dkt. 15, and the Court adopted that proposed schedule that same day.  Dkt.
17.
4.
On December 6, 2021, counsel for the Parties conferred, and Plaintiffs’ counsel
indicated that they intend voluntarily to dismiss the unincorporated association (Together
Employees) and agreed they would amend the Complaint by December 17, 2021.
5.
Defendant’s counsel proposed that, in light of the forthcoming Amended
Complaint, the Parties should stipulate to extend the deadline to respond to that Amended
Complaint.
6.
The Parties mutually agreed to a two-week extension of the deadline for
Defendant to respond to Plaintiffs’ Amended Complaint, to December 22, 2021.

WHEREFORE, the Parties respectfully request that the Court grant an extension of time up to
and including December 22, 2021 for Defendant to respond to Plaintiffs’ Amended Complaint.

Case 1:21-cv-11686-FDS   Document 51   Filed 12/07/21   Page 2 of 4

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DATED:  December 7, 2021
Respectfully submitted,
DEFENDANT

MASS GENERAL BRIGHAM
INCORPORATED
By Its Attorneys,
/s/ Lynn A. Kappelman
Lynn A. Kappelman (BBO# 642017)
Katherine E. Perrelli (BBO# 549820)
Kristin McGurn (BBO# 559687)
Dawn Reddy Solowey (BBO#567757)
SEYFARTH SHAW LLP
Seaport East
Two Seaport Lane, Suite 1200
Boston, MA 02210-2028
kperrelli@seyfarth.com
lkappelman@seyfarth.com
kmcgurn@seyfarth.com
dsolowey@seyfarth.com
TEL: (617) 946-4800
FAX: (617) 946-4801

PLAINTIFFS

By their attorneys,
/s/ Ryan P. McLane
Ryan P. McLane (BBO# 697464)
Lauren Bradford (BBO# 700084)
MCLANE & MCLANE, LLC
269 South Westfield Street
Feeding Hills, MA 01030
ryan@mclanelaw.com
lauren@mclanelaw.com

Case 1:21-cv-11686-FDS   Document 51   Filed 12/07/21   Page 3 of 4

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CERTIFICATE OF SERVICE

I, Lynn A. Kappelman, certify that on December 7, 2021, I caused a true and accurate copy
of the foregoing document to be filed and uploaded to the CM/ECF system.
/s/ Lynn A. Kappelman

Lynn A. Kappelman

Case 1:21-cv-11686-FDS   Document 51   Filed 12/07/21   Page 4 of 4

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