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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
TYLER ADAMS, et al.,
Plaintiffs,
v.
MASS GENERAL BRIGHAM
INCORPORATED,
Defendant.
Civil Action No. 1:21-cv-11686
DEFENDANT MASS GENERAL BRIGHAM INCORPORATED’S NOTICE OF
CERTAIN PLAINTIFFS’ NON-COMPLIANCE WITH NOTICE AND ORDER OF THE
COURT (DOC. 94) AND REQUEST FOR DISMISSAL WITH PREJUDICE FOR
FAILURE TO PROSECUTE
Per this Court’s Notice and Order dated May 16, 2022, see Doc. 94 (“Notice and Order”),
Defendant Mass General Brigham Incorporated (“MGB”) hereby notifies this Court that, with the
exception of Plaintiff Laina Frazier, none of the plaintiffs listed in Paragraph 1 of the Notice and
Order have complied with their discovery obligations.
As this Court ordered, the Plaintiffs listed in Paragraph 1 of the Notice and Order were to
answer the Questionnaire (including but not limited to producing all requested documents) and
Requests for Admission that were approved by this Court (Dkt No. 72) on March 15, 2022. Those
Plaintiffs were ordered to serve such discovery on the attorneys for MGB by e-mail no later than
June 6, 2022 at 5 P.M. As of the filing of this notice, only Plaintiff Frazier has served any discovery
responses. The remainder have neither served any discovery responses nor otherwise
communicated with MGB’s attorneys regarding their discovery responses.
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Accordingly, MGB respectfully notifies this Court that, with the exception of Plaintiff
Frazier, the foregoing Plaintiffs have failed to provide discovery and have not complied with this
Court’s Notice and Order. MGB respectfully requests that this Court dismiss those Plaintiffs’
claims with prejudice for failure to prosecute.
Dated: June 7, 2022
MASS GENERAL BRIGHAM
INCORPORATED
By Its Attorneys,
Respectfully Submitted,
/s/ Dawn R. Solowey
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
CERTIFICATE OF SERVICE
I, Dawn R. Solowey, certify that on June 7, 2022, I caused a true and accurate copy of the
foregoing document to be filed and uploaded to the CM/ECF system.
/s/ Dawn R. Solowey
Dawn R. Solowey
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