Joint Status Report — Tyler Adams, et al. v. Mass General Brigham (Civil Action No. 1:21-cv-11686-FDS, Document 117)
- Date
- 2022-08-23
Summary
A Joint Status Report filed September 6, 2022 as Document 117 in Tyler Adams, et al. v. Mass General Brigham Incorporated, Civil Action No. 1:21-cv-11686-FDS, in the U.S. District Court for the District of Massachusetts, following a status conference held August 23, 2022. The parties report that pro se Plaintiff James Wines had not produced questionnaire responses ordered by September 2, 2022, and that MGB intends to move to dismiss his claims with prejudice. The report states he had not signed the modified protective order acknowledgment form, that MGB produced discovery to him on September 2, 2022, and that he appeared for deposition on August 24, 2022 but refused to answer certain questions. Six of ten MGB witness depositions are reported complete, with Phase One Fact Discovery closing October 1, 2022.
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“Joint Status Report — Tyler Adams, et al. v. Mass General Brigham (Civil Action No. 1:21-cv-11686-FDS, Document 117).”
Original at archive.org, dated 2022-08-23. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2022-08-23-plaintiffs-v-mass-general-brigham/
, SHA-256 9a3d973266dbb2e2b52719a3b10b928fd661dcf70d164e503a4af70fde7ea507.Full text
Case 1:21-cv-11686-FDS Document 117 Filed 09/06/22 Page 1 of 3
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
TYLER ADAMS, et al.,
Plaintiffs,
v. Civil Action No. 1:21-cv-11686-FDS
MASS GENERAL BRIGHAM
INCORPORATED,
Defendant.
JOINT STATUS REPORT
Subsequent to the status conference held on August 23, 2022 and in advance of the status
conference this afternoon, the Parties report the following:
Pro Se Plaintiff James Wines Failed to Produce Questionnaire Responses as Ordered
During the status conference, this Court ordered Plaintiff Wines to provide his
outstanding questionnaire responses by Friday, September 2, 2022. At the time of filing,
Plaintiff Wines has still not produced his questionnaire responses. MGB intends promptly to
move to dismiss Plaintiff Wines’ claims with prejudice as a result of his refusal to comply with
his discovery obligations.
Plaintiff Wines Has Not Signed the Modified Protective Order Acknowledgement Form
Like every other Plaintiff in this case, Plaintiff Wines must sign the Court-ordered
protective order acknowledgment form as a prerequisite to learning the name of his
“communicator” on the MGB Religious Exemption Review Committee. See Dkt. 60. On
August 24, 2022, the Court granted MGB’s assented-to motion to modify the acknowledgment
form as to pro se Plaintiff Wines because the original form anticipated that the signatory was
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Case 1:21-cv-11686-FDS Document 117 Filed 09/06/22 Page 2 of 3
represented by counsel. See Dkt. 116. At the time of filing, Plaintiff Wines has still not signed
the modified protective order acknowledgment form, and so MGB has not – and cannot – notify
him of the name of his communicator.
Discovery Produced to Plaintiff Wines
After conferring and agreeing with counsel for the represented Plaintiffs regarding the
appropriate scope and logistics of producing discovery to Plaintiff Wines, MGB produced
discovery to Plaintiff Wines on September 2, 2022 in accordance with the Court’s order at Dkt.
115.
Depositions
Plaintiff Wines appeared for his deposition on August 24, 2022. Despite that this Court
denied his Motion for Protective Order (Dkt. 115), Plaintiff Wines improperly refused to answer
questions about the medical condition for which he sought a medical exemption from MGB’s
Vaccination Policy.
The Parties have completed six of the ten depositions of MGB witnesses. The remaining
four will be completed over the next several weeks before the Phase One Fact Discovery period
closes on October 1, 2022.
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Case 1:21-cv-11686-FDS Document 117 Filed 09/06/22 Page 3 of 3
Dated: September 6, 2022 Respectfully Submitted,
/s/_Ryan P. McLane______________ /s/ Dawn R. Solowey
Ryan P. McLane (BBO# 697464) Lynn A. Kappelman (BBO# 642017)
Lauren Bradford (BBO# 700084) Katherine E. Perrelli (BBO# 549820)
McLane & McLane, LLC Kristin McGurn (BBO# 559687)
269 South Westfield Street Dawn Reddy Solowey (BBO# 567757)
Feeding Hills, MA 01030 SEYFARTH SHAW LLP
ryan@mclanelaw.com Seaport East
lauren@mclanelaw.com Two Seaport Lane, Suite 1200
TEL: (413) 789-7771 Boston, MA 02210-2028
FAX: (413) 789-7731 kperrelli@seyfarth.com
lkappelman@seyfarth.com
COUNSEL FOR THE kmcgurn@seyfarth.com
REPRESENTED PLAINTIFFS dsolowey@seyfarth.com
TEL: (617) 946-4800
FAX: (617) 946-4801
COUNSEL FOR DEFENDANT
CERTIFICATE OF SERVICE
I hereby certify that this document filed through the CM/ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF)
and paper copies will be sent to those indicated as non-registered participants on September 6,
2022.
/s/ Dawn R. Solowey
Dawn R. Solowey
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