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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)

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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Cite this document

“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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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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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




                                                 3
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gov.uscourts.mad.238919.117.0.pdf
Size
87,671 bytes
SHA-256
9a3d973266dbb2e2b52719a3b10b928fd661dcf70d164e503a4af70fde7ea507
Our copy
gov.uscourts.mad.238919.117.0.pdf
Original
archive.org
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