Declaration of Ryan P. Mclane

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Declaration of Ryan P. McLane, lead counsel for the plaintiffs in Tyler Adams, et al. v. Mass General Brigham Incorporated, No. 1:21-cv-11686-FDS (District of Massachusetts), dated November 27, 2023. McLane states that good cause exists to terminate the representation of plaintiff Michelle Orfanos because of a fundamental disagreement over trial strategy. The declaration says the Phase II written discovery deadline is December 27, 2023, and that the case began with 267 plaintiffs, with 223 individually named in the Amended Complaint and 159 still in litigation after Phase I summary judgment. It states that the Motion to Withdraw is necessary to the effective prosecution of the case and the remaining plaintiffs' claims.

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UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

_________________________________________________
TYLER ADAMS, et al.

Plaintiffs

v.

NO.  1:21-cv-11686-FDS

MASS GENERAL BRIGHAM

INCORPORATED,

Defendant

DECLARATION OF RYAN P. MCLANE
I, Ryan P. McLane, Esq., hereby declare under penalty of perjury and pursuant to
28 U.S.C. § 1746, as follows:
1. I am an attorney licensed in the Commonwealth of Massachusetts.
2. I am lead counsel for the Plaintiffs in the above matter, including Michelle
Orfanos.
3. In accordance with Mass. R. Prof. C. 1.16 and 1.7, I believe that good cause
exists to terminate my representation of Plaintiff Michelle Orfanos, in that
we have a fundamental disagreement over trial strategy and there exists
other good cause, which I could inform the Court, in camera, if the Court so
wishes.
4. The client would not be adversely affected by the withdrawal in a material
way, as I sent an email to Ms. Orfanos on October 25, 2023 indicating that I
would file this motion in thirty days, and in the interim continued
representation and provided her the necessary Phase II written discovery
materials and guidance on responding to the same. Additionally, Phase II
Case 1:21-cv-11686-FDS   Document 179-1   Filed 11/27/23   Page 1 of 3

written discovery deadline is December 27, 2023, giving Ms. Orfanos
additional time to complete the discovery and find new counsel (a total of
sixty days).
5. Further, Ms. Orfanos is equipped to complete discovery and I would work
with opposing counsel to schedule her deposition enough in advance to allow
her even more time to find new counsel.
6. Based on the nature of this case and the amount of plaintiffs involved, and
given the seriousness of the breakdown of the attorney/client relationship, I
do not believe that I can represent Ms. Orfanos in the manner in which she
expects me to, and also adequately represent the remaining plaintiffs.
7. This case began with 267 plaintiffs. After this Court indicated that it would
dismiss the unincorporated association “Together Employees” after the denial
of preliminary injunctive relief, many plaintiffs decided not to pursue their
claims individually, resulting in 223 individually named plaintiffs listed in
the Amended Complaint. After Phase I summary judgment, 159 Plaintiffs are
still in litigation.
8. Attorney Bradford and I have dedicated hundreds of hours into this case,
taking great pains to zealously represent each individual plaintiff and to
ensure that they understand the nature of each stage of litigation.
9. The hearings speak for themselves, as well over 100 participants are
frequently on the remote hearings via zoom.
10. I am confident that we have satisfied our obligations to Ms. Orfanos under
Case 1:21-cv-11686-FDS   Document 179-1   Filed 11/27/23   Page 2 of 3

the Massachusetts Rules of Professional Conduct and that this Motion to
Withdraw is necessary to the effective prosecution of this case and the
remaining plaintiffs’ claims.

November 27, 2023

_____________________________________

Ryan P. McLane, Esq.
Case 1:21-cv-11686-FDS   Document 179-1   Filed 11/27/23   Page 3 of 3

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