Full text
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
__________________________________________
)
TYLER ADAMS; SARAH SHULMAN;
)
MICHELLE ORFANOS, ROSEANN
)
McNAMARA ; AND JAMIE STEVERMAN,
)
Plaintiffs,
)
) Civil Action No. 21-cv-11686 - FDS
v.
)
)
MASS GENERAL BRIGHAM, INC.,
)
)
Defendant.
)
__________________________________________)
PRO SE PLAINTIFFS’ EMERGENCY MOTION FOR A PROTECTIVE ORDER, AND
TO ALLOW PLAINTIFF ADAMS’S DEPOSITION TO BE CONDUCTED REMOTELY
Pursuant to Federal Rules of Civil Procedure 26(c) and 37(a), Plaintiffs respectfully
request that the Court enter:
(i)
a protective order pursuant to Fed. R. Civ. P. 26(c) prohibiting further depositions
of the Plaintiffs until the Court rules on Plaintiffs’ Motion for Leave to File a
Second Amended Complaint, to be filed on March 18, 2025; and
(ii)
an order allowing pro se Plaintiff Tyler Adams, a working single mother who lives
in South Carolina, to be deposed remotely, rather than in-person in Massachusetts.
As grounds therefore, Plaintiffs state as follows:
Case 1:21-cv-11686-FDS Document 280 Filed 03/11/25 Page 1 of 4
1.
In the interest of efficiency and fairness to all parties, the pro se plaintiffs are
entitled to a protective order prohibiting the depositions of Michelle Orfanos, Jamie
Steverman, and Tyler Adams, currently noticed for March 19, 2025, March 20, 2025, and
March 26, 2025, respectively, until after the Court has ruled on Plaintiffs Motion for
Leave to File a Second Amended Complaint. The proposed Second Amended Complaint
will contain new allegations based on changed circumstances, new causes of action, and
possibly an additional defendant.
2.
The pro se Plaintiffs are in the process of obtaining legal counsel, but will not be
able to do so before their Motion for Leave to File a Second Amended Complaint is filed
on March 18th.
3.
There is a pending Joint Motion for Entry of Amended Scheduling Order
regarding Phase Two of Fact Discovery, Expert Discovery and Phase Two Dispositive
Motions by Mass General Brigham, Inc. (Docket No. 265), as to which the five pro se
Plaintiffs did not consent, and to which they have filed an Opposition (Docket No. 270).
The pro se Plaintiffs intend to file a motion for a revised scheduling order extending
discovery which, if granted, will eliminate any prejudice to the Defendant caused by
postponing the Plaintiffs’ depositions.
4.
The currently noticed deposition dates conflict with the Plaintiffs’ schedules.
5.
Pro se Plaintiff Adams is a working single mother who resides in South Carolina,
where she was able to find work after she was fired by the Defendant. Arranging for
child care, and taking multiple days off from work to travel to Boston places an undue
burden on her when her deposition is able to be conducted remotely.
 2
Case 1:21-cv-11686-FDS Document 280 Filed 03/11/25 Page 2 of 4
6.
This request is made in good faith and not for the purpose of undue delay or
prejudice to any party.
7.
Plaintiffs have attempted to resolve the dispute over the timing and manner of the
depositions with Defendant’s counsel, but without success.
WHEREFORE, the pro se Plaintiffs respectfully request that this Court grant their
Emergency Motion for a Protective Order and to Allow Plaintiff Adams’s Deposition To Be
Conducted Remotely.
Dated: March 11, 2025
Respectfully submitted,
/s/ Tyler Adams
TYLER ADAMS (Pro se)
/s/ Rosann McNamara
ROSEANN MCNAMARA (Pro se)
/s/ Michelle Orfanos
MICHELLE ORFANOS (Pro se)
/s/ Sarah Shulman
SARAH SHULMAN (Pro se)
/s/ Jamie Steverman
JAMIE STEVERMAN (Pro se)
 3
Case 1:21-cv-11686-FDS Document 280 Filed 03/11/25 Page 3 of 4
CERTIFICATE OF SERVICE
We hereby certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF)
and paper and electronic copies will be sent to those indicated as non-registered participants on
March 11, 2025.
/s/ Tyler Adams
TYLER ADAMS (Pro se)
/s/ Rosann McNamara
ROSEANN MCNAMARA (Pro se)
/s/ Michelle Orfanos
MICHELLE ORFANOS (Pro se)
/s/ Sarah Shulman
SARAH SHULMAN (Pro se)
/s/ Jamie Steverman
JAMIE STEVERMAN (Pro se)
 4
Case 1:21-cv-11686-FDS Document 280 Filed 03/11/25 Page 4 of 4