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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
____________________________________
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ADAMS et al,
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Plaintiffs,
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Civil Action No. 1:21-11686-FDS
v.
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MASS GENERAL BRIGHAM, INC.,
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Defendants.
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____________________________________)
PRO SE PLAINTIFFS’ MEMORANDUM IN OPPOSITION (IN PART) TO
DEFENDANT’S AND REPRESENTED PLAINTIFFS’ MOTION TO STRIKE PRO SE
PLAINTIFFS’ MOTION FOR LEAVE TO AMEND
INTRODUCTION
Plaintiffs Adams, Orfanos, McNamara, Shulman, and Steverman (“Pro Se Plaintiffs”)
respectfully submit this memorandum opposing the overreaching motion to strike entire
documents, while only a few paragraphs need to be stricken.
The overarching issue remains the defendant’s continual breach of Local Rule 7.1(a)(2),
“No motion shall be filed unless counsel certify that they have conferred and have attempted in
good faith to resolve or narrow the issue.” Docket entries including motions and oppositions
continue to be filed in this case due to the refusal of defense counsel to earnestly confer in “good
faith” to narrow the issues per Local Rule 7.1(a)(2).
The Court may think the Pro Se Plaintiffs fail to grasp civil procedure and are making
mistakes. However, the Court should know that the Pro Se Plaintiffs earnestly tried to confer
with the defense counsel to narrow each issue. Defense counsel refused to earnestly confer
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regarding the protective orders issue that never should have resulted in multiple docket entries.
And now, defense counsel refused to confer to narrow the issues regarding the privileged
settlement negotiations in the recent filings, the same information that Attorney McLane posted
publicly on social media platforms including Facebook and Instagram since January, and still is
posted publicly as of this writing.
In the corporate business environment, even NDA language is narrowed through a few
rounds of communication between counsels for the parties. Is that not the purpose of Local Rule
7.1(a)(2)? This Court’s time and our time are being wasted on docket entries and filings, while
defense counsel accrues billable hours for documents that could have been avoided with a 5-
minute phone call. Judicial economy begs that the parties be held to the “good faith” standard
expressed in Local Rule 7.1(a)(2). The convenient thought, though errant in this case, is to blame
Pro Se litigants for such failures. Defense counsel and current plaintiffs’ counsel obviously
confer on scheduling and other items. Why does defense counsel not confer with the Pro Se
Plaintiffs, then misrepresent communications as earnest in status conferences?
FACTS
1.
On September 12, 2024, at the status conference, Pro Se Plaintiff Orfanos requested
to be involved in the settlement discussions between Attorney McLane and MGB to
which the defendant refused. The court then stated Attorney McLane would negotiate
the settlement and extend the offer to Pro Se Plaintiff Orfanos.
2.
On or about October, 2024 Attorney Steinberg, Defendant counsel, offered Pro Se
Plaintiff Orfanos the settlement amount with no discussion of confidentiality or NDA.
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3.
On October 21, 2024, Docket No. 239 is a STIPULATION of Dismissal was entered
for ~180 plaintiffs in this case.
4.
On January 16, 2025, Facebook profile name “McLane & McLane Attorneys at Law”
publicly posted, “Religious Discrimination Settlement” in white italic font on grey
background and the total amount of the settlement in green italic font.
The Pro Se Plaintiffs thought that the settlement information was public information
due to Attorney McLane’s public post on social media from which even children can
do simple division to determine roughly where the settlement ended up. The Pro Se
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Plaintiffs apologize to the Court and the defendant for not understanding that
Attorney McLane should not have publicly posted the information.
5.
On March 18, 2025, the Pro Se Plaintiffs filed a motion for leave to amend,
memorandum in support thereof, proposed second amended complaint, and exhibits
including plaintiffs’ declarations.
6.
On March 26, 2025 at 2:42PM, eight days after the Pro Se Plaintiffs’ filing, defense
counsel contacted the Pro Se Plaintiffs via email with an ultimatum to agree to their
motion to strike by 5PM, else their motion would be filed anyway.
7.
On March 26, 2025, there subsequently ensued a few emails back and forth between
defense counsel and some of the Pro Se Plaintiffs. Plaintiff Orfanos asked which lines
in the documents that defense counsel objected to and wanted removed. Defense
counsel never answered the question and only stated that the documents would be
stricken and that the Pro Se Plaintiffs can refile them without the offending
paragraphs. But how do the Pro Se Plaintiffs know which paragraphs are offensive to
the defendant?
ARGUMENT
From the defendant’s motion to strike,
“See Jones v. Metro. Life Ins. Co., No. C-08-03971-JW DMR,
2010 WL 4055928, at *14 (N.D. Cal. Oct. 15, 2010) (District
Courts have the “inherent power to strike portions of documents
that are improperly part of the record” and may “strike a paragraph
from a case management document that discloses confidential
settlement negotiations”)…”
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The Pro Se Plaintiffs are amenable to withdrawing the documents and refiling them
without the offending prose, if the defendant will tell them what, beyond the settlement amount
included in two declarations, they want removed.
In the alternative, by their own citation supra, the court can strike a few paragraphs as
agreed upon by the parties, again if defense counsel will simply communicate those paragraphs
to the Pro Se Plaintiffs as they would with a represented party.
CONCLUSION
The Pro Se Plaintiffs apologize to the Court and the defendant for thinking that Attorney
McLane’s post in social media meant that the settlement amount had become public information.
The Pro Se Plaintiffs are ready and willing to confer earnestly and in “good faith" to
solve the small issues resulting in needless and multiple docket entries.
Dated: March 27, 2025
Respectfully submitted,
/s/ Tyler Adams
TYLER ADAMS (Pro se)
/s/ Roseann McNamara
ROSEANN MCNAMARA (Pro se)
/s/ Michelle Orfanos
MICHELLE ORFANOS (Pro se)
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/s/ Sarah Shulman
SARAH SHULMAN (Pro se)
/s/ Jamie Steverman
JAMIE STEVERMAN (Pro se)
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CERTIFICATE OF SERVICE
I hereby certify that this document was sent via ECF to the counsel for MGB.
/s/ Tyler Adams
TYLER ADAMS (Pro se)
/s/ Roseann 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)
Dated: March 27, 2025
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