On February 16, 2024 a
Hearing
was filed
involving a dispute between
Holcim- Ner, Inc.,
and
Grp Paving And Construction, Llc,
Pereira, Ronald,
for Contract / Business Cases
in the District Court of Middlesex County.
Preview
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COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, SS SUPERIOR COURT DEPARTMENT
DOCKET NO
HOLCIM — NER, INC. QYUBICN YE 3S
Plaintiff,
v. PLAINTIFF’S EX PARTE MOTION FOR
PROVAL OF TRUSTEE PROCESS TO
lt
GRP PAVING AND CONSTRUCTION, ATTA ‘HBA OUNTS
LLC and RONALD PEREIRA,
Defendants, Thc ebm shall be scredubed
and fre henry -. Ue theif hoor
Row, ma, Kiey
the
BANK OF AMERICA, NA and
Sosy Pyype, Seon thea
(l
Bel
THE LOWELL FIVE CENT SAVINGS au) shen
BANK, Oncor, al of Grenee or Lowe
Trustee Process Defendants ohwer
Ece Cat Savi an cj om OM
tnsttvhon, phadl feo dene Core
lusitoes. De
Pursuant to Rules 4.1(f) and 4.2(g) of the Massachusetts Rules of Civil Procedure, PP
Plaintiff Holcim — NER, Inc. (“Holcim”) moves this Honorable Court to approve ex parte
attachment by trustee process for Defendant GRP Paving and Construction, LLC (“GRP”) and
Ronald Pereira’s (“Mr. Pereira”) funds now in the hands of Bank of America, NA (“Bank of
America”) and/or the Lowell Five Cent Savings Bank (“Lowell Five”) in the total amount of
$284,428.18. In support of this Ex Parte Motion, Holcim files herewith its Memorandum of Law,
Verified Complaint, and the supporting affidavit of Jeffrey Larson, Credit Manager of Holcim.
WHEREFORE, Plaintiff Holcim — NER, Inc. moves this Honorable Court to ALLOW ex
parte attachment and issue an ORDER or WRIT OF ATTACHMENT for Defendant GRP Paving
and Construction, LLC and Ronald Pereira’s funds now in the hands or control of Bank of
America, NA and/or the Lowell Five Cent Savings Bank, in the total amount of $284,428.18
Respectfully submitted,
Plaintiff
HOLCIM — NER, INC.
By its attorneys:
Miah gno
Christopher D. Strang, BBO No. 664742
cstrang@strangscott.com
Mikaela Rice DeCortin, BBO No. 707651
mrice@strangscott.com
STRANG, SCOTT & GIROUX, LLP
6 Beacon Street, Suite 305
Boston, MA 02108
Dated: February 13, 2024 (857) 233-5534
Document Filed Date
February 16, 2024
Case Filing Date
February 16, 2024
Category
Contract / Business Cases
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