Hearing: Teperman, Debra vs. Teperman, Alex

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                2   ‘
                                                                                            Norfolk Probate and Family Court
                                                                                               Date Filed: 3/20/2024 3:00 PM
                                                                                               Case Number: NO23D0017DR


                                    COMMONWEALTH OF MASSACHUSETTS
                                            THE TRIAL COURT

        NORFOLK, ss                                                         PROBATE AND FAMILY COURT
                                                                            DOCKET NO. NO23D0017DR



                                                                               The within Motion is hereby
        DEBRA TEPERMAN,                                                        Aliowed -Bentett
                  Plaintiff
                                                                              3fatley
                VS.                                                            Date

        ALEX TEPERMAN,
                                                                            cotiaved
                   Defendant                                                eC 9:     Dar


                         JOINT MOTION TO              INTINU)      EARING ON MOTIO                     1S
                      NOW COME the parties to this action, Debra Teperman (“Wife”) and Alex Teperman

        (“Husband”) (collectively, “parties”), and hereby respectfully request that this Honorable Court

        continue the hearing on the parties’ motions currently scheduled for March 21, 2024 to the next

        available date not less than 30 days hereafter.

                      As grounds therefore, the parties state as follows:

            1   Husband filed Defendant’s Motion for Issuance of Letters Rogatory and Commission to

                Take Deposition of a Non-Resident, Rochelle Winograd, on or about December 7, 2023.

                Husband’s Motion was scheduled for a hearing before this Honorable Court on March 21,

                2024.

                On or about March 12, 2024, Wife filed Plaintiff's Motion to Compel Defendant to

                Allow Access to Property and for Order to Allow Appraisal. Wife’s motion was



                                                                                                                 75
                consolidated for hearing with Husband’s motion on March 21, 2024. The parties are

                executing a Stipulation resolving this Motion.



                                                                                                              a
                                                          Page 1
        #4761484v1
ac
        eee              ene e



                   ANE




i   ~
oy   *
                                                                                            Norfolk Probate and Family Court
                                                                                                Date Filed: 3/20/2024 3:00 PM
                                                                                                Case Number: NO23D0017DR


            4.   The partics are in the process of working on a resolution of the Husband’s Motion for

                 Issuance of Letters Rogatory and Commission to Take Deposition of a Non-Resident,

                 Rochelle Winograd. The parties believe that an additional thirty (30) days will allow

                 them sufficient time to either resolve this issue by agreement or whether it will be

                 necessary to seck the intervention of the Court by way of contested hearing on one or

                 both of the parties’ motions.

                 Accordingly, in an effort to preserve this Honorable Court’s time and resources, a

                 continuance of this matter is requested in the interest of judicial economy.    Neither party

                 will be prejudiced by the allowance of a postponement.

         WHEREFORE, the parties respectfully request that this Honorable Court continue the Hearing

         scheduled for March 21, 2024 to the next available date at least thirty (30) days thereafter.



         Respectfully submitted,                                  Respectfully submitted,
         Debra Teperman,                                          Alex Teperman,
         By her attorneys,                                        By his attorneys,

          /a/ Jared Spinelli (w/ permission)                      /s/ Peter A. Kuperstein

         Jared D. Spinelli, Esq., BBO No. 682850                 Nancy A. Freed, Esq., BBO No. 543094
         Theresa A. Roeder, Esq., BBO No. 705825                 Peter Kuperstein, Esq., BBO No. 636568
         Rubin & Rudman, LLP                                     Patrick J. Galasso, Esq., BBO No. 692391
         53 State Street, Floor 15                               Prince Lobel Tye LLP
         Boston, MA 02109                                        One International Place, Suite 3700
         ispinelli@rubinrudman.com                               Boston, MA 02110
         troeder@rubinrudman.com
         trocder@)                                               nfreed@princelobel.com
                                                                 pkuperstein@princelobel.com
                                                                 pgalasso@princelobel.com

         Dated: March 20, 2024                                   Dated: March 20, 2024




                                                        Page 2
         #4761484v1