PROPOSED PRELIMINARY REQUESTS TO CHARGE

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On November 17, 2021 a case was filed by Harry Burr, represented by Law Offices Of Mchugh & Associates Llc, against Mks 55 Capital Llc C O Ks Partners Llc, represented by Hassett & George Pc, in the jurisdiction of Middlesex County. Judge Rupal Shah presiding.

                        
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                          DOCKET NO: MMX-CV21-6032853-S                      :      SUPERIOR COURT

HARRY BURR                                         :      J.D. OF MIDDLESEX

VS.                                                :      AT MIDDLETOWN

MKS 55 CAPITAL LLC                                 :      APRIL 10, 2024

               PLAINTIFF’S PROPOSED REQUEST TO CHARGE

      The Plaintiff Harry Burr hereby submits this Proposed Request to Charge
and respectfully requests that the Court charge the jury as follows:

   In this case the parties have agreed to or admitted through pleadings and
discovery several facts which are not in dispute. You should therefore consider
that these facts are proven without the need for evidence. It is still up to you to
decide what weight or importance those facts have, if any, in deciding the
issues in this case. These facts are as follows:

   The Defendant MKS 55 Capital LLC C/O KS Partners LLC (hereinafter MKS
55) admits that at all relevant times it was and is a Conne…