On March 13, 2023 a
Party Statement
was filed
involving a dispute between
Endsley, Mary,
and
Deyett, Kenneth,
for Equitable Remedies
in the District Court of Plymouth County.
Preview
Date Filed 5/10/2024 2:49 PM
‘Superior Court - Plymouth
Docket Number 2383CV00208 G4
COMMONWEALTH OF MASSACHUSETTS
PLYMOUTH, ss. SUPERIOR COURT DEPT.
CIVIL ACTION NO. 2383CV00208
MARY ENDSLEY,
Plaintiff, HEALTM OF SSACHUSETTS
suPeticn G OUT DEPT,
PUrMOULM THE TRIAL COURT
COUNT
v. '
KENNETH DEYETT, Ma 10 2024
Defendant.
be
CERTIFICATE OF COMPLIANCE WITH SUPERIOR COURT RULE 9C
I, Amy S. Mello, legal counsel for Plaintiff, Mary Endsley, hereby certify that I requested
a Superior Court Rule 9C telephone conference with counsel to Defendant Kenneth Deyett
i
(“Deyett”) by letter dated January 29, 2024. (Ex. F). My Office followed-up on the written request
by making telephone calls to Atty. John Fink at Sims and Sims, LLP, on February 6, 2024, and
February 7, 2024. The 1% February 6" telephone call (10:06 a.m.) resulted in my Office leaving a
voice mail message for Atty. Fink wherein it was stated we were trying to schedule the Rule 9C
telephone conference and asking for a call back. The 2" February 6" slephone call (4:17 p.m.)
resulted in our leaving a similar, detailed voice mail message for Atty. Fink. With the February 7,
2024, telephone call (3:58 p.m.), we were advised that Atty. Fink was unavailable, to which his
receptionist/secretary was advised that we were trying to reach Atty. Fink, but! that he had not been
returning our calls. My legal assistant was advised by the receptionist/secretary that she would
send Atty. Fink a message about our call. Neither Atty. Fink nor anyone at bis office returned our
calls. We heard nothing from legal counsel for Deyett with respect to our request to hold a Rule
i
9C telephone conference. i
Date Filed 5/10/2024 2:49 PM i
‘Superior Court - Plymouth
Docket Number 2383CV00208
1
1
1
Reasonable efforts were made to initiate a Rule 9(C)(a) telephone conference. There is no
agreement of the parties regarding the contents of Plaintiff Mary Endsley’s Motion to Compel
Response to Discovery by Defendant Kenneth Deyett
Amy S.
Law Offy
Lf-
llo, Esq., BBO #657888
of Amy S. Mello, LLE
P.O. Box 152 1
42 Main Street
Mattapoisett, MA 02739
Tel. (508) 758-4888
Dated: May 10,2024 amello amy melolaw.com
ERTIFICATE OF SERVICE
I hereby certify that the above document is being served within the time required by
Superior Court Standing Order No. 1-88. I further certify that 1 served a true copy of this document
upon the attorney of record for Defendant Kenneth Deyett by first-class mail, postage prepaid, this
10" day of May, 2024, by sending same addressed as follows:
William H. Sims, Esq.
John Fink, Esq.
Sims & Sims, LLP
130 Liberty Street Building 6
Brockton, MA 02301
Additionally, a true copy of the substance of the foregoing Certificate of Compliance with
Superior Court Rule 9C was served on the attorneys of record for Defendant [Kenneth Deyett on
the 22™ day of April, 2024, as the 5" page of Plaintiff Mary Endsley*s Motion to Compel Response
Mi,
to Discovery by Defendant Kenneth Deyett, by first-class mail, postage prepaid, addressed as
stated above. i
Amy,yf Milo, Esq.
-2-
Document Filed Date
May 10, 2024
Case Filing Date
March 13, 2023
Category
Equitable Remedies
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Date Filed 5/10/2024 2:49 PM ‘Superior Court - Plymouth Docket Number 2383CV00208 G4 COMMONWEALTH OF MASSACHUSETTS PLYMOUTH, ss. SUPERIOR COURT DEPT. CIVIL ACTION NO. 2383CV00208 MARY ENDSLEY, Plaintiff, HEALTM OF SSACHUSETTS suPeticn G OUT DEPT, PUrMOULM THE TRIAL COURT COUNT v. ' KENNETH DEYETT, Ma 10 2024 Defendant. be CERTIFICATE OF COMPLIANCE WITH SUPERIOR COURT RULE 9C I, Amy S. Mello, legal counsel for Plaintiff, Mary Endsley, hereby certify that I requested a Superior Court Rule 9C telephone conference with counsel to Defendant Kenneth Deyett i (“Deyett”) by letter dated January 29, 2024. (Ex. F). My Office followed-up on the written request by making telephone calls to Atty. John Fink at Sims and Sims, LLP, on February 6, 2024, and February 7, 2024. The 1% February 6" telephone call (10:06 a.m.) resulted in my Office leaving a voice mail message for Atty. Fink wherein it was stated we were trying to schedule the Rule 9C telephone conference and asking for a call back. The 2" February 6" slephone call (4:17 p.m.) resulted in our leaving a similar, detailed voice mail message for Atty. Fink. With the February 7, 2024, telephone call (3:58 p.m.), we were advised that Atty. Fink was unavailable, to which his receptionist/secretary was advised that we were trying to reach Atty. Fink, but! that he had not been returning our calls. My legal assistant was advised by the receptionist/secretary that she would send Atty. Fink a message about our call. Neither Atty. Fink nor anyone at bis office returned our calls. We heard nothing from legal counsel for Deyett with respect to our request to hold a Rule i 9C telephone conference. i Date Filed 5/10/2024 2:49 PM i ‘Superior Court - Plymouth Docket Number 2383CV00208 1 1 1 Reasonable efforts were made to initiate a Rule 9(C)(a) telephone conference. There is no agreement of the parties regarding the contents of Plaintiff Mary Endsley’s Motion to Compel Response to Discovery by Defendant Kenneth Deyett Amy S. Law Offy Lf- llo, Esq., BBO #657888 of Amy S. Mello, LLE P.O. Box 152 1 42 Main Street Mattapoisett, MA 02739 Tel. (508) 758-4888 Dated: May 10,2024 amello amy melolaw.com ERTIFICATE OF SERVICE I hereby certify that the above document is being served within the time required by Superior Court Standing Order No. 1-88. I further certify that 1 served a true copy of this document upon the attorney of record for Defendant Kenneth Deyett by first-class mail, postage prepaid, this 10" day of May, 2024, by sending same addressed as follows: William H. Sims, Esq. John Fink, Esq. Sims & Sims, LLP 130 Liberty Street Building 6 Brockton, MA 02301 Additionally, a true copy of the substance of the foregoing Certificate of Compliance with Superior Court Rule 9C was served on the attorneys of record for Defendant [Kenneth Deyett on the 22™ day of April, 2024, as the 5" page of Plaintiff Mary Endsley*s Motion to Compel Response Mi, to Discovery by Defendant Kenneth Deyett, by first-class mail, postage prepaid, addressed as stated above. i Amy,yf Milo, Esq. -2-