Wareham Free Library et al v. Wareham, Town of et al

Filing 42

CERTIFICATE OF CONSULTATION re 40 MOTION to Amend 7 Answer to Counterclaim,,,. (Zoubaidoulline, Timour)

Wareham Free Library et al v. Wareham, Town of et al

Doc. 42

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS DOCKET NO. 07-CV-11807 RGS WAREHAM FREE LIBRARY, INC. and PRISCILLA PORTER, MARY NYMAN, HAZEL TABER, MICHELLE BAUM, SANDRA WHEELER, JOHN LANCI, MARTHA MAGUIRE, YELENA FARIOLI-BEAUPRE, and DIANE LAZARUS, Individually and As Trustees of Wareham Free Library, Inc. Plaintiffs / Defendants in Counterclaim / Third Party Plaintiffs v. THE TOWN OF WAREHAM Defendant / Plaintiff in Counterclaim and BRENDA ECKSTROM, BRUCE SAUVAGEAU, JOHN CRONAN, JAMES POTTER, and M. JANE DONAHUE, Individually and As Members of The Board of Selectmen of Wareham Defendants v. FRIENDS OF THE WAREHAM FREE LIBRARY, INC., and THE WAREHAM LIBRARY FOUNDATION, INC. Defendants in Counterclaim v. MASSACHUSETTS INTERLOCAL INSURANCE ASSOCIATION Third Party Defendant LOCAL RULE 7.1 CERTIFICATE REGARDING MOTION FOR LEAVE OF COURT TO FILE AMENDED ANSWER TO COUNTERCLAIM BY PLAINTIFFS, WAREHAM FREE LIBRARY, INC. AND ITS INDIVIDUALLY NAMED TRUSTEES

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Pursuant to Local Rule 7.1(A)(2), the undersigned counsel for plaintiffs hereby certifies that he conferred with counsel for all other parties in this action, regarding plaintiffs' Motion for Leave of Court to File Amended Answer to Counterclaim by Plaintiffs Wareham Free Library, Inc. and Its Individually Named Trustees, by sending letter regarding same by facsimile and by email to all counsel of record on July 14, 2008, and thereafter by telephone with counsel for defendant in counterclaim Friends of The Wareham Free Library, Inc., Attorney Thomas J. Gallitano, and with counsel for third party defendant Massachusetts Interlocal Insurance Association, Attorney Arthur E. Maravelis. As of the date of the filing of this motion, Attorney Gallitano has indicated that his client assents to this motion; Attorney Maravelis has indicated that his client does not object; counsel for defendant and plaintiff in counterclaim The Town of Wareham, Attorney Elizabeth R. Corbo, has indicated that she could not give her client's assent to this motion; and counsel for defendant Selectmen, officially and individually, Attorney Leonard H. Kesten, has indicated that his clients assent to this motion.

COUNSEL FOR PLAINTIFFS / DEFENDANTS IN COUNTERCLAIM / THIRD PARTY PLAINTIFFS / S / Timour Zoubaidoulline ________________________________________ TIMOUR ZOUBAIDOULLINE, BBO # 656212 BEAUREGARD, BURKE & FRANCO 32 William Street, New Bedford, MA 02740 Tel. [phone] [e-mail] Dated: July 22, 2008

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CERTIFICATE OF SERVICE In accordance with the Electronic Case Filing ("ECF") Administrative Procedures of the United States District Court for the District of Massachusetts, I, Timour Zoubaidoulline, hereby certify that the foregoing document(s) filed through the ECF system will be sent electronically to the registered participants as identified on the Notice of Electronic Filing ("NEF") and that paper copies will be sent to those indicated as non-registered participants by first class mail on July 22, 2008. / S / Timour Zoubaidoulline ________________________________________ TIMOUR ZOUBAIDOULLINE, BBO # 656212

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