Transamerica Life Insurance Company v. Caramadre et al

Filing 127

MOTION To Join Emergency Motion For Partial Stay re #124 Emergency MOTION to Stay , in Part by Edward Maggiacomo, Jr. Responses due by 12/22/2011 (Traini, Anthony)

UNITED STATES DISTRICT COURT
DISTRICT OF RHODE ISLAND

TRANSAMERICA LIFE INSURANCE
COMPANY,
Plaintiff
vs.
JOSEPH CARAMADRE, RAYMOUR
RADHAKRISHNAN, ESTATE PLANNING
RESOURCES, INC., ESTELLA
RODRIGUES, EDWARD MAGGIACOMO,
JR., LIFEMARK SECURITIES CORP., and
PATRICK GARVEY,
Defendants.

TRANSAMERICA LIFE INSURANCE
COMPANY,
Plaintiff
vs.
LIFEMARK SECURITIES CORP.,
JOSEPH CARAMADRE, RAYMOUR
RADHAKRISHNAN, ESTATE PLANNING
RESOURCES, INC., and EDWARD
MAGGIACOMO, JR.
Defendants.

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C.A. No. 09-471-S

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C.A. No. 09-549-S

DEFENDANT EDWARD L. MAGGIACOMO, JR.’S
MOTION TO JOIN IN AND ADOPT EMERGENCY RENEWED MOTION
FOR PARTIAL STAY FILED BY DEFENDANTS CARAMADRE ET ALS.
Defendant Edward L. Maggiacomo, Jr. (“Maggiacomo”) hereby joins in and adopts the
Emergency Renewed Motion For Partial Stay of the within proceedings filed this date on behalf
of defendants Caramadre, et als. (See Document 125 filed in C.A. No. 09-470-S).

The arguments made in support of the Caramadre motion are equally applicable to Mr.
Maggiacomo, despite the fact that he has not himself been indicted in the criminal case.
WHEREFORE, for the foregoing reasons and for those set forth in the pleadings filed by
the other defendants (all of which are incorporated herein), and such reasons as shall be
advanced at hearing, Mr. Maggiacomo moves that the within actions be stayed as to him pending
the outcome of the criminal proceedings against Mr. Caramadre and Mr. Radhakrishnan.

EDWARD L. MAGGIACOMO, JR.
By his Attorney,
/s/ Anthony M. Traini
Anthony M. Traini #4793
56 Pine Street, Suite 200
Providence, RI 02903
Tel. [phone]
Fax. [phone]
[e-mail]

CERTIFICATE OF SERVICE
I hereby certify that on December 5, 2011, a copy of the within document was filed
electronically and served by mail on anyone unable to accept electronic filing. Notice of this
filing will be sent by e-mail to all parties by operation of the court’s electronic filing as indicated
on the Notice of Electronic Filing. Parties may access this filing through the Court’s CM/ECF
System.
/s/ Anthony M. Traini
Anthony M. Traini

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