Transamerica Life Insurance Company v. Caramadre et al

Filing 137

MOTION for Reconsideration re (121 in 1:09-cv-00471-S-DLM, 124 in 1:09-cv-00472-S-DLM, 149 in 1:09-cv-00473-S-DLM, 122 in 1:09-cv-00470-S-DLM, 110 in 1:09-cv-00502-S-DLM, 90 in 1:09-cv-00564-S-DLM, 97 in 1:09-cv-00549-S-DLM) Order on Motion to Compel,, with Supporting Memo by Estate Planning Resources, Inc.. Responses due by 4/9/2012 (Attachments: #1 Exhibit A - EPR Opposition to Motion to Compel, #2 Exhibit B - EPR Motion to Appoint Agent, #3 Exhibit C - Ramos Declaration in Support of Motion to Appoint Agent, #4 Exhibit D - Stay Order)Associated Cases: 1:09-cv-00470-S-DLM et al.(Ramos, Adam)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
____________________________________
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
C.A. No. 09-470-S
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., HARRISON CONDIT, )
and FORTUNE FINANCIAL SERVICES,
)
INC.,
)
Defendants;
)
____________________________________ )
)
TRANSAMERICA LIFE INSURANCE
)
COMPANY,
)
Plaintiff,
)
)
vs.
)
)
C.A. No. 09-471-S
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., ESTELA
)
RODRIGUES, EDWARD MAGGIACOMO, )
JR., LIFEMARK SECURITIES CORP., and )
PATRICK GARVEY,
)
Defendants;
)
____________________________________ )
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
C.A. No. 09-472-S
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., ADM ASSOCIATES, )
LLC, EDWARD HANRAHAN, THE
)
LEADERS GROUP, INC., and CHARLES )
BUCKMAN,
)
Defendants;
)

____________________________________
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., DK LLC, EDWARD
)
HANRAHAN, THE LEADERS GROUP,
)
INC., and JASON VEVEIROS,
)
Defendants;
)
)
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., NATCO PRODUCTS )
CORP., EDWARD HANRAHAN, and THE )
LEADERS GROUP, INC.,
)
Defendants;
)
)
)
TRANSAMERICA LIFE INSURANCE
)
COMPANY,
)
Plaintiff,
)
)
vs.
)
)
LIFEMARK SECURITIES CORP., JOSEPH )
CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC. and EDWARD
)
MAGGIACOMO, JR.,
)
Defendants; and
)
)

Doc. No. 50563759 

C.A. No. 09-473-S

C.A. No. 09-502-S

C.A. No. 09-549-S

2

____________________________________
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., HARRISON CONDIT, )
and FORTUNE FINANCIAL SERVICES,
)
INC.,
)
Defendants.
)
)

C.A. No. 09-564-S

DEFENDANT ESTATE PLANNING RESOURCES, INC.’S
MOTION FOR RECONSIDERATION
Defendant Estate Planning Resources, Inc. (“EPR”) moves this Court for reconsideration
of the Order Granting in Part Plaintiffs’ Motion to Compel Defendant Estate Planning Resources
to Respond to Interrogatories (the “Order”) entered on November 1, 2011. For the reasons set
forth in the accompanying memorandum, events that occurred after this Court entered the Order
provide reason for reconsideration of the Order and denial of Plaintiff’s motion to compel EPR
to respond to interrogatories. Accordingly, EPR respectfully requests that this Court grant this
motion, vacate the Order and enter an order denying Plaintiffs’ motion to compel.

Doc. No. 50563759 

3

Dated: Providence, Rhode Island
March 22, 2012
ESTATE PLANNING RESOURCES, INC.,
By its Attorneys,

/s/ Adam M. Ramos____________
Robert G. Flanders, Jr. (# 1785)
Adam M. Ramos (#7591)
HINCKLEY, ALLEN & SNYDER LLP
50 Kennedy Plaza, Suite 1500
Providence, RI 02903
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

CERTIFICATE OF SERVICE
I hereby certify that on March 22, 2012, a copy of the foregoing 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/ Adam M. Ramos

Doc. No. 50563759 

4

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
____________________________________
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
C.A. No. 09-470-S
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., HARRISON CONDIT, )
and FORTUNE FINANCIAL SERVICES,
)
INC.,
)
Defendants;
)
____________________________________ )
)
TRANSAMERICA LIFE INSURANCE
)
COMPANY,
)
Plaintiff,
)
)
vs.
)
)
C.A. No. 09-471-S
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., ESTELA
)
RODRIGUES, EDWARD MAGGIACOMO, )
JR., LIFEMARK SECURITIES CORP., and )
PATRICK GARVEY,
)
Defendants;
)
____________________________________ )
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
C.A. No. 09-472-S
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., ADM ASSOCIATES, )
LLC, EDWARD HANRAHAN, THE
)
LEADERS GROUP, INC., and CHARLES )
BUCKMAN,
)
Defendants;
)

____________________________________
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., DK LLC, EDWARD
)
HANRAHAN, THE LEADERS GROUP,
)
INC., and JASON VEVEIROS,
)
Defendants;
)
)
)
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., NATCO PRODUCTS )
CORP., EDWARD HANRAHAN, and THE )
LEADERS GROUP, INC.,
)
Defendants;
)
)
)
TRANSAMERICA LIFE INSURANCE
)
COMPANY,
)
Plaintiff,
)
)
vs.
)
)
LIFEMARK SECURITIES CORP., JOSEPH )
CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC. and EDWARD
)
MAGGIACOMO, JR.,
)
Defendants; and
)
)

Doc. No. 50563759 

C.A. No. 09-473-S

C.A. No. 09-502-S

C.A. No. 09-549-S

2

____________________________________
WESTERN RESERVE LIFE ASSURANCE )
CO. OF OHIO,
)
Plaintiff,
)
)
vs.
)
)
JOSEPH CARAMADRE, RAYMOUR
)
RADHAKRISHNAN, ESTATE PLANNING )
RESOURCES, INC., HARRISON CONDIT, )
and FORTUNE FINANCIAL SERVICES,
)
INC.,
)
Defendants.
)
)

C.A. No. 09-564-S

MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT
ESTATE PLANNING RESOURCES, INC.’S MOTION FOR RECONSIDERATION
Defendant Estate Planning Resources, Inc. (“EPR”) submits this memorandum of law in
support of its motion for reconsideration of the Order Granting in Part Plaintiffs’ Motion to
Compel Defendant Estate Planning Resources to Respond to Interrogatories (the “Order”)
entered on November 1, 2011. Events that occurred after this Court entered the Order make the
Order ripe for reconsideration. Additionally, those same events make it impossible for EPR to
comply with the Order. Accordingly, this Court should grant this motion, vacate the Order and
enter an order denying Plaintiffs’ motion to compel.
RELEVANT BACKGROUND
Plaintiffs brought seven related cases against EPR and many other defendants for alleged
misconduct in connection with the sale of annuities. Plaintiffs claim that the defendants all were
involved in an alleged scheme to make money by purchasing annuities from Plaintiffs and
naming terminally ill patients as the annuitants. Plaintiffs allege that in connection with this
supposed scheme, the annuities were purchased with a death benefit rider that provided a
guaranteed return on the investment, which was likely to be triggered because the annuitants

Doc. No. 50563759 

3

were terminally ill. Plaintiffs allege that EPR employed two other defendants, Joseph Caramadre
and Raymour Radhakrishnan, who acted in furtherance of this supposed scheme by matching
purchasers of annuities with the terminally ill annuitants.
The United States Attorney for the District of Rhode Island (“U.S. Attorney”) began an
investigation of Defendants Caramadre, Radhakrishnan, Edward Maggiacomo, Jr., Harrison
Condit and Edward Hanrahan (collectively, “Target Defendants”) in connection with the
allegations Plaintiffs made in their complaints. The defendants in the civil suits moved to
dismiss the complaints, and this Court dismissed several claims. Many of the defendants,
including EPR, moved to stay the civil suits until the resolution of the criminal investigation.
This Court did not stay the civil litigation at that time, but recognized that proceeding with the
normal course of discovery in these civil suits would result in unfair prejudice to the Target
Defendants in connection with both the criminal investigation and the civil litigation. Thus, the
Court directed the parties to come to an agreement on an order that would allow some discovery
to proceed, but also would protect the Target Defendants from the prejudice that might result
from either answering discovery requests or being forced to invoke their Fifth Amendment
privilege against self-incrimination.
The parties complied with the Court’s directive and agreed to the Initial Case
Management Order (ECF No. 58 in Case No. 09-470) (the “ICMO”). The ICMO provided
several protections for the Target Defendants: (1) they were required to serve only draft answers
to the complaints without asserting counterclaims if any of Plaintiffs’ new claims survived
motions to dismiss;1 (2) they would be required to produce documents in response to requests for
production pursuant to an agreement concerning the source and authentication of the documents

1

In the ICMO, the Court granted Plaintiffs leave to file amended complaints and set forth a schedule for defendants
to file new motions to dismiss.

Doc. No. 50563759 

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and would have a right to seek a non-disclosure order if any documents they produced became
the subject of a subsequent request or subpoena; and (3) they would not be required to respond to
any interrogatories or requests for admission, or testify at any depositions, either on their own
behalf, “or on behalf of an organization[.]” (Emphasis added). In exchange, Target
Defendants agreed not to propound any interrogatories or requests for admission, or to notice any
depositions.
Plaintiff served interrogatories on EPR in all seven cases. EPR, through counsel,
provided responses to all the interrogatories in all seven cases on August 12, 2011, stating in
response to each interrogatory:
Because the only "officers" or "agents" of EPR who could possibly answer this
interrogatory on behalf of EPR are "Target Defendants" as defined by Footnote 2
of the Court's Initial Case Management Order (the "lCMO"), which the Court
entered on September 1 0, 2010 and filed on September 13,2010 (after it was
submitted to the Court jointly by all of the parties on September 8, 2010), EPR
hereby declines to respond to this interrogatory subject to Paragraph 5 of the
ICMO, which states that "no Target Defendant shall propound interrogatories ...
nor shall any Target Defendant, whether on his own behalf or on behalf of an
organization ... be required to respond to any such interrogatories ... until further
order of the Court .... " (emphasis added). Accordingly, EPR also reserves any
and all objections that it might have as to the form of this Interrogatory until
further order of the Court.
Plaintiffs moved to compel EPR to provide substantive answers on September 26, 2011. EPR
objected and argued (1) that the ICMO prohibited the interrogatories because EPR could answer
the Interrogatories only through Target Defendants, and (2) that the law calls for a stay of
discovery from an organization when the responses to the discovery requests necessarily must
come from the target of a criminal investigation. EPR further argued that Caramadre (a Target

Doc. No. 50563759 

5

Defendant) was the only person capable of providing the information necessary to respond to the
interrogatories.2
The Court granted Plaintiffs’ motion to compel, in part, on November 1, 2011. The
Court set forth a procedure for EPR to answer the interrogatories without unduly interfering with
the constitutional rights of the Target Defendants. First, the Court ordered EPR to designate an
agent to answer the interrogatories. See ECF No. 122 in Case No. 09-470 at 10. Then the Court
set forth the precise steps that the agent must take to answer the interrogatories:
To the extent that a particular interrogatory requires EPR’s agent to consult a
Target Defendant and the Target Defendant refuses to provide the information
sought, the agent shall, in the response to such interrogatory, (1) explain why the
information can only be obtained from a Target Defendant and from no other
source (e.g., company records or persons other than a Target Defendant) and (2)
state verbatim the response which the agent received from the Target Defendant
who declined to provide the information requested. To insure accuracy with
respect to the latter requirement, any Target Defendant who declines to provide
information to EPR’s agent shall furnish the agent with a written statement
stating the basis for the refusal.
Id. at 10-11 (internal footnote omitted).3
Following the Court’s order granting Plaintiff’s motion to compel, EPR worked toward
complying with the order. EPR identified and designated an agent and began to provide the
agent with access to the information in EPR’s files to prepare responses to the interrogatories.
See Memorandum in Support of Emergency Motion of Estate Planning Resources, Inc. for
Appointment of an Agent to Answer Interrogatories (ECF No. 126 in Case No. 09-470);
Declaration of Adam Ramos, Esq. in Support of Defendant Estate Planning Resources, Inc.’s
Emergency Motion for Appointment of an Agent to Answer Interrogatories (ECF No. 127 in

2

EPR incorporates in full the arguments set forth in the Memorandum of Law in Support of Defendant Estate
Planning Resources, Inc.’s (“EPR”) Objection to Plaintiffs’ Motion to Compel EPR to Respond to Interrogatories
(ECF No. 119 in Case No. 09-470). A copy of that memorandum is attached as Exhibit A.
3
The Court explained that an answer to an interrogatory only “requires” the agent to consult with a Target
Defendant if the information sought by the interrogatory “cannot be obtained from any other source.” Id. at 10 n.5.

Doc. No. 50563759 

6

Case No. 09-470).4 On November 17, 2011, the U.S. Attorney issued a 66-count indictment
against Caramadre and Radhakrishnan. See Exhibit C at ¶ 8. As a result of the indictment, the
third-party agent was advised by counsel that he should no longer serve as EPR’s agent for
purposes of answering the interrogatories. See Exhibit C at ¶ 10. Caramadre has been unable to
find any person to serve as an agent to answer the interrogatories. See Ramos Declaration at ¶
11. EPR moved for an emergency extension of time to respond to the interrogatories on
November 22, 2011. The Court granted that motion allowing EPR up to and including December
12, 2011 to provide answers. See Exhibit B. EPR moved the Court to appoint an agent on its
behalf to answer the interrogatories. See Exhibit B.
Many defendants filed renewed motions to stay the civil litigation because of the
indictment. See, e.g., Emergency Renewed Motion for Partial Stay of Defendants Joseph
Caramadre, Raymour Radhakrishnan, Estella Rodrigues and ADM Associates, LLC (ECF No.
125 in Case No. 09-470). These motions were filed contemporaneously with EPR’s motion
seeking appointment of an agent. EPR’s motion for the appointment of an agent was
conditioned on a denial of the renewed motions to stay (because EPR understood that a stay of
the litigation would obviate the need for imminent interrogatory answers until the court removed
the stay). See Exhibit B.
The Court held a chambers conference to discuss the pending motions, including motions
to dismiss the complaints, on December 9, 2011. The parties and the Court discussed the
parameters of any potential stay, the pending motions to dismiss, and the status of EPR’s
obligation to respond to the interrogatories. The Court decided that it would allow Plaintiffs to
file oppositions to the motions to stay and would reserve decision on the motions to stay until

4

Copies of ECF No 126 in Case No. 09-470 and ECF No. 127 in Case No. 09-470 are attached as Exhibits B and C
respectively.

Doc. No. 50563759 

7

after it decided the pending motions to dismiss. The Court also entered a text order “staying the
deadline for Estate Planning Resour[c]es, Inc.'s answer to interrogatories until the Court decides
[125] Emergency Motion to Stay in Part by Joseph Caramadre, Raymour Radhakrishnan, ADM
Associates, LLC and Estella Rodrigues” on December 12, 2011.
The Court entered its Opinion and Order on the motions to dismiss on February 7, 2012
and dismissed many of the claims in the various complaints – including all claims against EPR
in case No. 09-470. The Court also scheduled another chambers conference for February 22,
2012. The parties again discussed whether a stay should enter and what the parameters of any
stay should be at the February 22, 2012 chambers conference. The Court concluded at the
chambers conference that a stay should enter, with some exceptions, and directed the parties to
submit a stay order to the Court for entry. The parties submitted two competing stay orders, and
the Court entered an order granting the motions to stay all the cases on March 2, 2012.5 The stay
order specifically stated that “Estate Planning Resources, Inc’s (“EPR”) obligation to respond to
the interrogatories propounded by the Plaintiffs pursuant to the Order Granting in Part Plaintiffs’
Motion to Compel Defendant Estate Planning Resources to Respond to Interrogatories (ECF No.
122 in Case No. 09-470) is stayed pending the resolution of a forthcoming motion for
reconsideration of that order that EPR will file.” See Exhibit D (ECF No. 134 in Case No. 09470).
ARGUMENT
The factual and procedural developments in this case since the Court entered the Order
granting Plaintiffs’ motion to compel clearly support reconsideration. The following significant
events occurred since the Court ordered EPR to answer the interrogatories:
•
5

The U.S. Attorney indicted Caramadre and Radhakrishnan;

A copy of the stay order is attached as Exhibit D.

Doc. No. 50563759 

8

•

The agent EPR identified to answer the interrogatories will no longer serve as agent –
and no replacement can be found;

•

The Court decided the motions to dismiss and dismissed many counts in the complaints,
including all counts against EPR in one of the cases; and

•

The Court entered an order staying the civil litigation with only limited exceptions: (1)
motions for entry of final judgment by defendants with no remaining claims against
them, (2) limited document discovery, and (3) this motion for reconsideration of the
Order.

Additionally, EPR has been reduced to a shell corporation. It has no employees. It has no
office. EPR continues to exist only because of its status as a defendant in these civil suits.
“[T]he considerations that govern the filing of a motion for reconsideration are very
flexible.” Penobscot Indian Nation v. Key Bank, 112 F.3d 538, 563 (1st Cir. 1997). “Not every
motion must fit within some neat pigeonhole.” Jusino v. Zayas, 875 F.2d 986, 990 n.10 (1st Cir.
1989). “There comes a time when courts must be practical.” Id. at 990. A district court “has
substantial discretion and broad authority to grant” a motion for reconsideration. Ruiz Rivera v.
Pfizer Pharms., LLC, 521 F.3d 76, 81 (1st Cir. 2008). A motion for reconsideration should be
granted in the case of a manifest error of law, newly discovered evidence, or when “the court
‘has patently misunderstood a party . . . or has made an error not of reasoning but
apprehension.’” Id. at 81-82 (quoting Sandoval Diaz v. Sandoval Orozco, No. 01-1022, 2005
U.S. Dist. LEXIS 12462, 2005 WL 1501672, at *2 (D.P.R. June 24, 2005)). A court can
properly consider new facts that arise after the initial decision as new evidence in support of a
motion for reconsideration. See Smith v. R.I. State Servs. for the Blind and Visually
Handicapped, 581 F. Supp. 566, 575 (D.R.I. 1984) (remarking that no new facts arose after the

Doc. No. 50563759 

9

initial hearing that give rise to a need for reconsideration). “‘Interlocutory orders, including
denials of motions to dismiss, remain open to trial court reconsideration, and do not constitute
the law of the case.’” W. Reserve Life Assur. Co. v. Caramadre, 2012 U.S. Dist. LEXIS 14327,
* 18 (D.R.I. Feb. 7, 2012) (quoting Perez-Ruiz v. Crespo-Guillen, 25 F.3d 40, 42 (1st Cir. 1994).
The Court should reconsider the Order. First, the intervening indictment of Caramadre
and Radhakrishnan magnifies the danger of potentially self-incriminating statements made by
either one of them in answering the interrogatories on behalf of EPR. First, the indictment is a
new fact that strengthens the argument that EPR cannot answer the interrogatories. The threat of
an indictment which prompted this Court to enter the ICMO has now ripened into a formally
returned and filed indictment. Even the meticulously designed process set forth by the Court in
the Order does not provide sufficient protection in light of this new fact. The Order allows
Target Defendants to refuse to provide information to the agent in response to an interrogatory in
reliance on the ICMO. However, such a response would be directly traceable back to the
invocation of Fifth Amendment privilege and likely result in the very same prejudice that the
ICMO was designed to prevent.
Second, EPR’s inability to identify an agent willing to respond to the interrogatories on
its behalf is an additional new fact that warrants reconsideration of the Order. When this Court
entered the Order, Caramadre and Radhakrishnan had not yet been indicted. The indictment has
proved to be an insurmountable obstacle to EPR’s attempt to designate an agent to provide
responses. Moreover, the cost of this litigation and the concomitant criminal investigation and
prosecution has depleted Caramadre’s funds to the point where he can no longer afford to pay
attorneys. Caramadre is the only person associated with EPR. EPR has no assets. As the Court
recognized at the February 22, 2012 chambers conference, it is unlikely that any person

Doc. No. 50563759 

10

designated to serve as EPR’s agent would be paid for the provision of such services. The Court
declined to appoint an agent, in part, for that very reason. Thus, as a practical matter, the new
developments since the entry of the Order make it impossible for EPR to comply with the Order.
Third, and perhaps most importantly, the new fact of the Court’s decision to stay the civil
litigation until the conclusion of the criminal prosecution also militates strongly in favor of
reconsideration. The Order does not allow for any other interrogatories, requests for admission
or depositions (written or oral). The only discovery permitted is any additional document
discovery, for which the restrictions set forth in the ICMO remain in place. There is no
prejudice to Plaintiffs if EPR is relieved of the obligation to respond to the interrogatories.
Granting reconsideration will simply put EPR on the same footing as the rest of the remaining
defendants in these cases.6
CONCLUSION
For the reasons stated herein, EPR respectfully requests that the Court: (1) grant this
motion for reconsideration; (2) vacate the order compelling EPR to answer the interrogatories
propounded by Plaintiffs in these matters; and (3) enter an order denying Plaintiffs’ motion to
compel EPR to answer the interrogatories.

6

Additionally, there are no claims remaining against EPR in Case No. 09-470. EPR is moving for entry of final
judgment in its favor in that case simultaneously with the filing of this motion. At the very least, reconsideration of
the Order is necessary to relieve EPR of the obligation to respond to discovery in Case No. 09-470 because it is no
longer a defendant in that case.

Doc. No. 50563759 

11

Dated: Providence, Rhode Island
March 22, 2012
ESTATE PLANNING RESOURCES, INC.,
By its Attorneys,

/s/ Adam M. Ramos____________
Robert G. Flanders, Jr. (# 1785)
Adam M. Ramos (#7591)
HINCKLEY, ALLEN & SNYDER LLP
50 Kennedy Plaza, Suite 1500
Providence, RI 02903
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

CERTIFICATE OF SERVICE
I hereby certify that on March 22, 2012, a copy of the foregoing 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/ Adam M. Ramos

Doc. No. 50563759 

12