Pleadings and Court responses, filed by date (Date links to separate web pages
containing the listed documents):
- July
26, 2011:
- Verified Motion to Amend Plaintiffs'
Ex Parte Motion for Restraining Order to include
Plaintiff Jennifer J. Adams
- Affidavit in Support of Plaintiffs'
Ex Parte Motion for Restraining Order to include
Intelius Report
- Exhibit T: Intelius Criminal Report
for James Kimberly Torres
- Verified Motion to Continue Hearing
of Plaintiffs' Motion to Maintain Status Quo until
Motion for Mental Exam can be heard
- Verified Motion for Mental Exam for
Defendant Sophie J. Torres
- Exhibit A: Addendum to the Will of
Defendant Sophie J. Torres - Permanent Transfer of
Property Rights
- Exhibit Q: Photos of Defendant
Sophie J. Torres' car and how she parked it July
22-July 23, 2011
- Exhibit R: Durable Power of
Attorney for Financial Management,
Principal: Defendant Sophie J. Torres,
Attorney-in-Fact: Plaintiff Jesse E. Torres III
- Exhibit S: Health Care Proxy for
Defendant Sophie J. Torres appointing Plaintiff
Jesse E. Torres III as her agent
- Exhibit G: The Will of Defendant
Sophie J. Torres
- July
27, 2011:
- Verified Motion to Allow Summons and
Complaint Service for Out-Of-State Defendants by U.S.
Mail, Return
- Exhibit U: Email from Arthur
Aaronson demanding service be made on him on behalf
of the Defendants
Jesse E. Torres IV (aka Jesse Stockwell, Jesse E.
Stockwell) and Debtmerica, LLC.
- July
28, 2011:
- Plaintiff Jesse E. Torres III's First
Request for Production of Documents from the Defendant
Sophie J. Torres
- July
29, 2011:
- Plaintiff Jesse E. Torres III's
First Interrogatories to the Defendant Sophie J.
Torres
- August
10, 2011:
- Motion Allowed: by
Plaintiffs to Allow Summons and Complaint for Service
of Process Out of State by US Mail Return Service
- August
18, 2011:
- Plaintiff Jesse E. Torres III's First
Request for Production of Documents from the Defendant
Debtmerica, LLC
- August
19, 2011:
- Defendant Sophie Torres' Ex Parte
Motion For Short Order Of Notice
- Defendant Sophie Torres' Motion For
Plaintiffs To Cease And Desist (RESTRAIN) From Posting
Information In The Internet
- Plaintiffs Notice Of Filing Rule 9a
Package
- August
22, 2011: 9a Package - Motion to
Dismiss Defendant Sophie J. Torres
- Defendant's Motion to Dismiss for
Failure to State a Claim;
- Memorandum of Law in Support of
Defendant, Sophie J. Torres, Motion To Dismiss
- Plaintiffs' Response And Opposition
To Defendant Sophie J. Torres' Motion To Dismiss For
Failure To State A Claim;
Request For Hearing
- Exhibit EE : Letter of intent, to
set up the Torres Farm Trust, Inc., signed by the
Defendant Sophie J. Torres and her natural son,
Plaintiff Jesse E. Torres III, on August 06, 2009
- Exhibit FF : Sealed envelope
containing the Will of Defendant Sophie J. Torres,
sent to Jeffrey S. Cooper on May 08, 2009. Unbroken
seal is signed by Plaintiff Jesse E. Torres III
- Exhibit GG : Sealed envelope
containing the Addendum to the Will (Contract) of
Defendant Sophie J. Torres, sent to Jeffrey S.
Cooper on May 08, 2009. Unbroken seal is signed by
Plaintiff Jesse E. Torres III
- Exhibit HH : Letter to Jeremy
Carter from Plaintiff Jesse E. Torres III, Re: Your
correspondence appears have been intercepted, not
receiving in a timely manner as required under 9 (a)
- Affidavit In Support Of Plaintiffs'
Response And Opposition To Defendant Sophie J. Torres'
Motion To Dismiss For Failure To State A Claim;
Request For Hearing
- August
23, 2011:
- Certificate of Service of Verified
Complaint and all related documents to: Debtmerica,
LLC
- Certificate of Service of Verified
Complaint and all related documents to: Jesse E.
Torres IV (aka Jesse Stockwell, Jesse E. Stockwell)
- Plaintiff Jesse E. Torres III's First
Request For Production Of Documents from The Defendant
Jesse E. Torres IV (aka Jesse Stockwell, Jesse E.
Stockwell)
- Plaintiffs' Verified Ex-Parte Motion
For Massachusetts Superior Court Rule9(A) Exception
- August
25, 2011:
- Plaintiffs' Ex Parte Motion for Short
Order of Notice or in the Alternative: Motion to
Combine
- Plaintiffs' Memorandum of Law in
Support of Motion of Evidentiary Hearing
- Plaintiffs' Motion to Combine
Motions, and to Combine With, the Scheduled Hearing of
Defendant Sophie J. Torres' Motion to Cease and Desist
- Plaintiffs' Memorandum in Support of
Plaintiffs' Motion to Combine Motions, Opposition to,
and to Combine With, the Scheduled Hearing of
Defendant Sophie J. Torres' Motion to Cease and Desist
- Plaintiffs' Opposition to the
Defendant Sophie J. Torres' Motion for Plaintiffs to
Cease and Desist (Restrain) from Posting Information
in the Internet
- Plaintiffs' Attestations Affidavit To
Motions And Memorandums
- August
29, 2011:
- Plaintiffs' Motion To Strike Any And
All Claims From/To New England Watchdogs, The Personal
Interests Of Attorney Jeremy Carter, Defendants Not
Represented By Mr. Carter, Any References To Any
Warning To DISCONTINUE All Internet Postings Within
The DEFENDANT Sophie J. Torres' Motion For Plaintiffs
To Cease And Desist (RESTRAIN) From Posting
Information In The Internet
- August
31, 2011:
- Motion Denied: by
Defendant, Sophie Torres, for Plaintiffs to Cease and
Desist (Restrain) from posting Information in the
Internet
- 9A Package: Plaintiffs' Motion for
Mental Exam of Defendant, Sophie Torres
- 9A Package: Plaintiffs' Verified
Motion To Restrain Certain Parties From Discussing The
Case Or The Plaintiffs With The Defendant Sophie J.
Torres
- September
01, 2011:
- Plaintiff Jesse E. Torres Ill's First
Interrogatories To The Defendant Jesse E. Torres IV
(aka Jesse Stockwell, Jesse E. Stockwell)
- September
21, 2011:
- Plaintiffs' Ex
Parte Motion For Short Order Of Notice Of
Plaintiff's Verified Motion To Compel Limited
Expedited Discovery
- Plaintiff's Verified Motion To Compel
Limited Expedited Discovery
- Plaintiffs' Notice of 9a Service
- October
12, 2011: 9a Package - Motion to
Dismiss Defendant Jesse E. Torres IV (aka Jesse
Stockwell, Jesse E. Stockwell)
- Defendant, Jesse E. Torres IV (aka
Jesse Stockwell, Jesse E. Stockwell), Motion To
Dismiss For Failure To State A Claim
- Memorandum Of Law In Support Of
Defendant, Jesse E. Torres IV (aka Jesse Stockwell,
Jesse E. Stockwell), Motion To Dismiss
- Plaintiffs' Response And Opposition
To "DEFENDANT, Jesse E. Torres IV (aka Jesse
Stockwell, Jesse E. Stockwell), Motion To Dismiss
For Failure To State A Claim"; Request For Hearing
- Exhibit II: Affidavit from Drew
and Gail Framson, witnesses to Defendant Sophie J.
Torres' signing of legal documents
on April 24, 2009
- Affidavit In Support Of Plaintiffs'
Response And Opposition To "DEFENDANT, Jesse E.
Torres IV (aka Jesse Stockwell, Jesse E. Stockwell),
Motion To Dismiss For Failure To State A Claim";
Request For Hearing, Verification Attestations
- Motion Allowed:
Plaintiffs' Ex Parte Motion for Short Order of
Notice
- October
17, 2011: Motion for Summary Judgement
against Sophie J. Torres
- Plaintiffs' Emergency Motion For
Hearing of Plaintiffs' Motion For Summary Judgment
With Defendants' Scheduled Hearing of Three (3)
12(b)(6) Motions to Dismiss and Other Scheduled
Motions on November 17, 2011
- Summary Judgement Cover Page - Index
of Pleadings
- Summary Judgement Table of Contents
- Summary Judgement Index of Cases
- Plaintiffs' Motion For Partial
Summary Judgement Against the Defendant Sophie J.
Torres
- Plaintiffs' Memorandum In Support Of
Plaintiffs' Motion For Partial Summary Judgement
Against the Defendant Sophie J. Torres
- Plaintiffs' Affidavit In Support Of
Plaintiffs' Memorandum In Support Of Plaintiffs'
Motion For Partial Summary Judgement Against the
Defendant Sophie J. Torres
- Plaintiffs' Concise Statement In
Support Of Their Motion For Summary Judgment
- Verified Complaint
- Exhibits
- Plaintiffs' Notice of 9a Service
Summary Judgement
- Plaintiffs' Certificate of Service
Summary Judgement
- October
18, 2011: 9a Package - Motion to
Dismiss Defendant Debtmerica, LLC
- Defendant, Debtmerica, LLC, Motion to
Dismiss;
- Defendant Debtmerica, LLC's
Memorandum in Support of Motion to Dismiss;
- Plaintiffs' Response And Opposition
To "DEFENDANT, Debtmerica, LLC's, Motion To Dismiss
For Failure To State A Claim";
Request For Hearing
- Exhibit II: Affidavit from Drew and
Gail Framson, witnesses to Defendant Sophie J.
Torres' signing of legal documents
on April 24, 2009
- Affidavit In Support Of Plaintiffs'
Response And Opposition To "DEFENDANT, Debtamerica,
LLC's, Motion To Dismiss For Failure To State A
Claim"; Request For Hearing
- October
26, 2011:
- Plaintiffs' Motion for hearing
Plaintiffs' Motion for Summary Judgment with
Defendants' Scheduled Hearing
of Motions to Dismiss on 11/17/11
- November
01, 2011: 9a
Package - Motion to Continue: Defendants'
- DEFENDANTS, Sophie J. Torres, Jesse
E. Torres IV (aka Jesse Stockwell, Jesse E.
Stockwell), and Debtmerica, LLC, Motion to Continue
- Plaintiffs' Verified Response and
Opposition to Defendants Jesse E. Torres IV's (aka
Jesse Stockwell, Jesse E. Stockwell), Sophie J.
Torres' and Debtmerica, LLC's Motion to Continue with
Attestations and Certificate of Service
- November
15, 2011:
- Motion Denied:
DEFENDANTS, Sophie J. Torres, Jesse E. Torres IV (aka
Jesse Stockwell, Jesse E. Stockwell), and Debtmerica,
LLC, Motion to Continue
- November
23, 2011:
- Memorandum of Decision and Order on
Defendant's Motion for Summary Judgment
- November
28, 2011:
- December
16, 2011:
- December
21, 2011:
- Emergency Motion to accept affidavit
of indigency
- December
27, 2011:
- Motion Allowed: as
to court cassette recording and transcripts for motion
hearings
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Appeal Court
Commonwealth of Massachusetts
Case No. 2012-P-0524
- Decision: The Judgement is
Vacated, and the Case is Remanded to the Superior Court.
- Notice of Decision
- Memorandum and Decision
- Oral Argument
- Notices and Requests
- Notice from Appeals Court, March 27,
2012: Docket Entry and Allowed Motions
- Notice from Appeals Court, January
11, 2013: Case is under Advisement
- Notice from Appeals Court, March 08,
2013: Notice of Oral Arguments scheduled for April 11,
2013
- Request from Appellants, March 11,
2013: Request for Oral Arguments via telephone/Skype
- Notice from Appeals Court, April 4,
2013: Notice of Argument by Telephone
- Appellants' letter, April 12, 2013:
Rule 16 (l) letter
- Appellants' letter, April 12, 2013:
Letter regarding correction to a case
- Appellants' letter, November 25,
2013: Letter regarding sending the mandate to the
lower court and change of venue
- Brief
- Appellants' Brief
- Appellants' Affidavit concerning
the requests for Trial Court Hearing Tapes
- Record Appendix
- Part 1
- Part 2
- Part 3
- Part 4
- Appellees' Brief
- Appellants' Reply Brief
- Transcripts:
- Preliminary Injunction of July 26,
2011
- Motion Hearing of August 30, 2011
- Motion Hearing of November 17, 2011
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