Civil lawsuit filed against NWHL

8/17/2019 Civil lawsuit filed against NWHL

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UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

* * * * * * * * * * * * * * * * * * * * * * * * * * * * *

Michael Moran, *

Plaintiff ** Civil No.: ____________________

v. *

*

Danielle Rylan, NWHL Foundation, Inc., *

NWHL Group, LLC and NWHL Holdings, LLC *

Defendants *

* * * * * * * * * * * * * * * * * * * * * * * * * * * * *

COMPLAINT

Plaintiff, Michael Moran, by and through his attorneys, Cronin, Bisson, & Zalinsky P.C.,

brings this suit against Defendants, and in support thereof states as follows:

Parties

1. Plaintiff, Michael Moran, is a natural person with a residential address of ------

------, Boston, Massachusetts 02215.

2. Defendant, Danielle Rylan, is a natural person with a residential address of ----

-----, Tampa, Florida 33609.

3. Defendant, NWHL Foundation, Inc., is registered with the New York Secretary of

State as a domestic for-profit corporation with service address of 501 Fifth Avenue, New York,

New York 10017. Exhibit 1.

4. Defendant, NWHL Group, LLC, is registered with the New York Secretary of State as

a domestic limited liability company with a principal address of 67 West Street Suite 401-B11,

Brooklyn, New York 11222-2093. Exhibit 2.

Case 1:16-cv-10787 Document 1 Filed 04/27/16 Page 1 of 11


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5. Defendant, NWHL Holdings, LLC, is registered with the New York Secretary of State

as a domestic limited liability company with a principal address of 67 West Street Suite 401-

B11, Brooklyn, New York 11222-2093. Exhibit 3.

6. Defendants own and operate hockey teams, one of which is “Boston Pride,” situated in

Boston Massachusetts area, playing home games at the Edge Sports Center in Bedford

Massachusetts, the Harvard Bright-Landry Center in Boston, Massachusetts, and the Raymond

Bourque Arena in Beverly, Massachusetts.

Jurisdiction and Venue

7. The parties are diverse, and the amount in controversy is greater than $75,000, giving

this Court jurisdiction over this matter pursuant to 28 U.S.C. § 1332.

8. Because the Defendants own and operate a hockey team situated in the Boston area

and themselves have with minimum contacts with the Boston Massachusetts area, it should have

been reasonably foreseeable to them that they may be hauled into court in Massachusetts. See

Int’l Shoe Co. v. Wash., 326 U.S. 310, 317 (1945) (“Presence in the state . . . [exists] when the

activities of the corporation there have not only been continuous and systematic, but also give

rise to the liabilities sued on, even though no consent to be sued or authorization to an agent to

accept service of process has been given.”)

9. Additionally, Defendant Rylan, as representative of Defendants, regularly attends

league-related events in the Boston area and conducts league-related business in Massachusetts,

subjecting herself to the jurisdiction of this state. Id.

Facts

10. Rylan and Moran had a friendship that goes back several years.

11. The pair discussed the foundation of a women’s hockey league in 2013.


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12. Rylan was working for the NHL Network and attempting to launch a coffee shop at

that time.

13. Rylan believed that the league would provide female athletes more opportunities for

playing hockey after college, and no one had started a United States based league.

14. Moran and Rylan agreed they would engage in this endeavor together, with Moran

providing some seed money.

15. Also, the fledgling league had certain start-up costs that Rylan could not afford to

pay for out of her own pocket.

16. Accordingly, the pair agreed that Moran would pay mostly fixed, regularly occurring

sums to Rylan as an investment in the league.

17. Initially, the pair agreed that these sums would be considered an investment in the

league, which Rylan and Moran would each control and from which each might someday profit,

as co-owners.

18. Rylan accepted payments for roughly two years and devoted much of her time to the

league’s formation.

19. Beginning around February 2015, Moran also started working full time as the

league’s Chief Marketing Officer.

20. Then, the league was launched in April 2015.

21. At that time, Moran and Rylan agreed their share of the profits of the league would

be 40/60, respectively.

22. None of these agreements were put in writing because Moran and Rylan were friends

and had been friends for years.



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23. Moran made payments to Rylan and to the league, knowing that Rylan was directing

these sums where they were needed, regardless of how they were received.

24. These purposes included paying vendors and players and repaying debts incurred by

the league. Exhibit 4.

25. Moran also made direct payments to third party vendors on behalf of the league.

26. These payments included sums sent to marketing companies, web hosting services,

advertising services, including Facebook, and sums paid related to events that the league hosted

for promotions and fundraising.

27. Moran assisted in the launch of the league with publicity, party planning, advertising,

and other logistics.

28. Moran was not compensated for the labor he expended for the league but Rylan was.

29. Thereafter, following launch of the league, Moran continued making payments

directly to Rylan or to the league’s foundation as a means of providing funds to be used for

league purposes.

30. In total, Moran provided more than $200,000 in financial support to launch the

league.

31. Shortly after Moran and Rylan agreed that their shares in the league would be 40/60,

respectively, Rylan sent an email to another individual affiliated with the league, indicating that

Moran was only allocated a 2 percent share.

32. Moran learned of this email, which Rylan did not intend Moran to see, and the pair’s

friendship soured.

33. The first pay cycle came in October 2015, when the league was to pay its players.



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34. On the eve of that deadline, Rylan, the league’s self -appointed commissioner, had no

plan for payment.

35. Rylan, Moran, and other officers, investors, and friends of the league cobbled

together enough money to be able to pay players their first paychecks.

36. However, after seeing how poorly organized the league was and after the

deterioration of the relationship between Moran and Rylan, Moran and Rylan agreed Moran’s

involvement with the league should be severed.

37. Specifically, Rylan agreed Moran would terminate his involvement as an investor,

and Rylan would cause his financial investments to be treated as loans and returned to him.

38. Rather than deny that Moran had lent sums to the league to assist in its formation,

Rylan, the league’s counsel, Ben Natter and its Chief of Operations at the time, George Speirs,

attempted to negotiate a repayment plan.

39. However, the league was not keen on paying Moran the full sum he had lent to allow

the league to be founded.

40. Additionally, George Speirs, who had been finalizing details of repayment with

Moran, was terminated in early February 2016.

41. Thereafter, communication between the league and Moran regarding repayment

ceased.1

42. As such, the parties could not coordinate mutually agreeable repayment terms.

43. This action has therefore become necessary.

1 On February 29, 2016 the league sought to have Moran transfer control of the league website. When Moran did notimmediately respond, on March 15, 2016, George Speirs’ login was used to attempt to access the league website toretake control. This effort came from an internet protocol (“IP”) address at the league office, was done withoutMoran’s assent or knowledge, and it was done after Speirs had left the league’s employment. Additionally, the

league requested access to the website that Moran had caused to be created and paid for, despite that it had notupheld its end of the bargain with Moran to pay his loan to the league.



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Count I – Breach of Contract (all Defendants)

44. The Plaintiff re-alleges and incorporates herein the allegations set forth above.

45. Moran and Rylan, acting on behalf of each of the Defendants, entered into a valid

contact because all of the essential elements of a contract were satisfied: offer, acceptance,

consideration, and a meeting of the minds. Situation Mgmt. Sys. v. Malouf, Inc., 724 N.E.2d 699,

703 (Mass. 2000).

46. Initially, Moran agreed to invest sums with the league as a co-founder and co-owner

of the league.

47. When that relationship soured, Moran requested that he be repaid the sums he lent as

a loan instead of continuing his involvement as an investor.

48. The league, through Rylan, agreed.

49. Nonetheless, Defendants have breached this agreement by failing to pay the balance

due to Moran for loans expended to the league.

Count II – Partnership Dissolution and Accounting (Rylan)


51. When individuals associate for the purpose of sharing profits and control, there is a

presumption the agreement they have made is in the nature of a partnership. MASS. GEN. LAWS

ch. 108A, § 6; see Shain Inv. Co. v. Cohen, 443 N.E.2d 126, 130 (Mass. App. Ct. 1982).

52. In this case, the agreement originally reached between Moran and Rylan was that

they would share profits, losses, and control in a 40/60 ratio, respectfully.

53. Therefore, if the Court finds that no contract was reached to treat Moran’s investment

as a loan, then Moran owned 40 percent of the league and had a proportionate controlling

interest.


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54. To the extent Rylan assigned Moran some other ownership interest without his

knowledge when the league was incorporated, that assignment constituted a breach of Rylan’s

fiduciary duty to her co-partner and fraud in the inducement, causing Moran to enter into the

partnership wrongfully. See Meehan v. Shaughnessy, 535 N.E.2d 1255, 1263 (Mass. 1989)

(discussing duties of good faith and loyalty); MASS. GEN. LAWS ch. 108A, § 39.

55. From the first discussion of the formation of the league, Moran and Rylan agreed that

the two of them would share in ownership and control of the league.

56. Nonetheless, Rylan assigned to others interest in the league that belonged to Moran

and attempted to hide that assignment from Moran all while inviting and encouraging his

continued participation in the league, including representing to others that he was the marketing

officer for the league.

57. Moran is therefore entitled to rescind the partnership, to receive a return of his

investment, and to be indemnified by the defrauding partner: Danielle Rylan. Madigan v.

McCann, 190 N.E.2d 215, 217 (Mass. 1963); Mass. Gen. Laws ch. 108A § 39.

58. In winding up the partnership, Moran is also entitled to an accounting. MASS. GEN.

LAWS ch. 108A, §§ 21; 22(a).

Count III – MASS. GEN. LAWS ch. 93A (all Defendants)


60. The contractual violations and misrepresentations discussed above constitute unfair

and deceptive business practices pursuant to Mass. Gen. Laws chapter 93A.

61. To prevail on a 93A claim, the objectionable conduct must attain a level of rascality

that would raise an eyebrow of someone inured to the rough and tumble of the world of

commerce. Levings v. Forbes & Wallace, Inc., 396 N.E.2d 149, 153 (Mass. App. Ct. 1979).


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62. Defrauding a partner into continued financial support while intentionally

misrepresenting the ownership and control interest being provided to that partner certainly

constitutes an unfair and deceptive trade practice.

63. Likewise, agreeing to treat an investor’s contribution as a loan in exchange for their

agreeing to terminate involvement in the business and then refusing to repay the loan also

constitutes a deceptive trade practice.

64. Moran seeks treble damages and attorney’s fees associated with this action pursuant

to chapter 93A.

Count IV –

Quantum Meruit (all Defendants)


66. Even if the Court does not find that the Moran had an enforceable contract with

Defendants, Moran is entitled to obtain the value of the services provided, for which he has not

been paid.

67. Quantum meruit refers to contracts implied in fact or to obligations imposed by law

without regard to the intention or assent of the parties bound, for reasons dictated by reason and

justice.

68. “To achieve recovery upon the theory of quantum meruit, the claimant must prove

(1) that it conferred a measurable benefit upon the defendants; (2) that the claimant reasonably

expected compensation from the defendants; and (3) that the defendants accepted the benefit

with the knowledge, actual or chargeable, of the claimant’s reasonable expectation.”

Finard & Co., LLC v. Sitt Asset Mgmt., 945 N.E.2d 404, 407 – 08, (Mass. App. Ct. 2011).

69. Moran served as the league’s Chief Marketing Officer full time for eight months,

from February to October 2015.


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70. In this role, he primarily engaged in advertising on behalf of the league, but he also

ensured a robust web presence, contracting and paying for web hosting and other digital

marketing services.

71. At the time, Moran’s expectation was that he would be paid out of the future

earnings of the league.

72. However, Moran’s involvement with the league has ended, and he has agreed not to

receive any future earnings from it.

73. In exchange and in addition to repaying sums lend to found the league, Moran must

be paid the value of the services he provided the league.

74. The league was aware Moran expected reimbursement in some form, and it has

benefitted from eight months of Moran’s skilled marketing efforts.

75. Thus, he is entitled to be reimbursed for the reasonable cost of his labor.

76. Upon information and belief, the other league executives receive compensation

ranging from $80,000 to $90,000 in the form of an annual salary.

77. Thus, Moran should be reimbursed for eight months at the minimum salary range of

$80,000 per year, which is roughly $50,000, minus appropriate withholdings.

Count V – Restitution (all Defendants)


79. As an alternative to breach of contract, partnership, 93A, Moran conferred a benefit

upon Defendants by paying debts on their behalf, lending money for them to pay their own debts

and for other services, and it would be unjust for Defendants to retain that benefit.

80. Defendants must make restitution of sums Moran lent to them.



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81. “Restitution is not damages; restitution is a restoration required to prevent unjust

enrichment. The fundamental substantive basis for restitution is that the defendant has been

unjustly enriched by receiving something, tangible or intangible, that properly belongs to the

plaintiff. Restitution rectifies unjust enrichment by forcing restoration to the plaintiff.”

Santagate v. Tower , 833 N.E.2d 171, 180 (Mass. App. Ct. 2005) (quoting 1 DOBBS, LAW OF

R EMEDIES § 4.1(1), at 557 (2d ed. 1993)).

82. In this case, Moran made payments to found a professional women’s hockey league

because he believes in what it can be.

83. Initially, Moran accepted that he would be an investor and see a return on sums paid

at some point in the distant future.

84. As the league was launched, however, it rapidly became apparent that not all others

involved in leadership of the league had responsible visions for how to manage the finances of

the league.

85. At that time, there was an agreement for Moran’s investments to instead be treated as

a loan and to be repaid.

86. With that decision, Moran’s involvement in the decision making for the league

would also end.

87. Since Moran agreeing to cease his involvement and actually ceasing his involvement

with the league, however, the league has failed and refused to return sums lent to it initially.

88. It is unjust for the league to retain sums lent to it while refusing to reimburse the

lender.

89. Plaintiff requests trial by jury on all claims.

WHEREFORE, the Plaintiff respectfully requests this Honorable Court:


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A. Award the Plaintiff reimbursement of sums lent to Defendants;

B. Find Plaintiff is a partner in the league and order an accounting;

C. Award the Plaintiff sums he should have been paid his efforts as Chief Marketing

Officer;

D. Order Defendants to reimburse Plaintiff for sums paid to them or on their behalf;

E. Award Plaintiff his attorney’s fees and costs associated with bringing this action

and treble damages; and

F. Grant such other relief as it may deem just and proper.

Respectfully submitted,

MICHAEL MORAN

By and through its attorneys,CRONIN, BISSON & ZALINSKY P.C.

Dated: April 27, 2016 /s/ John G. Cronin

John G. Cronin, Esquire (MA BBO #629011)----- Manchester, New Hampshire 03104----



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S 44 (Rev. 11/15) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except

rovided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for theurpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OFTHE TRACT OF LAND INVOLVED.

Attorneys (If Known)

I. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for(For Diversity Cases Only) and One Box for Defendant

1 U.S. Government 3 Federal Question PTF DEF PTF D

Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4

of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5

Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6

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110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act

120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC

130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))

140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionm

150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust & Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking

151 Medicare Act 330 Federal Employers’ Product Liabi lity 830 Patent 450 Commerce

152 Recovery of Defaulted Liability 368 Asbestos Personal 840 Trademark 460 Deportation

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(Excludes Veterans) 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizatio 153 Recovery of Overpayment Liabili ty PERSONAL PROPERTY 710 Fair Labor Standards 861 HIA (1395ff) 480 Consumer Credit

of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud Act 862 Black Lung (923) 490 Cable/Sat TV

160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending 720 Labor/Management 863 DIWC/DIWW (405(g)) 850 Securities/Commod

190 Other Contract Product Liability 380 Other Personal Relations 864 SSID Title XVI Exchange

195 Contract Product Liability 360 Other Personal Property Damage 740 Railway Labor Act 865 RSI (405(g)) 890 Other Statutory Acti

196 Franchise Injury 385 Property Damage 751 Family and Medical 891 Agricultural Acts

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REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 791 Employee Retirement FEDERAL TAX SUITS Act

210 Land Condemnation 440 Other Civil Rights Habeas Corpus: Income Security Act 870 Taxes (U.S. Plaintiff 896 Arbitration

220 Foreclosure 441 Voting 463 Alien Detainee or Defendant) 899 Administrative Proc

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240 Torts to Land 443 Housing/ Sentence 26 USC 7609 Agency Decision

245 Tort Product Liability Accommodations 530 General 950 Constitutionality of

290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION State Statutes

Employment Other: 462 Naturalization Application 446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration

Other 550 Civil Rights Actions

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Conditions of

Confinement

V. ORIGIN (Place an “X” in One Box Only)

1 OriginalProceeding

2 Removed fromState Court

3 Remanded fromAppellate Court

4 Reinstated or Reopened

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Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

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VII. REQUESTED INCOMPLAINT:

CHECK IF THIS IS A CLASS ACTIONUNDER RULE 23, F.R.Cv.P.

DEMAND $ CHECK YES only if demanded in complaint

JURY DEMAND: Yes No

VIII. RELATED CASE(S)IF ANY

(See instructions):JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 1:16-cv-10787 Document 1-1 Filed 04/27/16 Page 1 of 2

Michael Moran Danielle Rylan, NWHL Foundation, Inc., NWHL Group, LLC andNWHL Holdings, LLC

Suffolk Hillsborough, FL

(c) Attorneys (Firm Name, Address, and Telephone Number)John G. Cronin, Esquire, Cronin Bisson & Zalinsky, P.C. ------ Manchester, New Hampshire 03104 ------

28 U.S.C. 1332

Breach of contract, partnership, MGL c. 93A, quantum meruit, restitution for reimbursement.

200,000.00

04/27/2016 /s/ John G. Cronin



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JS 44 Reverse (Rev. 11/15)

INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as

required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is

required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk o

Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, us

only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency andthen the official, giving both name and title.

(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides attime of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In lan

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II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.

United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.

United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.

Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendm

to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code tak

precedence, and box 1 or 2 should be marked.

Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the

citizenship of the different parties must be checked . (See Section III below; NOTE: federal question actions take precedence over diversitycases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Marksection for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI belowsufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more th

one nature of suit, select the most definitive.

V. Origin. Place an "X" in one of the six boxes.Original Proceedings. (1) Cases which originate in the United States district courts.

Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.

When the petition for removal is granted, check this box.Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the fil

date.

Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.

Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers o

multidistrict litigation transfers.

Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 140

When this box is checked, do not check (5) above.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictionstatutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.

Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docketnumbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.

Case 1:16-cv-10787 Document 1-1 Filed 04/27/16 Page 2 of 2Case 1:16-cv-10787 Document 1-1 Filed 04/27/16 Page 2 of 2


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UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS

1. Title of case (name of first party on each side only)

2. Category in which the case belongs based upon the numbered nature of suit code listed on the civil cover sheet. (See local

rule 40.1(a)(1)).

I. 410, 441, 470, 535, 830*, 891, 893, 895, R.23, REGARDLESS OF NATURE OF SUIT.

II. 110, 130, 140, 160, 190, 196, 230, 240, 290,320,362, 370, 371, 380, 430, 440, 442, 443, 445, 446, 448, 710, 720,740, 790, 820*, 840*, 850, 870, 871.

III. 120, 150, 151, 152, 153, 195, 210, 220, 245, 310, 315, 330, 340, 345, 350, 355, 360, 365, 367, 368, 375, 385,400, 422, 423, 450, 460, 462, 463, 465, 480, 490, 510, 530, 540, 550, 555, 625, 690, 751, 791, 861-865, 890, 896,

950.

*Also complete AO 120 or AO 121. for patent, trademark or copyrigh t cases.

3. Title and number, if any, of related cases. (See local rule 40.1(g)). If more than one prior related case has been filed in thisdistri ct please indicate the title and number of the first fil ed case in this court.

4. Has a prior action between the same parties and based on the same claim ever been filed in this court?

YES NO

5. Does the complaint in this case question the constitutionality of an act of congress affecting the public interest? (See 28 USC§2403)

YES NO If so, is the U.S.A. or an officer, agent or employee of the U.S. a party?

YES NO

6. Is this case required to be heard and determined by a district court of three judges pursuant to title 28 USC §2284?

YES NO

7. Do all of the parties in this action, excluding governmental agencies of the United States and the Commonwealth of Massachusetts (“ governmental agencies”), residing in Massachusetts reside in the same division? - (See Local Rule 40.1(d)).

YES NO

A. If yes, in which d ivi sion do al l of the non-government al par ties res ide?

Eastern Division Central Division Western Division

B. If no, in which division do the majority of the plaintiffs or the only parties, excluding governmental agencies,

residing in Massachusetts reside?

Eastern Division Central Division Western Division

8. If filing a Notice of Removal - are there any motions pending in the state court requiring the attention of this Court? (If yes,

submit a separate sheet identifying the motions )

YES NO

(PLEASE TYPE OR PRINT)

ATTORNEY'S NAME

ADDRESS

TELEPHONE NO.

(CategoryForm-201.wpd )


Michael Moran v. Danielle Rylan, et al

✔

N/A

✔

✔

✔

✔

✔

✔

✔

John G. Cronin

Cronin Bisson & Zalinsky, P.C., -----, Manchester, New Hampshire 03104

----



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Exhibit 1


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Documents

Civil lawsuit filed against NWHL