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PROVIDENCB, SC
DEREK THERIEN
Now comes the Plaintiff and hereby prays this Court to enter an Adjudging the Defendant
As grounds therefore, the Plaintiff relies on the Complaint filed with this Court on
October 29,2009. The same complaint that formed the basis of a TRO granted by Judge
Lanphear on October 29,2009 and a Preliminary Injrmctisn issued by Magistrate Revens after
taking sworn testimony on November 72,20A9. This Preliminary Injunction is still in full force
and effect.
The Defendant has ordered the Transcript of the Preliminary Injunction Hearing held
before Magistrate Revens. There is confusion regarding her Order and given this fact, no
foreclosure should take place without the benefit of the transcript. The Defendant's view of the
docket, which is clear, is myopic and self serving and in line with the Foreclosure Industries
This Court should send this Defendant a strong message and hold it in contempt of an
This Court should fine this Defendant an amount equal to the mortgage in question for
said willful disregard of a Court Order and for its total lack of respect of the Court as a whole.
This Defendant has options that cost it nothing that would not be an open insult to the Court yet
it decides instead to test the mettle of the Court to stand by its own Orders and to stand by the
This is a compelling case where there has been an Order entered by a Justice based upon
her finding of wrongdoing in the handling of an assignment. To allow this Defendant to simply
ignore her comments, ruling and Order runs against everything that the Justice System stands for.
Further, given that there has been no change in circumstances since the TRO hearing and
the Preliminary Injunction Hearing, the order of the previous justices who heard this case should
not be disturbed.
WHEREFORE, the Plaintiff prays this Court to find the Defendant in willful
contempt of an order of this Court and that it fine this Defendant an amount equal to the
The Plaintiff,
By his attorney,
E sq u i re
lff Ei,l;"?lt :",*
Pawtucket. RI 02861
724-1904
CERTIFICATION
I hereby certify that I mailed a true and accurate copy of the within to Shanna Boughton,
Esquire,6 Kimball Lane, Suite 200, Lynnfield, MA 01940 on June 6,2011 and via email to
Shanna Boughton on even date.