nwhl lawsuit txt

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

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
*****************************
Michael Moran,
*
Plaintiff
*
*
v.
*
*
Danielle Rylan, NWHL Foundation, Inc.,
*
NWHL Group, LLC and NWHL Holdings, LLC *
Defendants
*
*****************************

Civil No.: ____________________

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 2 of 11

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 401B11, 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 not
immediately respond, on March 15, 2016, George Speirs’ login was used to attempt to access the league website to
retake control. This effort came from an internet protocol (“IP”) address at the league office, was done without
Moran’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 not
upheld 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)
50. The Plaintiff re-alleges and incorporates herein the allegations set forth above.
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)
59. The Plaintiff re-alleges and incorporates herein the allegations set forth above.
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)
65. The Plaintiff re-alleges and incorporates herein the allegations set forth above.
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)
78. The Plaintiff re-alleges and incorporates herein the allegations set forth above.
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

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

CIVIL COVER SHEET

JS 44 (Rev. 11/15)

The 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 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. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS

DEFENDANTS

Michael Moran

Danielle Rylan, NWHL Foundation, Inc., NWHL Group, LLC and
NWHL Holdings, LLC
Suffolk

(b) County of Residence of First Listed Plaintiff

County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES)
NOTE:

(c) Attorneys (Firm Name, Address, and Telephone Number)

Hillsborough, FL

(IN U.S. PLAINTIFF CASES ONLY)
IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

Attorneys (If Known)

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

II. BASIS OF JURISDICTION (Place an “X” in One Box Only)
u 1

U.S. Government
Plaintiff

u 3

Federal Question
(U.S. Government Not a Party)

u 2

U.S. Government
Defendant

u 4

Diversity
(Indicate Citizenship of Parties in Item III)

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only)
PTF
Citizen of This State
u 1

DEF
u 1

and One Box for Defendant)
PTF
DEF
Incorporated or Principal Place
u 4
u 4
of Business In This State

Citizen of Another State

u 2

u

2

Incorporated and Principal Place
of Business In Another State

u 5

u 5

Citizen or Subject of a
Foreign Country

u 3

u

3

Foreign Nation

u 6

u 6

IV. NATURE OF SUIT (Place an “X” in One Box Only)
CONTRACT
u
u
u
u
u
u
u

u
u
u
u
u

TORTS

110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veteran’s Benefits
160 Stockholders’ Suits
190 Other Contract
195 Contract Product Liability
196 Franchise

u
u
u
u
u
u
u
u
u
u

u
u
u
u
u
u

REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

u
u
u
u
u
u
u

PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers’
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities Employment
446 Amer. w/Disabilities Other
448 Education

FORFEITURE/PENALTY

PERSONAL INJURY
u 365 Personal Injury Product Liability
u 367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
u 368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
u 370 Other Fraud
u 371 Truth in Lending
u 380 Other Personal
Property Damage
u 385 Property Damage
Product Liability
PRISONER PETITIONS
Habeas Corpus:
u 463 Alien Detainee
u 510 Motions to Vacate
Sentence
u 530 General
u 535 Death Penalty
Other:
u 540 Mandamus & Other
u 550 Civil Rights
u 555 Prison Condition
u 560 Civil Detainee Conditions of
Confinement

u 625 Drug Related Seizure
of Property 21 USC 881
u 690 Other

BANKRUPTCY
u 422 Appeal 28 USC 158
u 423 Withdrawal
28 USC 157
PROPERTY RIGHTS
u 820 Copyrights
u 830 Patent
u 840 Trademark

LABOR
u 710 Fair Labor Standards
Act
u 720 Labor/Management
Relations
u 740 Railway Labor Act
u 751 Family and Medical
Leave Act
u 790 Other Labor Litigation
u 791 Employee Retirement
Income Security Act

u
u
u
u
u

SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))

FEDERAL TAX SUITS
u 870 Taxes (U.S. Plaintiff
or Defendant)
u 871 IRS—Third Party
26 USC 7609

IMMIGRATION
u 462 Naturalization Application
u 465 Other Immigration
Actions

OTHER STATUTES
u 375 False Claims Act
u 376 Qui Tam (31 USC
3729(a))
u 400 State Reapportionment
u 410 Antitrust
u 430 Banks and Banking
u 450 Commerce
u 460 Deportation
u 470 Racketeer Influenced and
Corrupt Organizations
u 480 Consumer Credit
u 490 Cable/Sat TV
u 850 Securities/Commodities/
Exchange
u 890 Other Statutory Actions
u 891 Agricultural Acts
u 893 Environmental Matters
u 895 Freedom of Information
Act
u 896 Arbitration
u 899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
u 950 Constitutionality of
State Statutes

V. ORIGIN (Place an “X” in One Box Only)
u 1 Original
Proceeding

u 2 Removed from
State Court

u 3

Remanded from
Appellate Court

u 4 Reinstated or
Reopened

u 5 Transferred from
Another District
(specify)

u 6 Multidistrict
Litigation

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

28 U.S.C. 1332

VI. CAUSE OF ACTION Brief description of cause:

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

u CHECK IF THIS IS A CLASS ACTION
VII. REQUESTED IN
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
IF ANY
JUDGE
DATE

CHECK YES only if demanded in complaint:
u Yes
u No
JURY DEMAND:

DEMAND $

200,000.00

DOCKET NUMBER

SIGNATURE OF ATTORNEY OF RECORD

/s/ John G. Cronin

04/27/2016
FOR OFFICE USE ONLY
RECEIPT #

AMOUNT

APPLYING IFP

JUDGE

MAG. JUDGE

JS 44 Reverse (Rev. 11/15)

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

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

(b)

(c)

Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
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 at the
time 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 land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

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 "X"
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 amendment
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 takes
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 diversity
cases.)

III.

Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section 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 below, is
sufficient 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 than
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 filing
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 or
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 1407.
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 jurisdictional
statutes 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 docket
numbers 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 1-2 Filed 04/27/16 Page 1 of 1
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
1. Title of case (name of first party on each side only) Michael Moran v. Danielle Rylan, et al

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 copyright 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 this
district please indicate the title and number of the first filed case in this court.

N/A
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?
§2403)
YES



NO

✔


YES



NO

✔


If so, is the U.S.A. or an officer, agent or employee of the U.S. a party?

(See 28 USC

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
A.

NO



If yes, in which division do all of the non-governmental parties reside?
Eastern Division

B.

✔


✔

Central Division



Western Division



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 John G. Cronin
ADDRESS Cronin Bisson & Zalinsky, P.C., -----, Manchester, New Hampshire 03104
TELEPHONE NO. ---(CategoryForm-201.wpd )

Case 1:16-cv-10787 Document 1-3 Filed 04/27/16 Page 1 of 1

Exhibit 1

Case 1:16-cv-10787 Document 1-4 Filed 04/27/16 Page 1 of 1

Case 1:16-cv-10787 Document 1-5 Filed 04/27/16 Page 1 of 1

Case 1:16-cv-10787 Document 1-6 Filed 04/27/16 Page 1 of 2

Case 1:16-cv-10787 Document 1-6 Filed 04/27/16 Page 2 of 2