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COPYRT,MOTREF

United States District Court

District of Massachusetts (Boston)

CIVIL DOCKET FOR CASE #: 1:19-cv-10203-IT

Larson v. Perry et al Date Filed: 01/30/2019

Assigned to: Judge Indira Talwani Jury Demand: Both

Cause: 17:101 Copyright Infringement Nature of Suit: 820

Copyright
Jurisdiction: Federal Question

Plaintiff
Sonya Larson represented by Andrew D. Epstein
Barker, Epstein & Loscocco
176 Federal Street, Suite 502
Boston, MA 02110
617-482-4900
Fax: 6179-426-5251
Email: [email protected]

LEAD ATTORNEY

ATTORNEY TO BE NOTICED

V.

Defendant
Dawn Dorland Perry represented by Howard M. Cooper
Todd & Weld
One Federal Street
27th Floor
Boston, MA 02110
617-720-2626
Fax: 617-227-5777
Email: [email protected]

TERMINATED: 04/15/2020

LEAD ATTORNEY

ATTORNEY TO BE
NOTICED

Elizabeth E. Olien
Todd & Weld
One Federal Street
27th Floor
Boston, MA 02110
617-670-8552
Email: [email protected]

TERMINATED: 04/15/2020

ATTORNEY TO BE NOTICED

Suzanne M. Elovecky
Partridge Snow & Hahn
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30 Federal Street
Boston, MA 02110
617-292-7900
Email: [email protected]

ATTORNEY TO BE NOTICED

Defendant
Cohen Business Law Group, PC represented by Mark William Shaughnessy
Boyle | Shaughnessy Law PC
695 Atlantic Avenue, 11th Flr.
Boston, MA 02111
617-451-2000
Fax: 617-451-5775
Email:
[email protected]

LEAD ATTORNEY

ATTORNEY TO BE
NOTICED

Matthew H. Greene
Boyle | Shaughnessy Law PC
695 Atlantic Avenue, 11th Flr.
Boston, MA 02111
617-451-2000 x.668
Fax: 617-451-5775
Email: [email protected]

LEAD ATTORNEY

ATTORNEY TO BE
NOTICED

Jeffrey W. Gordon
Riley Saafer Holmes & Cancila LLP
70 W. Madison Street
Chicago, IL 60602
(312) 471-8700
Fax: (312) 471-8701
Email: [email protected]

TERMINATED: 02/11/2020

ATTORNEY TO BE NOTICED

Defendant
Jeffrey A Cohen represented by Mark William Shaughnessy
Esquire
(See above for address)

LEAD ATTORNEY

ATTORNEY TO BE NOTICED

Matthew H. Greene
(See above for address)

LEAD ATTORNEY

ATTORNEY TO BE NOTICED

Jeffrey W. Gordon
(See above for address)

TERMINATED: 02/11/2020

ATTORNEY TO BE NOTICED

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Counter Claimant
Dawn Dorland Perry represented by Howard M. Cooper
(See above for address)

TERMINATED: 04/15/2020

LEAD ATTORNEY

ATTORNEY TO BE
NOTICED

Elizabeth E. Olien
(See above for address)

TERMINATED: 04/15/2020

ATTORNEY TO BE NOTICED

Suzanne M. Elovecky
(See above for address)

ATTORNEY TO BE NOTICED

V.

Counter Defendant
Sonya Larson represented by Andrew D. Epstein
(See above for address)

LEAD ATTORNEY

ATTORNEY TO BE NOTICED

Counter Claimant
Dawn Dorland Perry represented by Howard M. Cooper
(See above for address)

TERMINATED: 04/15/2020

LEAD ATTORNEY

ATTORNEY TO BE NOTICED

Elizabeth E. Olien
(See above for address)

TERMINATED: 04/15/2020

ATTORNEY TO BE NOTICED

Suzanne M. Elovecky
(See above for address)

ATTORNEY TO BE NOTICED

V.

Counter Defendant
Sonya Larson represented by Andrew D. Epstein
(See above for address)

LEAD ATTORNEY

ATTORNEY TO BE NOTICED

Date Filed # Docket Text

01/30/2019 1  COMPLAINT against Jeffrey A Cohen, Cohen Business Law Group, LLC, Dawn
Dorland Perry Filing fee: $ 400, receipt number 0101-7516921 (Fee Status: Filing Fee
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paid), filed by Sonya Larson. (Attachments: # 1 Exhibit Dorland's Factual Letter, # 2

Exhibit Dorland's Fsactual Letter Copyright Registration Information, # 3 Exhibit
Larson's Short Story, "The Kindest", # 4 Exhibit Larson's Fictional Letter, # 5 Exhibit
Letter from Larson's Attorney James Gregorio, July 17, 2018, # 6 Exhibit Boston Globe -
July 26, 2018 article, # 7 Exhibit Boston Globe - August 14, 2018 article, # 8 Exhibit
MGL ch. 93A - Thirty Day Demand Letters, # 9 Exhibit Cohen Law and Atty. Cohen's
response to MGL ch. 93A letter, # 10 Exhibit Larson's Attorney's response letter to Cohen
Law and Atty. Cohen, # 11 Civil Cover Sheet, # 12 Catagory Sheet)(Epstein, Andrew)
(Entered: 01/30/2019)
01/30/2019 2  REPORT on the filing of copyright case . (Epstein, Andrew) Modified on 1/31/2019 for
docket text.(Haran, Jodi). (Entered: 01/30/2019)
01/31/2019 3  ELECTRONIC NOTICE of Case Assignment. Judge Indira Talwani assigned to case. If
the trial Judge issues an Order of Reference of any matter in this case to a Magistrate
Judge, the matter will be transmitted to Magistrate Judge Marianne B. Bowler. (Finn,
Mary) (Entered: 01/31/2019)
01/31/2019 4  Summons Issued as to Jeffrey A Cohen, Cohen Business Law Group, PC, Dawn Dorland
Perry. Counsel receiving this notice electronically should download this summons,
complete one for each defendant and serve it in accordance with Fed.R.Civ.P. 4 and
LR 4.1. Summons will be mailed to plaintiff(s) not receiving notice electronically for
completion of service. (Jones, Sherry) (Entered: 01/31/2019)
02/01/2019 5  ELECTRONIC NOTICE issued requesting courtesy copy for 1 Complaint.

Counsel who filed the document are requested to submit a courtesy copy to the Clerk's
Office by February 6, 2019. These documents must be clearly marked as a Courtesy
Copy, contain appropriate (number/letter) tabs, reflect the document number
assigned by CM/ECF, and be placed in a 3-ring binder.

(DaSilva, Carolina) (Entered: 02/01/2019)

02/27/2019 6  NOTICE of Appearance by Mark William Shaughnessy on behalf of Jeffrey A Cohen,
Cohen Business Law Group, PC (Shaughnessy, Mark) (Entered: 02/27/2019)
02/27/2019 7  NOTICE of Appearance by Matthew H. Greene on behalf of Jeffrey A Cohen, Cohen
Business Law Group, PC (Greene, Matthew) (Entered: 02/27/2019)
02/27/2019 8  WAIVER OF SERVICE Returned Executed by Cohen Business Law Group, PC. Cohen
Business Law Group, PC waiver sent on 1/30/2019, answer due 4/1/2019. (Greene,
Matthew) (Entered: 02/27/2019)
02/27/2019 9  WAIVER OF SERVICE Returned Executed by Jeffrey A Cohen. Jeffrey A Cohen waiver
sent on 1/30/2019, answer due 4/1/2019. (Greene, Matthew) (Entered: 02/27/2019)
03/20/2019 10  NOTICE of Scheduling Conference. Scheduling Conference set for 4/22/2019 03:15 PM
in Courtroom 9 before Judge Indira Talwani. Counsel for the plaintiff(s) is responsible for
ensuring that all parties and/or their attorneys who have not filed an answer or appearance
with the court are notified of the date of the scheduling conference. (MacDonald, Gail)
(Entered: 03/20/2019)
04/01/2019 11  MOTION to Dismiss for Lack of Jurisdiction , MOTION to Dismiss ( Responses due by
4/15/2019) by Jeffrey A Cohen, Cohen Business Law Group, PC.(Greene, Matthew)
(Entered: 04/01/2019)
04/01/2019 12  MEMORANDUM in Support re 11 MOTION to Dismiss for Lack of Jurisdiction
MOTION to Dismiss filed by Jeffrey A Cohen, Cohen Business Law Group, PC.

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(Attachments: # 1 Exhibit A)(Greene, Matthew) (Entered: 04/01/2019)

04/09/2019 13  NOTICE of Appearance by Suzanne M. Elovecky on behalf of Dawn Dorland Perry
(Elovecky, Suzanne) (Entered: 04/09/2019)
04/09/2019 14  NOTICE of Appearance by Howard M. Cooper on behalf of Dawn Dorland Perry
(Cooper, Howard) (Entered: 04/09/2019)
04/11/2019 15  STIPULATION to Enlarge Time to Respond to Complaint by Dawn Dorland Perry.
(Elovecky, Suzanne) (Entered: 04/11/2019)
04/14/2019 16  Opposition re 11 MOTION to Dismiss for Lack of Jurisdiction MOTION to Dismiss filed
by Sonya Larson. (Attachments: # 1 Exhibit Copyright Certificate of Registration for The
Kindest, # 2 Exhibit Affidavit of Sonya Larson, # 3 Exhibit Dorland's "2015 Letter" or
"Factual Letter", # 4 Exhibit Larson's "Fictional Letter", # 5 Exhibit Cohen Law Firm
Letter of July 3, 2018, # 6 Exhibit Cohen Law Firm Letter of July 20, 2018)(Epstein,
Andrew) (Entered: 04/14/2019)
04/16/2019 17  Judge Indira Talwani: ELECTRONIC ORDER: The stipulation 15 is treated as an
assented-to motion to enlarge time to respond to complaint, and is ALLOWED in
accordance with the parties' agreement. Defendant Dawn Dorland Perry's time to respond
is extended to April 25, 2019, without waiver of any right to challenge the complaint on
any grounds. (Kinsella, Devan) (Entered: 04/16/2019)
04/18/2019 18  Assented to MOTION to Continue Scheduling Conference by Dawn Dorland Perry.
(Elovecky, Suzanne) (Entered: 04/18/2019)
04/18/2019 19  NOTICE of Appearance by Jeffrey W. Gordon on behalf of Jeffrey A Cohen, Cohen
Business Law Group, PC (Gordon, Jeffrey) (Entered: 04/18/2019)
04/19/2019 20  Judge Indira Talwani: ELECTRONIC ORDER entered granting 18 Motion to Continue.
Scheduling Conference set for 4/22/19 is RESET for 4/24/2019 03:15 PM in Courtroom 9
before Judge Indira Talwani. (MacDonald, Gail) (Entered: 04/19/2019)
04/19/2019 21  Assented to MOTION for Leave to File the correct exhibit for an exhibit erroneously
included in Plaintiff's Complaint and in her Opposition to the Motion to Dismiss of
Defendants, Cohen Business Law Group, PC, and Jeffrey A. Cohen by Sonya Larson.
(Attachments: # 1 Exhibit Exhibit to be substituted for erroneously filed exhibit)(Epstein,
Andrew) (Entered: 04/19/2019)
04/22/2019 22  NOTICE Resetting a Hearing. Scheduling Conference set for 4/24/19 is RESET for
5/31/2019 02:45 PM in Courtroom 9 before Judge Indira Talwani. (MacDonald, Gail)
(Entered: 04/22/2019)
04/23/2019 23  Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING Assented-to Motion
of Plaintiff for Leave to Substitute the Corrected Exhibit 21 . Counsel using the Electronic
Case Filing System should now file the document for which leave to file has been granted
in accordance with the CM/ECF Administrative Procedures. Counsel must include -
Leave to file granted on (date of order)- in the caption of the document. (Kinsella, Devan)
(Entered: 04/23/2019)
04/24/2019 24  NOTICE of Appearance by Elizabeth E. Olien on behalf of Dawn Dorland Perry (Olien,
Elizabeth) (Entered: 04/24/2019)
04/25/2019 25  MOTION to Dismiss Counts I, II, V, and VIII of the Complaint by Dawn Dorland Perry.
(Elovecky, Suzanne) (Entered: 04/25/2019)
04/25/2019 26  MEMORANDUM in Support re 25 MOTION to Dismiss Counts I, II, V, and VIII of the
Complaint filed by Dawn Dorland Perry. (Elovecky, Suzanne) (Entered: 04/25/2019)

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04/26/2019 27  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 25 MOTION to Dismiss

Counts I, II, V, and VIII of the Complaint by Suzanne M. Elovecky on behalf of Dawn
Dorland Perry. (Elovecky, Suzanne) (Entered: 04/26/2019)
04/26/2019 28  MOTION for Hearing re 25 MOTION to Dismiss Counts I, II, V, and VIII of the
Complaint Request by Dawn Dorland Perry.(Elovecky, Suzanne) (Entered: 04/26/2019)
05/09/2019 29  MEMORANDUM in Opposition re 25 MOTION to Dismiss Counts I, II, V, and VIII of
the Complaint filed by Sonya Larson. (Attachments: # 1 Exhibit Dorland's 2015 Letter, #
2 Exhibit The Audible/Brilliance print-on-demand CD variant, # 3 Exhibit The
Audible/Brilliance Audio mp3 and ASF variant, # 4 Exhibit The BBF version of The
Kindest, # 5 Exhibit Letters between the BBF and legal counsel)(Epstein, Andrew)
(Attachment 6 added on 5/10/2019 upon request from counsel: # 6 Exhibit D) (Kinsella,
Devan). (Entered: 05/09/2019)
05/09/2019 30  AFFIDAVIT of Sonya Larson in Opposition re 25 MOTION to Dismiss Counts I, II, V,
and VIII of the Complaint filed by Sonya Larson. (Attachments: # 1 Exhibit Larson
Agreement with Plympton, # 2 Exhibit Larson Agreement with American Short Fiction
(ASF), # 3 Exhibit Larson Agreement with the Boston Book Festival (BBF))(Epstein,
Andrew) (Documents replaced on 5/10/2019 to correct formatting) (Kinsella, Devan).
(Entered: 05/09/2019)
05/20/2019 31  MOTION for Leave to File a Reply Brief in Support of Dorland's Partial Motion to
Dismiss and Incorporated Motion to Strike Affidavit of Sonya Larson by Dawn Dorland
Perry. (Attachments: # 1 Exhibit A)(Elovecky, Suzanne) (Entered: 05/20/2019)
05/22/2019 32  Assented to MOTION to Continue Scheduling Conference to June 11, 2019 by Sonya
Larson.(Epstein, Andrew) (Entered: 05/22/2019)
05/28/2019 33  Judge Indira Talwani: ELECTRONIC ORDER entered granting 32 Motion to Continue.
Scheduling Conference set for 5/31/19 is RESET for 6/18/2019 11:15 AM in Courtroom
9 before Judge Indira Talwani. (MacDonald, Gail) (Entered: 05/28/2019)
06/03/2019 34  Opposition re 31 MOTION for Leave to File a Reply Brief in Support of Dorland's
Partial Motion to Dismiss and Incorporated Motion to Strike Affidavit of Sonya Larson
filed by Sonya Larson. (Epstein, Andrew) (Entered: 06/03/2019)
06/18/2019 35  CERTIFICATION pursuant to Local Rule 16.1 . (Elovecky, Suzanne) (Entered:
06/18/2019)
06/18/2019 36  STATEMENT OF COUNSEL of Defendants Pursuant to Local Rule 16.1 and Fed. R.
Civ. P. 26(f) by Jeffrey A Cohen, Cohen Business Law Group, PC, Dawn Dorland Perry.
(Elovecky, Suzanne) (Entered: 06/18/2019)
06/18/2019 37  CERTIFICATION pursuant to Local Rule 16.1 by Jeffrey A Cohen, Cohen Business Law
Group, PC.(Greene, Matthew) (Entered: 06/18/2019)
06/18/2019 38  STATEMENT OF COUNSEL of Andrew D. Epstein Pursuant to Local Rule 16.1 and
Fed. R. Civ. P. 26(f) by Sonya Larson. (Epstein, Andrew) (Entered: 06/18/2019)
06/18/2019 39  STATEMENT OF COUNSEL of Andrew D. Epstein Pursuant to Local Rule 16.1(d)(3)
by Sonya Larson. (Epstein, Andrew) (Entered: 06/18/2019)
06/18/2019 40  STATEMENT OF COUNSEL of Defendants Pursuant to Local Rule 16.1 and Fed. R.
Civ. P. 26(f) by Jeffrey A Cohen, Cohen Business Law Group, PC, Dawn Dorland Perry.
(Attachments: # 1 Exhibit A)(Elovecky, Suzanne) (Entered: 06/18/2019)
06/18/2019 43  Electronic Clerk's Notes for proceedings held before Judge Indira Talwani: Scheduling
Conference held on 6/18/2019. Case called. Court has colloquy with counsel. Counsel to

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confer with clients re: ADR and file a joint report in two weeks if agreed to a referral to
mediation. The Motion for Leave to File 31 denied without prejudice; counsel shall
confer and will be allowed to renew the motion after notice to the court. Court orders that
a joint, proposed Scheduling Order be filed when initial disclosures are due. Certifications
pursuant to Rule 16.1 to be resubmitted with live signatures. Initial Sched. Order to issue.
(Court Reporter: Cheryl Dahlstrom at [email protected].)(Attorneys present:
Epstein, Olien, Elovecky, Greene, Gordon,) (MacDonald, Gail) (Entered: 06/25/2019)
06/19/2019 41  STATEMENT OF COUNSEL of Andrew D. Epstein and Plaintiff, Sonya Larson under
Local Rule 16.1(d)(3) by Sonya Larson. (Epstein, Andrew) (Entered: 06/19/2019)
06/21/2019 42  STATUS REPORT by Sonya Larson. (Epstein, Andrew) (Entered: 06/21/2019)
06/25/2019 44  Judge Indira Talwani: ORDER entered. SCHEDULING ORDER:(MacDonald, Gail)
(Entered: 06/25/2019)
06/28/2019 45  MOTION for Leave to File Amended Complaint by Sonya Larson. (Attachments: # 1
Exhibit Proposed Amended Complaint with exhibits)(Epstein, Andrew) (Entered:
06/28/2019)
07/03/2019 46  CERTIFICATION pursuant to Local Rule 16.1 . (Greene, Matthew) (Entered:
07/03/2019)
07/03/2019 47  Opposition re 45 MOTION for Leave to File Amended Complaint filed by Jeffrey A
Cohen, Cohen Business Law Group, PC. (Gordon, Jeffrey) (Entered: 07/03/2019)
07/08/2019 48  JOINT STATEMENT of counsel Concerning Mediation Per Court's Request. (Elovecky,
Suzanne) (Entered: 07/08/2019)
07/12/2019 49  Opposition re 45 MOTION for Leave to File Amended Complaint filed by Dawn Dorland
Perry. (Elovecky, Suzanne) (Entered: 07/12/2019)
07/31/2019 50  Judge Indira Talwani: ORDER ALLOWING Motion for Leave to File Amended
Complaint 45 . Counsel using the Electronic Case Filing System should now file the
document for which leave to file has been granted in accordance with the CM/ECF
Administrative Procedures. Counsel must include - Leave to file granted on (date of
order)- in the caption of the document. Defendants shall file within 14 days of this Order
a notice that they intend to rest on their previously filed papers, file supplemental
memoranda not exceeding five pages, or file superseding motions to dismiss and
memoranda not exceeding twenty pages. See attached Order. Modified on 8/2/2019
(Kinsella, Devan). (Entered: 07/31/2019)
07/31/2019 51  NOTICE of Withdrawal of Appearance by Jeffrey W. Gordon (Gordon, Jeffrey) (Entered:
07/31/2019)
07/31/2019 52  AMENDED COMPLAINT against Jeffrey A Cohen, Cohen Business Law Group, PC,
Dawn Dorland Perry, filed by Sonya Larson. (Attachments: # 1 Exhibit Dorland's 2015
Factual Letter, # 2 Exhibit Copyright Registration information for Dorland's 2015 Factual
Letter, # 3 Exhibit Agreement by and between Larson and Plympton, Inc., # 4 Exhibit
Agreement by and between Larson and ASF, # 5 Exhibit Agreement by and between
Larson and the Boston Book Festival (BBF), # 6 Exhibit Copy of The Kindest, # 7
Exhibit Certificate of Copyright Registration for The Kindest, # 8 Exhibit Letter from
Atty. Cohen of Cohen Law to the BBF dated July 3, 2018, # 9 Exhibit Letter from Atty.
Gregorio to Atty. Cohen of Cohen Law dated July 17, 2018, # 10 Exhibit July 26, 2018,
Boston Globe article, # 11 Exhibit August 14, 2018, Boston Globe article, # 12 Exhibit
Letter from Cohen Law to Atty. Gregorio dated July 20, 2018, # 13 Exhibit Letter from
Cohen Law to Atty. Gregorio dated Sept. 6, 2018, # 14 Exhibit Larson's M.G.L. Chapter
93A thirty-day demand letter, # 15 Exhibit Response of Dorland, Cohen Law and Atty.

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Cohen to Larson's Chapter 93A letter, # 16 Exhibit Plaintiff's attorney's response to

Defendants' Chapter 93A letter)(Epstein, Andrew) (Entered: 07/31/2019)
08/08/2019 53  RESPONSE TO COURT ORDER by Dawn Dorland Perry Supplemental Memoranda
Pursuant to July 31, 2019 Order. (Olien, Elizabeth) (Entered: 08/08/2019)
08/08/2019 54  RESPONSE TO COURT ORDER by Jeffrey A Cohen, Cohen Business Law Group, PC
TO COURT'S JULY 31, 2019 ORDER. (Greene, Matthew) (Entered: 08/08/2019)
08/22/2019 55  MEMORANDUM in Opposition re 11 MOTION to Dismiss for Lack of Jurisdiction
MOTION to Dismiss filed by Sonya Larson. (Attachments: # 1 Exhibit Affidavit of
Plaintiff, Sonya Larson)(Epstein, Andrew) (Entered: 08/22/2019)
08/22/2019 56  MEMORANDUM in Opposition re 25 MOTION to Dismiss Counts I, II, V, and VIII of
the Complaint filed by Sonya Larson. (Attachments: # 1 Exhibit Affidavit of Plaintiff,
Sonya Larson)(Epstein, Andrew) (Entered: 08/22/2019)
02/14/2020 57  Judge Indira Talwani: ELECTRONIC ORDER: Setting Hearing on Defendants Cohen
Business Law Group, PC, and Jeffrey A. Cohen, Esq.'s Motion to Dismiss 11 pursuant to
Fed. R. Civ. P. 12(b)(1) for lack of subject matter jurisdiction for Wednesday, February
26, 2020, at 3:30 P.M. in Courtroom 9 before Judge Indira Talwani. Counsel should
be prepared to discuss whether a case or controversy exists as to Count VIII of the
Amended Complaint 52 , whether declaratory relief is proper under the specific
circumstances of this action, and whether, if Count VIII is dismissed, the court has subject
matter jurisdiction over the remainder of the action. (Kelly, Danielle) (Entered:
02/14/2020)
02/26/2020 58  Electronic Clerk's Notes for proceedings held before Judge Indira Talwani: Motion
Hearing held on 2/26/2020 re 11 MOTION to Dismiss for Lack of Jurisdiction MOTION
to Dismiss filed by Jeffrey A Cohen, Cohen Business Law Group, PC. Case called. Court
heard argument from counsel. Order to follow. (Court Reporter: Kristin Kelley at
[email protected].) (Attorneys present: Epstein, Olien, Elovecky, Greene)
(MacDonald, Gail) (Entered: 02/27/2020)
03/27/2020 59  Judge Indira Talwani: ORDER entered. MEMORANDUM AND ORDER. The Cohen
Defendants' Motion to Dismiss 11 is DENIED and Defendant Dorland's Motion to
Dismiss 25 is ALLOWED IN PART as to counts I and II, but otherwise DENIED.
Defendant Dorland's Motion for Hearing 28 is DENIED. IT IS SO ORDERED. (Kelly,
Danielle) (Entered: 03/27/2020)
03/27/2020 60  Judge Indira Talwani: ELECTRONIC ORDER Pursuant to the Scheduling Order 44 , by
April 10, 2020, the parties shall serve their Initial Disclosures required by Fed. R. Civ. P.
26(a)(1) and this court's Notice of Scheduling Conference and shall jointly file a proposed
scheduling order for further proceedings in this case. (Kelly, Danielle) (Entered:
03/27/2020)
04/07/2020 61  Joint MOTION for Extension of Time to April 24, 2020 to File , Joint Scheduling Order
and Responsive Pleadings and Exchange Initial Disclosures by Dawn Dorland Perry.
(Olien, Elizabeth) Modified on 4/8/2020: Corrected motion type to reflect proper
extension of time (Kelly, Danielle). (Entered: 04/07/2020)
04/08/2020 62  Judge Indira Talwani: ELECTRONIC ORDER entered ALLOWING 61 Joint Motion for
Extension of Time to April 24, 2020 to File , Joint Scheduling Order and Responsive
Pleadings and Exchange Initial Disclosures. (Kelly, Danielle) (Entered: 04/08/2020)
04/09/2020 63  MOTION for Reconsideration by Jeffrey A Cohen, Cohen Business Law Group, PC.
(Greene, Matthew)). Modified on 4/9/2020: Replace document due to being attached to
wrong entry. (Kelly, Danielle). (Entered: 04/09/2020)

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04/09/2020 64  MEMORANDUM in Support re 63 MOTION for Reconsideration filed by Jeffrey A

Cohen, Cohen Business Law Group, PC. (Greene, Matthew) Modified on 4/9/2020:
Replace document due to being attached to wrong entry. (Kelly, Danielle). (Entered:
04/09/2020)
04/10/2020 65  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 64 Memorandum in Support
of Motion, 63 MOTION for Reconsideration by Matthew H. Greene on behalf of Jeffrey
A Cohen, Cohen Business Law Group, PC. (Greene, Matthew) (Entered: 04/10/2020)
04/10/2020 66  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 64 Memorandum in Support
of Motion, 63 MOTION for Reconsideration , 65 Certificate of Consultation pursuant to
LR 7.1 Revised Certification by Matthew H. Greene on behalf of Jeffrey A Cohen, Cohen
Business Law Group, PC. (Greene, Matthew) (Entered: 04/10/2020)
04/13/2020 67  Judge Indira Talwani: Electronic Order DENYING Defendants Jeffrey A. Cohen and
Cohen Business Law Group, PC's Motion for Reconsideration 63 . Defendants move for
reconsideration of the court's Memorandum and Order 59 finding that the litigation
privilege defense put forth by Defendants presented questions of fact that could not be
resolved on the pleadings. Defendants argue that the court "reached its decision based
primarily on 58 Swansea Mall Drive" and that this case "should not be considered the
controlling law in this matter" and "the court's reliance on 58 Swansea Mall Drive was an
error of law. " Defs.' Mem. 3 64 (citing 58 Swansea Mall Drive, LLC v. Gator Swansea
Prop., LLC, No. CV 15-13538-RGS, 2016 WL 5946872 (D. Mass. Oct. 12, 2016)).

As an initial matter, the court did not reach its decision based primarily on 58 Swansea
Mall Drive. Indeed, Defendants are correct that 58 Swansea Mall Drive is not controlling;
as a decision of a district judge presiding over a diversity action, Judge Stearns' opinion is
only persuasive authority. Instead, the court is bound to apply Massachusetts law in the
manner pronounced by the Massachusetts Supreme Judicial Court (SJC). Andrew
Robinson Int'l, Inc. v. Hartford Fire Ins. Co., 547 F.3d 48, 51 (1st Cir. 2008)

Relevant to the discussion here, the SJC has ruled that statements by a party, counsel or
witness in the institution of, or during the course of, a judicial proceeding are absolutely
privileged provided such statements relate to that proceeding. Sriberg v. Raymond, 370
Mass. 105, 108 (1976) (collecting cases). The SJC has curtailed the reach of this privilege
where the communications at issue are made before litigation is actually initiated. In such
cases, a communication to a prospective defendant is only subject to the privilege where
it relates to a proceeding which is contemplated in good faith and which is under serious
consideration. Sriberg, 370 Mass. at 109. Defendants argue that the SJC reversed this
holding in Theran v. Rokoff. 413 Mass. 590 (1992). However, Theran did not discuss this
question and Defendants' argument that Theran abrogated Sriberg sub silentio is
unpersuasive. See also Meltzer v. Grant, 193 F. Supp. 2d 373, 380 (D. Mass. 2002)
(discussing that court's opinion on why Theran does not change the rule, stated in Sriberg,
that where communications are made preliminary to proposed proceedings, the
proceedings must be contemplated in good faith and be under serious consideration for
the privilege to apply). Accordingly, the court finds no clear error of law in its prior
determination that there is a question of fact as to whether Defendants' letter relates to
litigation contemplated in good faith and under serious consideration.

As an aside, Defendants' memorandum in support of their motion argues that Plaintiff's

proper remedy would be a complaint lodged with the State Bar of California. Defs.' Mem.
6-7 64 . There is a remarkable discordance with Defendants' position that they are
protected by Massachusetts' litigation privilege--a policy designed to ensure that attorneys
admitted to practice before courts in Massachusetts can effectively represent their clients

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in such courts--and their tacit admission that they are not licensed to engage in the
practice of law in Massachusetts.

Finally, Defendants argue that even if the court applies the rule from Sriberg, Larson has
not made sufficient allegations of bad faith in her complaint. This is a new argument that
was not raised on Defendants' Motion to Dismiss 11 and thus is not proper for
Defendants' motion for reconsideration. See Cochran v. Quest Software, Inc., 328 F.3d 1,
11 (1st Cir. 2003) ("It is generally accepted that a party may not, on a motion for
reconsideration, advance a new argument that could (and should) have been presented
prior to the district court's original ruling"). (Kelly, Danielle) Modified on 4/13/2020
(Kelly, Danielle). (Entered: 04/13/2020)
04/15/2020 68  NOTICE of Change of Address or Firm Name by Suzanne M. Elovecky (Elovecky,
Suzanne) (Entered: 04/15/2020)
04/15/2020 69  NOTICE of Withdrawal of Appearance by Elizabeth E. Olien of Howard Cooper (Olien,
Elizabeth) (Entered: 04/15/2020)
04/15/2020 70  DUPLICATE FILING. Please refer to 69 NOTICE of Withdrawal of Appearance by
Elizabeth E. Olien (Olien, Elizabeth) Modified on 4/15/2020 (Kelly, Danielle). (Entered:
04/15/2020)
04/15/2020 71  NOTICE of Withdrawal of Appearance by Elizabeth E. Olien (Olien, Elizabeth) (Entered:
04/15/2020)
04/24/2020 72  Defendants, Cohen Business Law Group, P.C. and Jeffrey A. Cohen, Esq.'s ANSWER to
52 Amended Complaint,,,,, by Jeffrey A Cohen, Cohen Business Law Group, PC.
(Greene, Matthew) (Entered: 04/24/2020)
04/24/2020 73  CORPORATE DISCLOSURE STATEMENT by Jeffrey A Cohen, Cohen Business Law
Group, PC. (Greene, Matthew) (Entered: 04/24/2020)
04/24/2020 74  Proposed JOINT STATEMENT of counsel regarding scheduling of further proceeding in
this case. (Epstein, Andrew) (Entered: 04/24/2020)
04/24/2020 75  ANSWER to 52 Amended Complaint,,,,, , COUNTERCLAIM against Sonya Larson by
Dawn Dorland Perry. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4
Exhibit D)(Elovecky, Suzanne) (Entered: 04/24/2020)
05/08/2020 76  Judge Indira Talwani: ORDER entered. SCHEDULING ORDER. See attached Order.
(Kelly, Danielle) (Entered: 05/08/2020)
05/15/2020 77  MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Counterclaim of Dawn
Dorland Perry by Sonya Larson.(Epstein, Andrew) (Entered: 05/15/2020)
05/15/2020 78  MEMORANDUM in Support re 77 MOTION TO DISMISS FOR FAILURE TO STATE
A CLAIM Counterclaim of Dawn Dorland Perry filed by Sonya Larson. (Attachments: #
1 Exhibit The Kindest - Brialliance Version, # 2 Exhibit The Kindest - Audible Version, #
3 Exhibit The Kindest - American Short Fiction Version, # 4 Exhibit The Kindest -
Version submitted to the Boston Book Festival, # 5 Exhibit The Kindest - Final Boston
Book Festival Version, # 6 Exhibit Defendant - Dawn Dorland Perry's Letter of July 2015,
# 7 Exhibit Compilation of Plaintiff, Sonya Larson's Letters from the five versions of The
Kindest, # 8 Affidavit Affidavit of Plaintiff, Sonya Larson, # 9 Affidavit Affidavit of
Andrew D. Epstein)(Epstein, Andrew). Modified on 5/15/2020: Replaced attachments 1
& 2 to remove blank pages (Kelly, Danielle). (Entered: 05/15/2020)
05/15/2020 79  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 77 MOTION TO DISMISS
FOR FAILURE TO STATE A CLAIM Counterclaim of Dawn Dorland Perry by Andrew
D. Epstein on behalf of Sonya Larson. (Epstein, Andrew) (Entered: 05/15/2020)
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05/27/2020 80  Assented to MOTION for Extension of Time to 06/19/2020 to File Response/Reply as to
77 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM Counterclaim of
Dawn Dorland Perry by Dawn Dorland Perry.(Elovecky, Suzanne) (Entered: 05/27/2020)
05/28/2020 81  Judge Indira Talwani: ELECTRONIC ORDER ALLOWING 80 Motion for Extension of
Time to File Response/Reply re 77 MOTION TO DISMISS FOR FAILURE TO STATE
A CLAIM Counterclaim of Dawn Dorland Perry. Responses due by June 19, 2020.
(Kelly, Danielle) (Entered: 05/28/2020)
06/19/2020 82  Opposition re 77 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM
Counterclaim of Dawn Dorland Perry filed by Dawn Dorland Perry. (Elovecky, Suzanne)
(Entered: 06/19/2020)
07/01/2020 83  MOTION for Judgment on the Pleadings by Jeffrey A Cohen, Cohen Business Law
Group, PC.(Greene, Matthew). Modified on 7/1/2020: Main document replaced to extract
Memorandum in support to properly file in separate entry. (Kelly, Danielle). (Entered:
07/01/2020)
07/01/2020 84  MEMORANDUM of Law in Support re 83 MOTION for Judgment on the Pleadings filed
by Jeffrey A Cohen, Cohen Business Law Group, PC. (Attachments: # 1 Exhibit A, # 2
Exhibit B, # 3 Exhibit C) (Kelly, Danielle) (Entered: 07/01/2020)
07/15/2020 85  MOTION for Leave to File Second Amended Complainr by Sonya Larson. (Attachments:
# 1 Exhibit Proposed Second Amended Complaint with exhibits)(Epstein, Andrew)
(Entered: 07/15/2020)
07/15/2020 86  MEMORANDUM in Opposition re 83 MOTION for Judgment on the Pleadings , 85
MOTION for Leave to File Second Amended Complainr filed by Sonya Larson.
(Attachments: # 1 Affidavit Affidavit of Andrew D. Epstein, # 2 Exhibit American Short
Fiction (ASF) Agreement with Plaintiff, # 3 Exhibit Boston Book Festival (BBF) letter
agreement with Plaintiff, # 4 Affidavit Affidavit of Plaintiff, Sonya Larson, # 5 Exhibit
Email chain letters between ASF and Defendant Dorland, # 6 Exhibit Demand letter of
July 3, 2018 from Cohen Business Law Group to the BBF, # 7 Exhibit Email chain letter
between ASF and Defendant Dorland, # 8 Exhibit June 18, 2018 letter from BBF to
Dorland, # 9 Exhibit August 13, 2018 letter from BBF to Dorland, # 10 Exhibit Copyright
Registration Information for Dorland's 2015 Letter showing June 10, 2018 registration
date, # 11 Exhibit Letter from Atty. James Gregorio to Cohen Business Law Group)
(Epstein, Andrew) (Entered: 07/15/2020)
07/15/2020 87  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 85 MOTION for Leave to
File Second Amended Complainr by Andrew D. Epstein on behalf of Sonya Larson filed
by on behalf of Sonya Larson. (Epstein, Andrew) (Entered: 07/15/2020)
07/29/2020 88  MEMORANDUM in Opposition re 85 MOTION for Leave to File Second Amended
Complainr filed by Jeffrey A Cohen, Cohen Business Law Group, PC. (Greene, Matthew)
(Entered: 07/29/2020)
07/29/2020 89  Opposition re 85 MOTION for Leave to File Second Amended Complaint filed by Dawn
Dorland Perry. (Elovecky, Suzanne) (Entered: 07/29/2020)
08/14/2020 90  Judge Indira Talwani: ELECTRONIC ORDER: After the court entered a Memorandum
and Order 59 denying Defendants Cohen Business Law Group, PC, and Jeffrey A.
Cohen's ("Cohen Defendants") Motion to Dismiss 11 and allowing defendant Dawn
Dorland Perry's ("Dorland") Motion to Dismiss 25 as to Counts I and II of Plaintiff Sonya
Larson's Amended Complaint 52 and otherwise denying the motion, the Cohen
Defendants filed a Motion for Judgment on the Pleadings 83 and Plaintiff filed a Motion
for Leave to File a Second Amended Complaint 85 .

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Larson's July 15, 2020 motion was filed prior to the August 31, 2020, deadline for filing a
motion to amend the complaint set forth under the court's Scheduling Order 76 .
Accordingly, Larson's motion is considered under Fed. R. Civ. P. 15's standard that the
court should freely give leave to amend when justice so requires. See Somascan, Inc. v.
Philips Med. Sys. Nederland, B.V., 714 F.3d 62, 64 (1st Cir. 2013).

In dismissing Larson's claims that alleged that Dorland intentionally interfered with
Larson's contracts with two publishers, the court found that Larson could not move
forward on these claims where there were no allegations that the publishers breached their
contractual obligations with Larson. Mem. and Order 16-17 59 . The court noted,
however, that in contrast to an intentional interference with contract claim, an intentional
interference with an advantageous business relationship claim "does not require Plaintiff
to prove a breach of contract, but only, inter alia, interference with a 'business relationship
or contemplated contract of economic benefit.'" Id. at 15 n. 5 (citing Am. Private Line
Servs., Inc. v. E. Microwave, Inc., 980 F.2d 33, 36 (1st Cir. 1992)). The proposed second
amended complaint makes three revisions to the operative complaint. First, it substitutes
previously dismissed Counts I and II with claims that Defendant Dorland intentionally
interfered with Plaintiff Larson's advantageous business relationships with the publishers.
See Proposed Am. Compl. ¶¶ 6176 [85-1]. Second, the proposed second amended
complaint revises Counts III and IV, which presently claim that the Cohen Defendants
intentionally interfered with Larson's contracts with the publishers, to allege that the
Cohen Defendants interfered with Plaintiff's advantageous business relationships with the
publishers. Third, the proposed second amended complaint adds factual allegations to
Larson's claim under Mass. Gen. Laws ch. 93A ("ch. 93A") that "clarify and elaborate on
the alleged impact that the Cohen Defendants had on trade and commerce." See Mot.
Leave File Second Am. Compl. 10 85 .

Dorland opposes Larson's motion arguing that the amendments are futile since the
proposed amendments "seek to add claims which are in both form and substance identical
to claims which this Court has already dismissed." Dorland's Opp'n 1-2 89 . But while the
facts underlying the proposed amended claims may be the same, the legal claims are
distinct insofar as the newly proposed claims do not require Plaintiff to establish a
contract with the publishers as an element of the claim, while the previous claims did
require that Plaintiff establish such a contract. Instead, the newly proposed claim requires
that Plaintiff prove, inter alia, interference with an "advantageous relationship."
Defendant Dorland acknowledges that Plaintiff has alleged as much. See Def.'s Opp'n 89
("Of course, here, Ms. Larson does allege an 'advantageous relationship' with both
entities... ") and the contracts previously entered into the record do not foreclose such an
advantageous relationship. Defendant Dorland cites cases that stand for the proposition
that a plaintiff cannot bring a claim of interference with an advantageous relationship on
top of a claim for interference with a contractual relationship where there are not
allegations that a defendant interfered with business relationships that were likely to yield
economic benefits beyond the existing contracts. However, here Ms. Larson makes the
required allegations to survive a Fed. R. Civ. P. 12(b)(6) motion; she plausibly alleges that
there were economic benefits that she could have yielded from her relationships with the
publishers, beyond what was provided for in the contracts in place, but for Dorland's
alleged intentional interference with those relationships. See Proposed Second Am.
Compl. ¶¶ 68, 76 [85-1]. The Cohen Defendants' opposition concerning the proposed
second amended complaint as to Counts III and IV fails for the same reason.

The Cohen Defendants also challenge Plaintiff's motion for leave to amend the complaint
insofar as it seeks to add factual allegations to buttress the ch. 93A claim brought against
the Cohen Defendants. Def.'s Opp'n 5-6 88 . But the Cohen Defendants' opposition
merely restates the argument submitted in its previously filed Motion for Judgment on the

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Pleadings 83 and does not explain why specific additions proposed by Plaintiff are futile
or otherwise improper under Fed. R. Civ. P. 15.

Accordingly, for the reasons set forth above, Plaintiff's Motion for Leave to File a Second
Amended Complaint 85 is ALLOWED. The Cohen Defendants' Motion for Judgment on
the Pleadings 83 will be DENIED without prejudice upon the filing of the Second
Amended Complaint. Defendants shall file their responses to the Second Amended
Complaint 85 within 21 days of the filing of that pleading. Dorland's Counterclaim 75 and
Larson's Motion to Dismiss the Counterclaim 77 remain pending before the court.

Counsel using the Electronic Case Filing System should now file the document for which
leave to file has been granted in accordance with the CM/ECF Administrative Procedures.
Counsel must include - Leave to file granted on (date of order)- in the caption of the
document. (Kelly, Danielle) (Entered: 08/14/2020)
08/16/2020 91  AMENDED COMPLAINT Second Amended Complaint filed with leave granted on
August 14, 2020 against Dawn Dorland Perry, Jeffrey A Cohen, Cohen Business Law
Group, PC, filed by Sonya Larson. (Attachments: # 1 Exhibit Dorland's 2015 Factual
Letter, # 2 Exhibit Copyright registration information for Dorland's 2015 Factual Letter, #
3 Exhibit Agreement by and between Larson and Plympton, # 4 Exhibit Agreement by
and between Larson and ASF, # 5 Exhibit Agreement by and between Larson and the
BBF, # 6 Exhibit Copy of The Kindest, # 7 Exhibit Certificate of Copyright Registration
for The Kindest, # 8 Exhibit Letter from Attorney Cohen of Cohen Law to the BBF dated
July 3, 2018, # 9 Exhibit Letter from Attorney Gregorio to Attorney Cohen of Cohen Law
dated July 17, 2018, # 10 Exhibit July 26, 2018 - Boston Globe article, # 11 Exhibit
August 14, 2018 - Boston Globe article, # 12 Exhibit Letter from Cohen Law to Attorney
Gregorio dated July 20, 2018, # 13 Exhibit Letter from Cohen Law to Attorney Gregorio
dated September 6, 2018, # 14 Exhibit Larson's M.G.L. Chapter 93A thirty-day demand
letter, # 15 Exhibit Response of Dorland, Cohen Law and Attorney Cohen to Larson's
Chapter 93A letter, # 16 Exhibit Plaintiff's attorney's response to Defendant's Chapter
93A letter)(Epstein, Andrew) (Entered: 08/16/2020)
08/17/2020 92  Judge Indira Talwani: ELECTRONIC ORDER: In light of Plaintiff filing her Second
Amended Complaint 91 , the Cohen Defendants' Motion for Judgment on the Pleadings
83 is DENIED without prejudice. See Electronic Order 90 . (Kelly, Danielle) (Entered:
08/17/2020)
09/02/2020 93  Joint MOTION of the Parties to Extend Discovery and Subsequent Deadlines by Jeffrey
A Cohen, Cohen Business Law Group, PC.(Greene, Matthew) Modified on 9/3/2020:
Corrected docket text (Kelly, Danielle). (Entered: 09/02/2020)
09/03/2020 94  Judge Indira Talwani: ELECTRONIC ORDER ALLOWING 93 Joint Motion of the
Parties to Extend Discovery and Subsequent Deadlines.

Fact Discovery to be completed by 2/28/2021. Dispositive Motions due by 6/15/2021.

Status Conference set for 3/1/2021 02:30 PM before Judge Indira Talwani. (Kelly,
Danielle) (Entered: 09/03/2020)
09/04/2020 95  Defendant's, Cohen Business Law Group. PC and Jeffrey A. Cohen, Esquire ANSWER to
91 Amended Complaint,,,,, by Jeffrey A Cohen, Cohen Business Law Group, PC.
(Greene, Matthew) (Entered: 09/04/2020)
09/08/2020 96  ANSWER to 91 Amended Complaint,,,,, , COUNTERCLAIM against Sonya Larson by
Dawn Dorland Perry. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4
Exhibit D)(Elovecky, Suzanne) (Entered: 09/08/2020)
01/27/2021 97  MOTION for Protective Order and to extend scheduling order deadlines by Sonya
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Larson. (Attachments: # 1 Affidavit Affidavit of Plaintiff Sonya Larson)(Epstein,

Andrew) (Entered: 01/27/2021)
01/27/2021 98  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 97 MOTION for Protective
Order and to extend scheduling order deadlines by Andrew D. Epstein on behalf of Sonya
Larson. (Epstein, Andrew) (Entered: 01/27/2021)
02/02/2021 99  Judge Indira Talwani: ORDER entered. Memorandum and Order GRANTING IN PART
and DENYING IN PART Sonya Larson's Motion to Dismiss Counterclaims 77 . Please
see attached. (Kelly, Danielle) (Entered: 02/02/2021)
02/02/2021 100  Judge Indira Talwani: ELECTRONIC ORDER entered denying 97 Motion for Protective
Order and to extend scheduling order deadlines as moot. (Kelly, Danielle) (Entered:
02/02/2021)
02/17/2021 101  Joint MOTION for Extension of Time to April 14, 2021 to Complete Discovery by Sonya
Larson.(Epstein, Andrew) (Entered: 02/17/2021)
02/17/2021 102  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 101 Joint MOTION for
Extension of Time to April 14, 2021 to Complete Discovery by Andrew D. Epstein on
behalf of Sonya Larson. (Epstein, Andrew) (Entered: 02/17/2021)
02/18/2021 103  Judge Indira Talwani: Electronic order: granting Joint Motion of the Parties to Extend
Scheduling Order Deadlines 101 . The requested deadlines are adopted by the court,
except as to the trial date. The March 1, 2021 status conference is cancelled and will be
reset by the clerk. (Kelly, Danielle) (Entered: 02/18/2021)
02/18/2021 104  ANSWER to Counterclaim by Sonya Larson.(Epstein, Andrew) (Entered: 02/18/2021)
02/22/2021 105  ELECTRONIC NOTICE of Hearing. Telephonic Status Conference set for 4/20/2021
03:15 PM in Remote Proceeding : Boston before Judge Indira Talwani. Teleconference #:
(888)-808-6929 access code: 8523158. (MacDonald, Gail) (Entered: 02/22/2021)
03/15/2021 106  MOTION to Compel The Production of Documents By Sonya Larson by Dawn Dorland
Perry.(Elovecky, Suzanne) (Entered: 03/15/2021)
03/15/2021 107  MEMORANDUM in Support re 106 MOTION to Compel The Production of Documents
By Sonya Larson filed by Dawn Dorland Perry. (Attachments: # 1 Exhibit A, # 2 Exhibit
B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H,
# 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit
N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20
Exhibit T)(Elovecky, Suzanne) Modified on 3/16/2021: properly labeled exhibits (Kelly,
Danielle). (Attachment 3 replaced on 3/16/2021). Modified on 3/16/2021: Replaced
Exhibit C with corrected version (Kelly, Danielle). (Entered: 03/15/2021)
03/29/2021 108  MEMORANDUM in Opposition re 106 MOTION to Compel The Production of
Documents By Sonya Larson filed by Sonya Larson. (Attachments: # 1 Affidavit Affidavit
of Plaintiff Sonya Larson, # 2 Exhibit July 3, 2018 Letter from Cohen Law to the BBF, #
3 Exhibit Email from NY Times reporter Robert Kolker)(Epstein, Andrew) (Entered:
03/29/2021)
04/01/2021 109  ELECTRONIC NOTICE of Hearing. Case Management Conference set for 4/5/2021
03:30 PM in Remote Proceeding : Boston before Judge Indira Talwani.

This hearing will be conducted by video conference. Counsel of record will receive a
video conference invite at the email registered in CM/ECF. If you have technical or
compatibility issues with the technology, please notify the session's courtroom deputy as
soon as possible.

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Access to the hearing will be made available to the media and public. In order to gain
access to the hearing, you must sign up at the following address:
https://forms.mad.uscourts.gov/courtlist.html.

For questions regarding access to hearings, you may refer to the Court's general orders
and public notices available on www.mad.uscourts.gov or contact
[email protected].

(MacDonald, Gail) (Entered: 04/01/2021)

04/05/2021 110  MOTION to Compel by Sonya Larson. (Attachments: # 1 Exhibit Dorland's Answers to
Interrogatories, # 2 Affidavit Affidavit of Andrew D. Epstein, # 3 Exhibit Dorland's 2015
Facebook Letter, # 4 Affidavit Affidavit of Sonya Larson, # 5 Exhibit Dorland's response
to document request)(Epstein, Andrew) Modified on 4/5/2021, to remove "Emergency"
from text per order of the court (MacDonald, Gail). (Entered: 04/05/2021)
04/05/2021 111  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 110 Emergency MOTION to
Compel by Andrew D. Epstein on behalf of Sonya Larson. (Epstein, Andrew) (Entered:
04/05/2021)
04/05/2021 112  MOTION for Leave to File A Reply Brief In Further Support Of Her Motion To Compel
by Dawn Dorland Perry. (Attachments: # 1 Reply Brief with Exhibits)(Elovecky,
Suzanne) (Entered: 04/05/2021)
04/05/2021 113  Judge Indira Talwani: ELECTRONIC ORDER entered. REFERRING CASE to
Magistrate Judge Marianne B. Bowler Referred for: Events Only (e). Motions referred:
106 MOTION to Compel The Production of Documents By Sonya Larson, 112 MOTION
for Leave to File A Reply Brief In Further Support Of Her Motion To Compel. (Kelly,
Danielle) Motions referred to Marianne B. Bowler. (Entered: 04/05/2021)
04/05/2021 114  Electronic Clerk's Notes for proceedings held before Judge Indira Talwani: Case
Management Conference held on 4/5/2021. Case called. Court had colloquy with counsel.
The MOTION for Leave to File A Reply Brief [112} and 110 MOTION to Compel to be
referred to the magistrate judge; the motion to compel shall have the word "emergency"
removed. All dates stayed until ruling on referred motions is entered; one week after
ruling is entered counsel shall file a joint proposed schedule for the remaining depositions
and shall include any request for ADR. Deft. Perry may file a motion to compel 3rd party
in 2 weeks. (Court Reporter: Robert Paschal at [email protected].) (Attorneys
present: Andrew D. Epstein, Suzanne M. Elovecky, Matthew H. Greene) (MacDonald,
Gail) (Entered: 04/05/2021)
04/05/2021 115  Judge Indira Talwani: ELECTRONIC ORDER entered. REFERRING MOTION 112
MOTION for Leave to File A Reply Brief In Further Support Of Her Motion To Compel
filed by Dawn Dorland Perry, 110 MOTION to Compel filed by Sonya Larson to
Magistrate Judge Bowler. (MacDonald, Gail) Motions referred to Marianne B. Bowler.
Modified on 4/5/2021, to remove the word "emergency" from 110. (MacDonald, Gail).
(Entered: 04/05/2021)
04/06/2021 116  Magistrate Judge Marianne B. Bowler: ELECTRONIC ORDER entered granting 112
Motion for Leave to File Document. Counsel using the Electronic Case Filing System
should now file the document for which leave to file has been granted in accordance with
the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on
(date of order)- in the caption of the document. (Bowler, Marianne) (Entered: 04/06/2021)
04/06/2021 117  ELECTRONIC NOTICE Setting Hearing on Motion 110 MOTION to Compel , 106
MOTION to Compel The Production of Documents By Sonya Larson : Motion Hearing
set for 4/29/2021 11:00 AM before Magistrate Judge Marianne B. Bowler. ALL

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COUNSEL ARE DIRECTED TO APPEAR BY PHONE by calling 888-675-2535

approximately five minutes prior to the conference, using Access Code 6641794. If, for
some reason, the call is disconnected, dial back in. NOTE that yours may not be the first
case called, but please remain on the line until it is.(Putnam, Harold) (Entered:
04/06/2021)
04/06/2021 118  BRIEF by Dawn Dorland Perry to 106 MOTION to Compel The Production of
Documents By Sonya Larson - Leave to file granted on 4/6/21. (Attachments: # 1 Exhibit
A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Elovecky, Suzanne) (Entered: 04/06/2021)
04/15/2021 119  ELECTRONIC NOTICE Canceling Hearing: The Status conference set for 4/20/21 is
continued. Date to be reset by clerk after parties file joint proposed schedule per 114.
(Kelly, Danielle) (Entered: 04/15/2021)
04/19/2021 120  Opposition re 110 MOTION to Compel Further Answers to Interrogatories and to
Produce All Requested Documents filed by Dawn Dorland Perry. (Attachments: # 1
Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7
Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, #
13 Exhibit M)(Elovecky, Suzanne) (Attachment 9 replaced on 4/20/2021 - corrected page
formatting) (Kelly, Danielle). (Entered: 04/19/2021)
04/19/2021 121  DECLARATION re 120 Opposition to Motion, by Dawn Dorland Perry. (Elovecky,
Suzanne) (Entered: 04/19/2021)
04/19/2021 122  Letter/request (non-motion) from Dawn Dorland Perry For Enlargement of Time.
(Elovecky, Suzanne) (Entered: 04/19/2021)
04/20/2021 123  Judge Indira Talwani: ELECTRONIC ORDER granting Defendant and Plaintiff-in-
Counterclaim Dawn Dorland Perry's Request for Enlargement of Time motion 122 .
Perry's time to file motions to compel responses to third-party subpoenas is extended to
May 3, 2021. (Kelly, Danielle) (Entered: 04/20/2021)
04/28/2021 124  MOTION for Leave to File by Sonya Larson. (Attachments: # 1 Exhibit Proposed Reply
and further Opposition, # 2 Exhibit Dorland 2015 Facebook Letter, # 3 Exhibit Dorland
pursuing legal remedies, # 4 Exhibit Dorland's acceptable remedies, # 5 Exhibit Cohen
Law letter of July 3, 2018, # 6 Exhibit Notice to Larson that BBF canceled her story, # 7
Exhibit Cohen Law letter of Sept. 6, 2018, # 8 Exhibit Cohen Law letter of October 26,
2018, # 9 Exhibit Dorland's request to accept service of process, # 10 Exhibit Email to
1C/1S sponsor that program was canceled, # 11 Exhibit Email to Larson canceling 1
City/1 story project, # 12 Exhibit Dorland letter to GrubStreet, # 13 Exhibit Dorland letter
to American Short Fiction, # 14 Exhibit Letter to Bread Loaf Writing Center, # 15 Exhibit
Facebook page showing redactions by Dorland, # 16 Exhibit Dorland appearing in public
supporting kidney donatios, # 17 Exhibit Email to Boston Book Festival regarding
plagiarism, # 18 Exhibit Boston Globe articles about Larson's story and the Boston Book
Festival, # 19 Exhibit Dorland's letter seeking negative publicity about Larson, # 20
Affidavit Larson Affidavit, # 21 Affidavit Epstein Affidavit)(Epstein, Andrew) (Entered:
04/28/2021)
04/28/2021 125  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 124 MOTION for Leave to
File Reply and Further Opposition by Andrew D. Epstein on behalf of Sonya Larson.
(Epstein, Andrew) (Entered: 04/28/2021)
04/28/2021 126  ELECTRONIC NOTICE Canceling Hearing 4/29/2021 motion hearing. Matter will be
rescheduled. (Putnam, Harold) (Entered: 04/28/2021)
04/29/2021 127  Magistrate Judge Marianne B. Bowler: ELECTRONIC ORDER entered granting 124
Motion for Leave to File Document. Counsel using the Electronic Case Filing System
should now file the document for which leave to file has been granted in accordance with
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the CM/ECF Administrative Procedures. Counsel must include - Leave to file granted on
(date of order)- in the caption of the document. (Bowler, Marianne) (Entered: 04/29/2021)
04/29/2021 128  REPLY to Response to 106 MOTION to Compel The Production of Documents By Sonya
Larson, 110 MOTION to Compel filed by Sonya Larson. (Attachments: # 1 Exhibit
Doland's 2015 Facebook Letter, # 2 Exhibit Dorland statement she is pursing legal
remedies, # 3 Exhibit Dorland's acceptable remedies, # 4 Exhibit Cohen Law letter of July
3, 2018, # 5 Exhibit Notice to Larson that the BBF canceled her story, # 6 Exhibit Cohen
Law letter of Sept. 6, 2018, # 7 Exhibit Cohen Law letter of Oct. 26, 2018, # 8 Exhibit
Dorland' request to accept service of process, # 9 Exhibit Email to One City/One Story
sponsor that program was canceled, # 10 Exhibit Email to Larson canceling One City/One
Story project, # 11 Exhibit Dorland Letter to GrubStreet, # 12 Exhibit Dorland Letter to
Am. Short Fiction as to acceptable punishments, # 13 Exhibit Dorland Letter to Bread
Loaf Writing Conference, # 14 Exhibit Dorland's Facebook page showing redactions, #
15 Exhibit Dorland appearing in public supporting kidney donations, # 16 Exhibit
Dorland letter to Boston Book Festival regarding plagiarism claim, # 17 Exhibit Boston
Globe Articles, # 18 Exhibit Dorland seeking further negative publicity about Larson, #
19 Affidavit Sonya Larson Affidavit, # 20 Affidavit Epstein Affidavit)(Epstein, Andrew)
(Entered: 04/29/2021)
04/30/2021 129  Assented to MOTION for Protective Order by Dawn Dorland Perry. (Attachments: # 1
Stipulated Protective Order)(Elovecky, Suzanne) (Entered: 04/30/2021)
05/03/2021 130  Judge Indira Talwani: ELECTRONIC ORDER denying without prejudice Assented-to
Motion for Protective Order 129 . See Local Rule 7.2(c), (d). Because the public has a
"presumptive" right of access to judicial documents, United States v. Kravetz, 706 F.3d
47, 59 (1st Cir. 2013) (citing Siedle v. Putnam Invs., Inc., 147 F.3d 7, 10 (1st Cir. 1998)),
"'only the most compelling reasons can justify non-disclosure of judicial records that
come within the scope of the common-law right of access.'" Id. (quoting In re Providence
Journal Co., 293 F.3d 1, 10 (1st Cir. 2002)). The burden is thus on the impoundment-
seeking party to show that impoundment will not violate the public's presumptive right of
access. See Foltz v. State Farm Mut. Auto. Ins. Co., 331 F.3d 1122, 1130 (9th Cir. 2003)
("A party asserting good cause bears the burden, for each particular document it seeks to
protect, of showing that specific prejudice or harm will result if no protective order is
granted") (citing Phillips v. Gen. Motors Corp., 307 F.3d 1206, 1212 (9th Cir. 2002));
Miller v. City of Bos., 549 F. Supp. 2d 140, 141 (D. Mass. 2008) ("The proponent of a
Protective Order bears the burden of establishing 'good cause' for its continuation"
(internal citation omitted)). For that reason, when seeking to file under seal any
confidential information, a party must show this court good cause for the impoundment.
See Kravetz, 706 F.3d at 60. Specifically, the party seeking impoundment must make "'a
particular factual demonstration of potential harm, not... conclusory statements,'" id.
(quoting Fed. Trade Comm'n v. Standard Fin. Mgmt. Corp., 830 F.2d 404, 412 (1st Cir.
1987)), as to why a document should be sealed. See Anderson v. Cryovac, Inc., 805 F.2d
1, 7 (1st Cir. 1986) ("A finding of good cause must be based on a particular factual
demonstration of potential harm, not on conclusory statements." (citations omitted)). This
court "will not enter blanket order" for impoundment. L.R. 7.2(d). (Kelly, Danielle)
(Entered: 05/03/2021)
05/08/2021 131  ELECTRONIC NOTICE Resetting Hearing on Motion 110 MOTION to Compel , 106
MOTION to Compel The Production of Documents By Sonya Larson : Motion Hearing
reset for 5/14/2021 11:00 AM before Magistrate Judge Marianne B. Bowler. ALL
COUNSEL ARE DIRECTED TO APPEAR BY PHONE by calling 888-675-2535
approximately five minutes prior to the conference, using Access Code 6641794. If, for
some reason, the call is disconnected, dial back in. NOTE that yours may not be the first
case called, but please remain on the line until it is.(Putnam, Harold) (Entered:
05/08/2021)
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05/10/2021 132  ELECTRONIC NOTICE Resetting Hearing on Motion 110 MOTION to Compel , 106
MOTION to Compel The Production of Documents By Sonya Larson : Motion Hearing
reset for 5/14/2021 02:00 PM before Magistrate Judge Marianne B. Bowler. ***THIS IS
A TIME CHANGE ONLY*** ALL COUNSEL ARE DIRECTED TO APPEAR BY
PHONE by calling 888-675-2535 approximately five minutes prior to the conference,
using Access Code 6641794. If, for some reason, the call is disconnected, dial back in.
NOTE that yours may not be the first case called, but please remain on the line until it is.
(Putnam, Harold) (Entered: 05/10/2021)
05/14/2021 133  Electronic Clerk's Notes for proceedings held before Magistrate Judge Marianne B.
Bowler: Motion Hearing by telephone held on 5/14/2021 re 106 MOTION to Compel The
Production of Documents By Sonya Larson filed by Dawn Dorland Perry, 110 MOTION
to Compel filed by Sonya Larson. The court continues argument until 5/17/21 at 3:15 PM.
(Court Reporter: Lee Marzilli at [email protected].) (Russo, Noreen) (Entered:
05/14/2021)
05/14/2021 134  ELECTRONIC NOTICE Setting Hearing on Motion 110 MOTION to Compel :
Continued Motion Hearing by telephone set for 5/17/2021 03:15 PM in Remote
Proceeding : Boston before Magistrate Judge Marianne B. Bowler. ALL COUNSEL ARE
DIRECTED TO APPEAR BY PHONE by calling 888-675-2535 approximately five
minutes prior to the conference, using Access Code 6641794. If, for some reason, the call
is disconnected, dial back in. NOTE that yours may not be the first case called, but please
remain on the line until it is.(Russo, Noreen) (Entered: 05/14/2021)
05/17/2021 136  Electronic Clerk's Notes for proceedings held before Magistrate Judge Marianne B.
Bowler: Motion Hearing held on 5/17/2021 re 106 MOTION to Compel The Production
of Documents By Sonya Larson filed by Dawn Dorland Perry, 110 MOTION to Compel
filed by Sonya Larson. Court hears argument, makes rulings as noted in Docket Entry
#135. (Court Reporter: Kristin Kelley at [email protected].)(Attorneys present:
Epstein, Elovecky) (Putnam, Harold) (Entered: 05/19/2021)
05/18/2021 135  Magistrate Judge Marianne B. Bowler: ELECTRONIC ORDER entered granting in part
and denying in part 106 Motion to Compel and granting in part and denying in part 110
Motion to Compel, in accordance with rulings made on the record in open court at
hearings on May 14 and 17, 2021. Requests for attorney's fees and sanctions are DENIED
without prejudice to be renewed at the conclusion of the case. (Bowler, Marianne)
(Entered: 05/18/2021)
06/01/2021 137  Transcript of Motion Hearing held on May 14, 2021, before Magistrate Judge Marianne
B. Bowler. The Transcript may be purchased through the Court Reporter, viewed at the
public terminal, or viewed through PACER after it is released. Court Reporter Name and
Contact Information: Lee Marzilli at [email protected]. Redaction Request due
6/22/2021. Redacted Transcript Deadline set for 7/2/2021. Release of Transcript
Restriction set for 8/30/2021. (Coppola, Katelyn) (Entered: 06/03/2021)
06/01/2021 138  NOTICE is hereby given that an official transcript of a proceeding has been filed by the
court reporter in the above-captioned matter. Counsel are referred to the Court's
Transcript Redaction Policy, available on the court website at
http://www.mad.uscourts.gov/attorneys/general-info.htm (Coppola, Katelyn) (Entered:
06/03/2021)
06/14/2021 139  Joint MOTION for Extension of Time to July 5, 2021 to complete fact discovery and
submit a statement concerning the parties view on mediation by Dawn Dorland Perry.
(Elovecky, Suzanne) (Entered: 06/14/2021)
06/14/2021 140  Judge Indira Talwani: ELECTRONIC ORDER granting Joint Motion for Extension of
Time 139 . The time for counsel to submit a proposed deposition schedule and updated
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statement concerning ADR is extended to July 5, 2021. (Kelly, Danielle) (Entered:

06/14/2021)
06/17/2021 141  Transcript of Motion Hearing held on May 17, 2021, before Magistrate Judge Marianne
B. Bowler. The Transcript may be purchased through the Court Reporter, viewed at the
public terminal, or viewed through PACER after it is released. Court Reporter Name and
Contact Information: Kristin Kelley at [email protected]. Redaction Request due
7/8/2021. Redacted Transcript Deadline set for 7/19/2021. Release of Transcript
Restriction set for 9/15/2021. (Coppola, Katelyn) (Entered: 06/21/2021)
06/17/2021 142  NOTICE is hereby given that an official transcript of a proceeding has been filed by the
court reporter in the above-captioned matter. Counsel are referred to the Court's
Transcript Redaction Policy, available on the court website at
http://www.mad.uscourts.gov/attorneys/general-info.htm (Coppola, Katelyn) (Entered:
06/21/2021)
07/06/2021 143  Joint MOTION for Extension of Time to September 30, 2021 to Complete depositions
and fact discovery by Sonya Larson.(Epstein, Andrew) (Entered: 07/06/2021)
07/06/2021 144  CERTIFICATE OF CONSULTATION pursuant to LR 7.1 re 143 Joint MOTION for
Extension of Time to September 30, 2021 to Complete depositions and fact discovery by
Andrew D. Epstein on behalf of Sonya Larson. (Epstein, Andrew) (Entered: 07/06/2021)
07/07/2021 145  Judge Indira Talwani: ELECTRONIC ORDER granting Request for Revised Scheduling
Order Deadlines 143 . All fact discovery shall be completed by September 30, 2021.
(Kelly, Danielle) (Entered: 07/07/2021)
07/07/2021 146  Case no longer referred to Magistrate Judge Marianne B. Bowler. (MacDonald, Gail)
(Entered: 07/07/2021)
08/12/2021 147  ELECTRONIC NOTICE of Hearing.

This hearing will be conducted by video conference. Counsel of record will receive a
video conference invite at the email registered in CM/ECF. If you have technical or
compatibility issues with the technology, please notify the session's courtroom deputy as
soon as possible.

Access to the hearing will be made available to the media and public. In order to gain
access to the hearing, you must sign up at the following address:
https://forms.mad.uscourts.gov/courtlist.html.

For questions regarding access to hearings, you may refer to the Court's general orders
and public notices available on www.mad.uscourts.gov or contact
[email protected].

Status Conference set for 10/1/2021 02:30 PM in Remote Proceeding : Boston before
Judge Indira Talwani. (MacDonald, Gail) (Entered: 08/12/2021)
08/26/2021 148  NOTICE Resetting a Hearing. Status Conference set for 10/1/2021 is RESET for
10/12/2021 02:45 PM in Remote Proceeding : Boston before Judge Indira Talwani.

This hearing will be conducted by video conference. Counsel of record will receive a
video conference invite at the email registered in CM/ECF. If you have technical or
compatibility issues with the technology, please notify the session's courtroom deputy as
soon as possible.

Access to the hearing will be made available to the media and public. In order to gain
access to the hearing, you must sign up at the following address:
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https://forms.mad.uscourts.gov/courtlist.html.

For questions regarding access to hearings, you may refer to the Court's general orders
and public notices available on www.mad.uscourts.gov or contact
[email protected].

(MacDonald, Gail) (Entered: 08/26/2021)

09/24/2021 149 MOTION to Compel Plaintiff's Supplemental Answers to Interrogatories by Jeffrey A
Cohen, Cohen Business Law Group, PC. (Attachments: # REFER TO 150 Supplement
Memorandum of Law In Support)(Greene, Matthew) Modified on 9/27/2021: Removed
memorandum in support to properly file in separate entry; Corrected filing parties to
reflect both defendants (Kelly, Danielle). (Entered: 09/24/2021)
09/24/2021 150 MEMORANDUM of Law in Support re 149 MOTION to Compel Plaintiff's
Supplemental Answers to Interrogatories filed by Jeffrey A Cohen, Cohen Business Law
Group, PC. (Kelly, Danielle) (Entered: 09/27/2021)
10/04/2021 151 Opposition re 149 MOTION to Compel Plaintiff's Supplemental Answers to
Interrogatories filed by Sonya Larson. (Attachments: # 1 Exhibit Certificate of Copyright
Registration effective 6-10-2018, # 2 Exhibit Email chain showing Dorland read The
Kindest on June 2 or 3, 2018, # 3 Exhibit Demand letter from Atty Cohen to the Boston
Book Festival dated July 3, 2018)(Epstein, Andrew) (Entered: 10/04/2021)

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