MIIA's certification of conference, June 12, 2015

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UNITED STATES DISTRICT COURT 
DISTRICT OF MASSACHUSETTS 
JAMES ROSENCRANZ, ) 
Plaintiff, ) 
) 
v. ) 1:14-cv-13050-JGD 
) 
JAMES A. FREEMAN, ) 
Defendant. ) 
LOCAL RULE 7.1 CERTIFICATION OF THE NON-PARTY, 
MIIA PROPERTY AND CASUALTY GROUP, INC. 
MIIA Property and Casualty Group, Inc., a non-party, hereby certifies that its counsel
attempted to confer in good faith with the Plaintiff regarding its Emergency Motion to Quash
Subpoena and for a Protective Order. On or about June 3, 2015, the undersigned spoke with the
Plaintiff to advise that she was awaiting confirmation from MIIA regarding what, if any,
documents MIIA had in response to Plaintiff’s subpoena to MIIA. At that time, the Plaintiff
agreed to extend the deadline for responding to said subpoena and/or to file a motion to quash
and/or a motion for protective order until June 12, 2015, in order that counsel may receive
information and confirmation from MIIA with the intent that that information would be
sufficient to persuade the Plaintiff to withdraw his subpoena. 
On the morning of June 11, 2015, after receiving additional information from MIIA, the
undersigned contacted the Plaintiff pursuant to Local Rule 7.1 to discuss the subpoena and
MIIA’s ongoing objections to same. The Plaintiff indicated he was unable to talk at the time this
call was made and indicated he could possibly call late in the afternoon or on the morning of
June 12, 2015. As the undersigned would not be available on June 12 to discuss, she requested
the Plaintiff contact her later on the 11 th prior to her having to leave the office at 3:30 pm for a
meeting or, in the alternative, to extend the deadline for the subpoena to June 19, 2015. The 
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Plaintiff did not contact the undersigned by the appointed time nor indicate an agreement to a
further extension and therefore, despite their best efforts, the undersigned and the Plaintiff were
unable to discuss the motion to quash substantively. As the agreed upon date to produce the
documents and/or file a motion to quash and/or for protective order is today, the non-party,
MIIA, is filing this motion at this time. 
Date: June 12, 2015 Respectfully submitted, 
MIIA Property and Casualty Group, Inc., 
A non-party, 
By its attorneys, 
/s/ Deawn C. Takahashi 
Arthur E. Maravelis (BBO#564673) 
Deawn C. Takahashi (BBO#657282) 
TANG & MARAVELIS, P.C. 
50 Mall Road, Suite 111 
Burlington, MA 01803 
(781) 221-1400 
Certificate of Service 
I hereby certify that a true copy of the above document was served upon Plaintiff by
forwarding same via ECF on June 12, 2015. 
/s/ Deawn C. Takahashi 
______________________________ 
Deawn C. Takahashi 
Case 1:14-cv-13050-JGD Document 30-1 Filed 06/12/15 Page 2 of 2