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Court

Massachusetts Unified County

Massachusetts

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Case Information

Filed 2024-10-25
Status Open
Type Malpractice Other
Docket 61 entries

Parties

Plaintiff Howitt, Dan
Defendant Progressive Law Llc|Reid, Charles|Sanchez, Beatriz

Docket Entries

  1. Addendum to Motion for Capias Warrant Applies To: Howitt, Dan (Plaintiff)
  2. Original civil complaint filed.
  3. Civil action cover sheet filed.
  4. Plaintiff John Doe's Motion to Proceed VIA Pseudonym
  5. Attorney appearance On this date Pro Se added for Plaintiff Dan Howitt
  6. Attorney appearance On this date Pro Se added for Defendant Progressive Law LLC
  7. Attorney appearance On this date Pro Se added for Defendant Charles Reid
  8. Attorney appearance On this date Pro Se added for Defendant Beatriz Sanchez
  9. Attorney appearance On this date Pro Se added for Defendant Progessive Law LLC
  10. Case assigned to: DCM Track A - Average was added on 10/25/2024
  11. Plaintiff(s) John Doe's Motion for a Preliminary Injunction
  12. Endorsement on Motion to Proceed VIA Pseudonym (#4.0): DENIED Denied. Plaintiff can ask the Court to impound any portions of the complaint regarding any personal medical information. (dated 10/28/24) Notice sent by email
  13. Endorsement on Motion for Preliminary Injunction (#5.0): Other action taken Short Order 2-Party hearing to be scheduled. (dated 10/28/24) Notice sent by email
  14. Plaintiff Dan Howitt's Motion to Withdraw Motion for Preliminary Injunction
  15. Endorsement on Motion to Withdraw Motion for Preliminary Injunction (#6.0): ALLOWED Court vacates a short order 2 party hearing at plaintiffs request. dated (11/4/24) Notice sent 11/6/24
  16. Amended: First amended complaint filed by Dan Howitt
  17. Plaintiff Dan Howitt's Motion to Amend Complaint
  18. Service Returned for Applies To: Sanchez, Beatriz (Defendant)
  19. Service Returned for Applies To: Reid, Charles (Defendant)
  20. Service Returned for Applies To: Progressive Law LLC (Defendant)
  21. Endorsement on Motion to Amend Complaint (#8.0): DENIED Motion to Amend the Complaint is DENIED without prejudice. Even though, the Plaintiff is Pro Se, he must comply with Superior Court Rule 9A before filing any Motion with the Court. Additionally, the Certificate of Service provided is inadequate. Dan Howitt is the Plaintiff. The Certificate of service says he made service on "the Plaintiff:. Finally, a proper Certificate of service must accompany all Court's filings properly identifying the party served and the means of service. (Dated 1/8/2025) Notice sent 1/9/25
  22. Plaintiff Dan Howitt's Motion to Amend Complaint
  23. Endorsement on Motion to Amend Complaint (#12.0): DENIED without prejudice. As stated in this Court's 1/9/2025 Decision, any & all parties must comply with Superior Court Rule 9A. This Court will not consider any Motion that does not comply with the Rule's Requirements. (dated 1/15/2025) Notice sent 1/16/25
  24. Plaintiff Dan Howitt's Notice of Motion to Amended Complaint
  25. Notice about Motion to Amend Complaint
  26. Plaintiff Dan Howitt's Motion to Amend Complaint
  27. Plaintiff Dan Howitt's Request for Entry of Default per Rule 55(a)
  28. Endorsement on Motion to Amend Complaint (#13.0): ALLOWED Motion to amend the complaint is allowed. Plaintiff shall file the amended complaint this court within twenty (20) days and plaintiff shall properly serve all parties as required by Mass R. Civ. Proc. 5 and any other applicable rules. dated (1/27/25) Notice Sent 1/29/25
  29. Amended: amended complaint filed by Dan Howitt
  30. Plaintiff Dan Howitt's Request for Entry of Default per Rule 55(a)
  31. Plaintiff Dan Howitt's Submission of Motion about the Situation of my 3/15/2025 request for entry of Default per Rule 55(a)
  32. Plaintiff Dan Howitt's Submission of Amended Motion about the Status of my 3/15/25 Request for Entry of Default per Rule 55(a)
  33. Document: Default order Mass. R. Civ. P. 55(a) Sent On: 04/18/2025 09:28:08
  34. Endorsement on Request for Default Rule 55a (#16.0): ALLOWED dated 4/14/25 notice sent 4/18/25
  35. Endorsement on Motion for the status of 3/15/25 Request for Entry of Default (#18.0): Other action taken SEE ORDER 4/15/25 NOTICE SENT 4/18/25 Judge: Budreau, Hon. James
  36. Default Order 55a Entered as to Progressive Law LLC (Defendant); Reid, Charles (Defendant); Sanchez, Beatriz (Defendant) notice sent 4/18/25
  37. Plaintiff Dan Howitt's Motion for Default Judgment for a Certain Sum Pursuant to Rule 55(b)(1)
  38. Plaintiff's Submission of Affidavit Regarding Military Service
  39. Amended 50 USC s3931 Affidavit Regarding Military Service
  40. Plaintiff Dan Howitt's Submission of Rule 55(b)(2) 14 Day Notice of Hearing Regarding Default Order Against Defendants
  41. Event Result:: Damage Assessment Hearing scheduled on: 05/29/2025 02:00 PM Has been: Held as Scheduled Hon. James Budreau, Presiding Staff: Christine M Hayes, Assistant Clerk
  42. Plaintiff Dan Howitt's Notice of Service of 7/1/25 Hearing to Defendants
  43. Rule 55(b)(2) Affidavit & Motion For Default Judgment By The Court Applies To: Howitt, Dan (Plaintiff)
  44. Matter taken under advisement: Damage Assessment Hearing scheduled on: 07/01/2025 02:00 PM Has been: Held - Under advisement Hon. James Budreau, Presiding Staff: Christine M Hayes, Assistant Clerk
  45. MEMORANDUM & ORDER: Memorandum of Decision and Order on Plaintiff's Request for Damages Defendant's Charles Reid and Progressive law, LLC are hereby ordered to pay jointly and severally damages to Plaintiff Daniel Howitt in the amount of $50,000 (fifty thousand dollars) with interest. See paper #26 (Dated 7/21/25) (Notice sent 7/25/25) Judge: Budreau, Hon. James
  46. JUDGMENT entered on this date.: Default Judgment MRCP 55(b)2 After Hearing Presiding: Hon. James Budreau Judgment For: Dan Howitt Judgment Against: Progressive Law LLC Charles Reid Terms of Judgment: Interest Begins: 10/25/2024 Jdgmnt Date: 07/25/2025 Interest Rate: .12 Daily Interest Rate: .000329 Damages: Damage Amt: 50000.00 Judgment Total: 54,490.85 Entered on docket pursuant to Mass R Civ P 58(a) and notice sent to parties pursuant to Mass R Civ P 77(d)
  47. CORRECTED JUDGMENT entered on this date.: Default Judgment MRCP 55(b)2 After Hearing Presiding: Hon. James Budreau Judgment For: Dan Howitt Judgment Against: Progressive Law LLC Charles Reid Terms of Judgment: Interest Begins: 10/25/2024 Jdgmnt Date: 07/25/2025 Interest Rate: .12 Daily Interest Rate: .000329 Damages: Damage Amt: 50000.00 Judgment Total: 54,490.85 Further Orders: The claim against Defendant Beatriz Sanchez is DISMISSED. Entered on docket pursuant to Mass R Civ P 58(a) And notice sent to parties pursuant to Mass R Civ P 77(d)
  48. Execution Issued: Execution Judgment Debtor: Progressive Law LLC / Reid, Charles Judgment Creditor: Howitt, Dan Terms of Execution: EXON Issuance Date: 09/30/2025 Judgment Total: 54,490.85 Post Judgment Int. Rate: .12 Post Judgment Int. Total: 1,201.14 Execution Subtotal: 55,691.99 Execution Total: 55,691.99
  49. Defendant Progressive Law LLC, Charles Reid's Motion to Vacate Default Judgment and Request for Leave to File an Answer
  50. Affidavit of Charles Rein in Support of Defendants' Motion to Vacate Default and Leave to File an Answer and Counterclaims Late
  51. Proposed Filings/Orders Proposed Answer
  52. Affidavit of Charles Reid in Support of Defendants' Answer and Counterclaims
  53. Opposition to the Defendant's Motion to Vacate Default Judgment and Counterclaims filed by Dan Howitt
  54. Plaintiff Dan Howitt's Notice of Rule 9A Violation Regarding Defendant's Motion #30
  55. Opposition to Defendant's Motion to Vacate Judgment and for Leave to File an Amended Answer filed by Dan Howitt
  56. Plaintiff Dan Howitt's Notice of Rule 9A Violation Regarding Defendant Filing #32 as My Opposition (Second Notice)
  57. Exhibits/Appendix Defendants' Supplemental Exhibit to Defendants' Motion to Vacate Default Judgment Remove Default and Allow the Filing of a Late Answer and Counterclaims Applies To: Progressive Law LLC (Defendant); Reid, Charles (Defendant)
  58. Endorsement on Motion to Vacate Default Judgment and Request for Leave to File an Answer (#29.0): DENIED I do not credit Charles Ried. In his affidavit, he stated that he was arguming in court during the day the "alleged service" was made. Paper #10 and #11 shows the return of service of 12/19/24. According to Judgment (disbarment) entered by Justice Wendlant on 9/16/25, former attorney Reid's bar license was suspended on 11/18/24 uner SJC Rule 4.01 12A and never reinstated. He could not have not be arguing in any court. I credit Plaintiff who states in his opposition that the Deputy Sheriff served Mr.Reid in-hand who was in his car in his driveway. Default Judgment stands and the previous assessment of damages also stands. (Dated: 10/28/25) Notice sent 11/3/25
  59. Plaintiff(s) Dan Howitt's Motion for Contempt of Court
  60. Plaintiff Dan Howitt's EMERGENCY Motion for Trustee Execution and Writ of Sequestration
  61. Plaintiff Dan Howitt's Motion for Capias Warrant

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