SMOC Lawsuit Information
Links
PILOT Commitee Index of Materials
SMOC Lawsuit Document: Table Of Contents
Compiled by William LaBarge
Disclaimer: This is a rough draft, consequently may contain errors.
Top of Page UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS
"List of Plaintiffs v. List of Defendants"
Page 1 Before #1 VERIFIED COMPLAINT AND JURY TRIAL DEMAND INTRODUCTION
Page 4 Before #9 PARTIES
Page 12 Before #29 JURISDICTION AND VENUE
Page 12 Before #30 FACTS SMOC and its MISSION
Page 15 Before #39 The Dover Amendment
Page 16 Before #41 The Hostile Climate for Nonprifit Social Service Agencies In Framingham
Page 18 Before #47 Actions in Furtherance of the Conspiracy to Defame SMOC and to Violate the Civil Rights of SMOC and its Disabled Clients The Sage House Program
Page 21 Before #52 Plans to Relocate and Expand the Sage House Program
Page 22 Before #58 Unlawful Interference with SMOC's Plans to Relocate Sage House to 517 Winter Street
Page 31 Before #77 Amendment of the Zoning By-Law to Attempt to Subject the Sage House Program to Burdensome Site Plan Review
Page 40 Before #105 Continued Efforts to Obstruct the Sage House Program
Page 47 Before #124 The Planning Board Holds Seven Public Hearings Regarding the Sage House Program
Page 67 Before #174 The Planning Board Attempts to Impose Illegal Conditions on the Sage House Program
Page 68 Before #177 Anonymous Town Actors Leak a Confidential 51A Report
Page 74 Before #192 Social Service PILOT and Comparative Impact Study
Page 77 Before #200 Defendants Attempt to Pressure SMOC by Attacking Other Projects
Page 77 Before #201 105 Irving Street - The Common Ground Shelter
Page 82 Before #211 3 Merchant Road - Turning Point Shelter
Page 84 Before #217 Defendants' Ongoing Discrimination 90 Lincoln Street: Larry's Place - A Homeless Veterans Residence
Page 87 Before #227 Lodging House Bylaw
Page 90 Before #234 STEPPS Declares "Victory" and Seeks Donations to "Finish the Job"
Page 92 Before #239 COUNT ONE (Conspiracy) (SMOC and SMNPHC v. All Individual Defendants)
Page 93 Before #246 COUNT TWO (Violation of the Fair Housing Act, 42 U.S.C. §3601 et seq.) (SMOC and SMNPGH v. All Defendants)
Page 94 Before #253 COUNT THREE (Violoation of the Americans With Disabilities Act, 42 U.S.C. §§12101 et seq.) (SMOC and SMNPHC v. Town of Framingham)
Page 94 Before #257 COUNT FOUR (Violation of the Federal Rehabilitation Act of 1973, 29 U.S.C. §§ et seq.) (SMOC and SMNPHC v. Town of Framingham)
Page 95 Before #261 COUNT FIVE (Violation of Title VI of the Civil Rights Act of 1964, 42 U.S.C. §1983) (SMOC and SMNPHC v. Town of Framingham and Peter C.S. Adams, Steven Orr, Laurie Lee, Cynthia Laurora, Dennis Giombetti, Ginger Esty, Jason Smith, Susan Bernstein, Carol Spack, Andrea Carr-Evans, Ann Welles, Alexis Silver, Julian M. SUSO, John Does I-V and Jane Does I-V, each in their individual and official capacities)
Page 95 Before #264 COUNT SIX (Violation of the Massachusetts Civil Rights Act, M.G.L. c. 12, §§11H-aaI) (SMOC and SMNPHC v. All Individual Defendants)
Page 96 Before #267 COUNT SEVEN (Defamation) (SMOC and SMNPHC v. Adams, Orr, Wolfe, Esty, Giombetti, Laurora, Siciliano and Jane or John Doe)
Page 96 Before #270 COUNT EIGHT (Preliminary and Permanent Injunctive Relief v. Town of Framingham)
Page 98 After #275 viii PLAINTIFFS DEMAND A TRIAL BY JURY ON ALL ISSUES AND CLAIMS SO TRIABLE.
Signatures and names
Page 99 Verification
Table of Contents of Exhibits
Exhibit 1
Series of MWDN articles found on www.stepps.info/news.html May 2005 thru July 2005
Exhibit 2
May 27,2006 letter from STEPPS to The Framingham Board of Selectment concerning 517 Winter property sale to SMOC
Exhibit 3
STEPPS webpage Issues Surrounding Private Property Sprawl in Framingham May 25, 2005
Exhibit 4
Frambors post from Peter C.S. Adams Subject: Re; wet shelter and SMOC Date: Fri 03 Jun 2005 12;22:17 -0400
Exhibit 5
makingpages.org/mailman/listinfo/stepps_makingpages.org submitted by Janice Skelley on behalf of STEPPS June 2005
Exhibit 6
Frambors post from Peter C.S. Adams Subject: Re: SC ruling Date: Sat, 25 Jun 2005 13:29:49 -0400
Exhibit 7
Frambors post from Steven W. Orr Subject Re: Winter Street drain on the tax base Date: Sat, 21 may 2005 11:00:38 -0400
Exhibit 8
http://www.smockingham.org/the-anonymouse-letter.html 10/17/2007
Exhibit 9
http://www.smocingham.org/smocingham-fromt.html 7/21/2005 The Anonymous Letter To: STEPPS From: (anonymous) Re: Framingham Nursing Home Date: May 25, 2005
Exhibit 10
June, 2005 letter from SMOC to the Residents
Exhibit 11
Frambors post from Steven W. Orr Subject We are not alone Date: Mon, 30 May 2005 12:07:35 -0400
Exhibit 12
Board of Selectmen Meeting Minutes Thursday, June 2, 2005 Ablondi Room
Exhibit 13
http://www.smocingham.org reprint of MWDN David McLaughlin news Friday, June 3, 2005
Exhibit 14
Memorandum from Christopher J. Petrini to the Board of Selectmen Date: July 8, 205 Re: 517 Winter St - List of Questions dated by 5/31/05 presented by STEPPS
Exhibit 15
A letter from Matthew A. Romero Sent: Monday, June 20, 2005 11:01 AM to: Joe R. Mikielian CC: George P. King, Jr. Subject: 517 Winter St
Letter from Triplett, Jim Sent: Tueday, May 24, 2005 2:12 PM To Janice Skelley CC: Cobb, Granger Subject: STEPPS Forwarded to David Westwater on May 28, 2005 9:36AM Subject Forward: Letter from Summerville
Date:May 27, 2005 Letter to The Framingham Board of Selectmen From: STEPPS Re: 517 Winter Property Sale to SMOC
Exhibit 16
To: George P. King, Jr. Town Manager From: Joseph R. Mikielian, Director of Inspectional Services Date: June 21, 2005 Re: 517 Winter Street - proposed SMOC residence
Exhibit 17
Letter hand delivered from Bowditch & Dewey Attorneys July 12, 2005 to Joseph R. Mikielian, Building Commissioner
Re: 517 Winter Street, Framingham ("Property")
Certificate of inspection for the Nursing Home
Fire Certificate of Inspection for the nursing home
Department of Building Inspection application to change use of property
Exhibit 18
Letter hand delivered from Bowditch & Dewey Attorneys July 13, 2005 to Joseph R. Mikielian, Building Commissioner
Re: 517 Winter Street, Framingham, ("Property")
Exhibit 19
Letter from SMOC July 12, 2005 To: George P. King, Jr. Town Manager
Re: 517 Winter Street, Framingham, MA
Exhibit 20
Memorandum from Christopher J. Petrini To: Board of Selectmen Date: July 22, 2005 CC: Zoning Board of Appeals Planning Board Standing Committee on Planning and Zoning Government Study Committee Edward Noonan, Town Moderator George P. King, Jr., Town Manager Mark J. Purple, Assistant Town Manager Joe Mikielian, Building Commissioner Eugene Kennedy, Senior Planner
Exhibit 21
Planning Board Minutes Thursdya, July 28, 2005 Public Hearing Room
Exhibit 22
Special Town Meeting August 3, 2005
Article 1 Article 1 Amendments Planning Board proposed zoning amendments (Fairly extensive exhibit)
Exhibit 23
From: Inspectional Services Division To: James T. Cuddy, President SMNPHC Re: 517 Wnter St- proposed change of use permit
Special Town Meeting August 3, 2005 Article 1 Article 1 Amendments
Exhibit 24
Letter from Bowditch & Dewey Attorneys To: Joseph R. Mikielian, Building Commissioner August 19, 2005 Re: 517 Winter Street, Framingham ("Property")
Exhibit 25
Date: October 24,2005 From Christopher J. Petrini To: Kelli E Gunagan, Esq. Assistant Attorney General Re: Town of Framingham Zoning By-Law Amendments Adopted at Special Town Meeting on August 3, 2005 Response to Letters of SMNPH Corporation dated August 25, 2005 and September 9, 2005
Exhibit 26
To: Framingham Zoning Board of Appeals From L Gene Kennedy, Senior Planner CC: Kathleen Bartolini, Director of Planning and Economic Planning Board Re: ZBA #05-58 517 Winter Street Date: 10/25/05
Date: October 24, 2005 From Christopher J. Petrini To: Kelli E. Gunagan, Esq. Assistant Attorney General Re: Town of Framingham Zoning By-Law Amendments Adopted at Special Town Meeting on August 3, 2005 Response to Letters of SMNPH Corporation dated August 25, 2005 and September 9, 2005
Memorandum from Christopher J. Petrini To: Joseph Mikielian, Building Commissioner CC: Board of Selectmen Planning Board George P. King, Jr, Town Manager Zoning Board of Appeals Date: October 24, 2005 Re: Opinion Letter in response to SMNPHC August 19, 2005 Letter of Denial of an Application for Change of Use for 517 Winter Street
Memorandom form Gene Kennedy, Senior Planner To: Zoninb Board of Appeals CC: Kathleen Bartolini, Director of Planning and Economic Development Planning Board Re: 517 Winter Street SMNPHC - Sage House Family Treatment Program Date: 10/25/05
Exhibit 27
Frambors post from Peter C.S. Adams Subject: Re: Social Services discussion tuneup Date: Mon, 19 Sep 2005 15:59:04 -0400
Exhibit 28
Frambors post from Tony Siciliano Subject: REJECT: Re: An update on the telephone game Date: Mon, 14 Nov 2005 09:20:30 -0800
Exhibit 29
Frambors post from Peter C. S. Adams Subject: Re: Police coverage for SMOC Date Wed, 16 Nov 2005 10:58:01 -0500
Exhibit 30
From: Kelli E. Gunagan, Assistant Attorney General To Valerie Mulvey, Town Clerk Re: Framingham Special Town Meeting of August 3, 2005 Case #3545 Warrant Article # 1 (Zoning)
Exhibit 31
Memorandum from Christopher J. Petrini To Joseph R. Mikielian, Building Commissionerl CC: Board of Selectmen Planning Board Zoning Board of Appeals George P. King, Jr. Town Manager Mark J. Purple, Assistant Town Manager John W. Grande, Planning Board Administrator Eugene F. Kennedy, Zoning Board Administrator Glenna J. Shveland, Esq,. Petrini & Associates, P.C. Date: November 22, 2003 Re: Opinion Letter in Response to SMNPHC August 19, 2005 Letter Regarding Denial of a Application for Change of Use for 517 Winter Street
Exhibit 32
Letter from JOseph R. Mikielian, Building Commissioner To: James D. Hanrahan, Esq. Bowditch & Dewey, LLP Re: 517 Winter Street - Proposed Change of Use Permit Your letter of August 19, 2005
Exhibit 33
SMOCINGHAM reprint of MWDN news article SMOC has deal to place ex-cons: Only a few people served under pact with DOC have been placed in Framingham Date: Saturday, December 31, 2005 David McLaughlin
Exhibit 34
http://www.stepps.info/news.htm
Exhibit 35
Frambors post from Peter C.S. Adams Subject: Re: Mass. Dept of Corrections and SMOC - Coming to Date: Mon, 02 Jan 2006 15:36:38 -0500
Exhibit 36
Frambors post from Steven W. Orr Subject Re: Channel 5 News Report Date: Mon, 15, May 2006 09:34:01 -0400
Exhibit 37
Frambors post from Tony Siciliano Subject: SMOC thoughts Date: 1 Jan 2006 18:15:08 -0800
Exhibit 38
Letter from Joseph R. Mikielian Building Commissioner Date: February 7, 2006 To: James D. Hanrahan, Esq. Bowditch & Dewey, LLP Re: 517 Winter Street - Proposed Change of Use Permit Your Letter of January 11, 2006
Exhibit 39
To: Christopher J. Petrini From: John W. Grande, Planning Board Director Date: Bebruary 23, 2006 Re. Site Plan Review Process for Dover Amendment - Protected Uses (517 Winter Street)
Exhibit 40
Memorandum from Christopher J. Petrini To Planning Board John W. Grande, Planning Board Director Jessica Levengood, Senior Planner CC: Board of Selectmen Valerie W. Mulvey, Interim Town Manager Joseph Mikilian, Building Commissioner Eugene F. Kennedy, Senior Planner Glenna J. Sheveland, Esq., Petrini & Associates P.C. Date: April 6, 2006 Re: Response to Questions Regarding Site Plan Review Pursuant to Section IV.1.2 of the Zoning By-Law as Applied in G.L.c 40A. § 3 (Dover Amendment) Uses.
Exhibit 41
From: Jessica Levengood, Senior Planner To James D. Hanrahan, Esq. Bowditch & Dewey, LLP Date: April 7, 2006
Exhibit 42
Inter Office Memorandum To: Joseph Mikielian, Building Commissioner CC: Planning Board From Jay W. Grande, Planning Board Director Subject: Site Plan Review, 517 Winter Street Date: June 9, 2006
Exhibit 43
From Peter C.S. Adams on behalf of STEPPS To: Framingham Building Department Date June 12, 2006
Exhibit 44
From: Joseph R. Mikielian, Building Commissioner To: John W. Grande, Plannming Board Director Cc: Julian M. Suso, Town Manager Christopher J. Petrini Michael F. Foley, Assistant Director Re: Site Plan Review, 517 Winter Street Date: June 13, 2006
Exhibit 45
Frambors post from Steven W. Orr Subject Re: Planning Board Hearing 517 Winter St. June 22, 7:45 Date: 6 Jun 2006 13:49:02 -400
Exhibit 46
Frambors post from CFrary Subject Re: Planning Board Hearing 517 Winter St June 22, 7:45 Date: Tue, 6 Jun 2006 12:06:15 EDT
Exhibit 47
STEPPS SMOC Site Plan Comments & Suggestions 517 Winter Street Planning Board Town of Framingham Thursday, September 7, 2006
Exhibit 48
Planning Board Minutes Thursday September 7, 2006 Ablondi Room
Exhibit 49
Inter Office Memorandum To: Joseph Milielian, Building Commissioner From: Jay W. Grande, Planning Board Director Subject: Site Plan Review, 517 Winter Street Date: September 18, 2006 CC: Planning Board
Exhibit 50
From: Joseph R. Mikielian, Building Commissioner To: Chirstopher J. Petrini CC: Julian M. Suso, Town Manager John B. Grande, Planning Board Director Michael F. Foley, Assistant Director Date: September 21, 2006 Re: Planning Board memo
Exhibit 51
Memorandum From CHristopher J. Petrini To: Joseph R. Milielian, Building Commissioner CC: Board of Selectmen Planning Board Julian M. Suso, Town Manager John W. Grande, Planning Board Director Michael Foley, Assistant Building Commissioner Barbara J. Saint Andre, Esq., Petrini & Associates, P.C Date: September 29, 2006 Re: 517 Winter Street - Response to Your September 21, 2006 Request for an Opinion re the Planning Board Director's September 18, 2006 Memorandum Seeking Information Regarding Verification and Monitoring of Dover Amendment Uses for Sage House
Exhibit 51
Memo from James D. Hanrahan, Esq. Marisa L. Pizzi, Esq. Bowditch & Dewey Attorneys To: Framingham Planning Board Date: October 5, 2006 Re: SMNPHC 517 Winter Street, Framingham, Massachusetts
Exhibit 53
Hand delivered from Bowditch & Dewey Attorneys To: Christopher J. Petrini, Esq. Date: October 5, 2006 Re: 517 Winter Street, Framingham, MA
Exhibit 54
Planning Board Minutes Thursday October 12, 2006 Ablondi Room
Exhibit 55
Planning Board Minutes Thursday, November 9, 2006 Ablondi Room
Exhibit 56'
Planning Board Minutes Thursday, Decenber 7, 2006 Memorial Building
Exhibit 57
Planning Board Minutes Thursday, January 4, 2007 Public Hearing Room
Exhibit 58
Planning Board Meeting Thursday, January 25, 2007 Memorial Building
Exhibit 59
To: Julian Suso, Town Manager cc: Christopher Petrini, Town Counsel From: Mike Foley, Acting Building Commissioner Date: November 1, 2006 Re: 517 Winter Street 20 Vernon Street Dover Amendment Exempt Use Status, MGL c. 40A sec. 3
Exhibit 60
From: Julian M. Suso, Town Manager To: Peter Adams STEPPS Date: November 7, 2006 CC: Cynthia Laurora Laurie Lee Larry Hendry Board of Selectmen Chris Petrini Mike Foley
Exhibit 61
From: Michael F. Foley, Acting Building Commissioner Date: November 22, 2006 To: James Hanrahan Bowditch & Dewey Re: 517 Winter Street Property Proposed Use
Blank form Supplemental Information for Applications Seeking Exempt Use Status MGL c. 40 A S 3. / Dover Amendment
Exhibit 62
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/27/06 From: Blanca Medina
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/27/06 From: Ashley Da Souca<illegible>
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/8/06 From: Dawn Roche
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/10/06 From: Kevin L<illegible>
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/3/06 From: Susan Bennett
Complaint Form Inspectional Service Division Department of Building Inspection Date: Nov 3, 2006 From: Cynthia + Massimo Laurora
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/14/06 From: Enzo Rotatori
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/14/06 From:
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/13/06 From: Judy Leeror <illegible>
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/13/06 From: David Rooney
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/27/06 From: Ellen E. Casey
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/27/06 From: Debbie Chase
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/12/06 From: Betty Sullivan
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/11/06 From: Chris Ti<illegible>
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/11/06 From: Eric and Tammy Vallerder <illegible>
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/27/06 From: Lillian Cairney
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/11/06 From: Ed bard
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/14/06 From:
Complaint Form Inspectional Service Division Department of Building Inspection Date: 11/2/06 From: Lillian Belfonti
Exhibit 63
Memorandum from Christopher J. Petrini To: Board of Selectmen Date: November 28, 2006 CC: Julian M. Suso, Town Manager Michael Foley, Acting Building Commissioner Zoning Board of Appeals Eugene F. Kennedy, Senior Planner Jay W. Grande, Planning Board Director Re: Ability of Building Commissioner to Reconsider Decision as to Applicability of Dover Amendment and to Retroactively Apply new Dover Criteria to Evaluate Past Dover Determination Decisions
Exhibit 64
Slide Show Neighborhood Requests for SMOC's Proposed Use of 517 Winter Street December 7, 2006
Exhibit 65
STEPPS letter to the Planning Board Members and Mr. Grande, January 22, 2007
Exhibit 66
Frambors post from Steven W. Orr Subject Re: SMOC's client "Spare Change Guy" Date: Fri, 2 Feb 2007 15:00:40 -0500
Exhibit 67
Frambors post from Peter C.S. Adams Subject: Wayside prevails in first round of "screw Framingham" contest Date: Fri, 16, Feb 2007 11:29:19 -0500
Exhibit 68
Frambors post from Steven W. Orr Subject Re: School Budget Cuts + PILOT Date: Thu, 22 Mar 2007 17:41:53 -0400
Exhibit 69
Frambors post from Steven W. Orr Subject [SSA Watch] Another model SMOC Client living in Framingham Date: Thu, 15 Feb 2007 16:37:12 -0500
Exhibit 70
Frambors post from Tony Siciliano Subject Re: [SSA Watch] Another model SMOC Client living in Framingham Date: Thu, 15 Feb 2007 15:55:24 -0800
Exhibit 71
Memorandum from Christopher J. Petrini To: Planning Board CC: Jay W. Grande, Planning Board Director Board of Selectmen Julian Suso, Town Manager Michael Foley, Acting Building Commissioner Barbara J. Saint Andre, Esq, Petrini & Associates, P.C. Date: February 8, 2007 Re: 517 Winter Street - Proposed Site Plan Conditions set forth in draft decision dated February 8, 2007
From: Keilli E. Gunagan, Assistant Attorney General To Valerie Mulvey, Town Clerk Date: November 16, 2005 RE: Framingham Special Meeting of August 3, 2005 - case #3545 Warrant Article #1 (Zoning)
Exhibit 72
Decision Of The Framingham Planning Board On The Application Of South Middlesex Non-Profit Housing Corporation For Site Plan Review Approval and Public Way Access Permit for 517 Winter Street, Framingham, MA Date of Decision: April 5, 2007
Exhibit 73
Planning Board Minutes Thursday, April 12, 2007 Public Hearing Room
Exhibit 74
Frambors post from Steven W. Orr Subject: Re: Illegal activities within SMOC Date: Fri, 13 Apr 2007 14:32:44 -0400
Exhibit 75
Frambors post from: Cynthia Laurora Subject: Re: Illegal activites within SMOC Date: Sat, 14 Apr 2007 00:09:59 -0400
Exhibit 76
Frambors post from Steven W. Orr Subject Re: Unfounded illegal activities within SMOC Date: Sat, 14 Apr 2007 13:04:17 -0400
Exhibit 77
STEPPS State slams SMOC in Sage House drug running investigation July 9, 2007 HTTP://www.stepps info/Sage House drug running investigation.html
Exhibit 78
Frambors post from Steven W. Orr Subject: Re: SMOC client accused of invading home on Winter Street Date: Sun, 17 Jun 2007 09:15:01 -0400
Exhibit 79
Frambors post from Steven W. Orr Subject: Resolution? on the drug runners out of Sage House Date: Wed, 11 Jul 2007 18:04L45 -0400
Exhibit 80
Frambors post from Peter C.S. Adams Subject Re: Resolution? on the drug runners out of Sage House Date: Sun, 15 Jul 2007 22:06:40 -0400
Exhibit 81
STEPPS STEPPS News & Updates August 2007 www.Stepps.info.news.html
Exhibit 82
Memorandum From Christopher J. Petrini To: Board of Selectmen Social Service PILOT and Comparative Impact Study PILOT Committee CC: Mark Purple, Interim Town Manager Edward Noonan, Town Moderator Glenna J. Sheveland, Esq., Petrini & Associates, P.C. Date: December 12, 2005 Re: Evaluation of Legal issues Posted by Activities of Social Service PILOT and Comparative Impact Study PILOT Committee, Including Voluntary Questionaire Issued to Various Non-Profit Social Service Organizations in the Town of Framingham
Exhibit 83
Town of Freamingham Social Service PILOT and Comparative Impact Study Committee Final Report May 2006
Exhibit 84
Town of Framingham PILOT/Impact Study Committee Report of the Minority May 2006
Exhibit 85
From: Dawn Harkness Date: Wednesday, November 02, 2005 1:14PM To: Jim Cuddy; George P. King, Jr., Steven W. Orr, BobBerman Subject: Steve Orr's visit to 105 Irving Street
Exhibit 86
The South Middlesex Opportunity Council Ending Homelessness For Single Adults In The Metrowest Region of the Commonwealth of Massachusetts June 14th, 2006
Exhibit 87
SMOCINGHAM Reprint of MWDN Shelter change in the long run Friday, September 29,2006 D. Craig MacCormack
Exhibit 88
SMOCINGHAM Reprint of MWDN Memo: SHelter not protected by Law Thursday, October 5, 2006 D. Craig MacCormack
Exhibit 89
From: Michael Foley, Acting Building Commissioner Date: September 18, 2007 To: James Hanrahan Bowditch & Dewey, LLP Re: 90 Lincoln Street, Framingham, MA
Exhibit 90
Article 12 Bylaw Concerning Lodging Houses
Exhibit 91
STEPPS Victory Fund 2007
Exhibit 92
From: stepps-bounces@makingpages.org On behalf of Peter Adams Sent: Sunday, September 30, 2007 10:28 AM To: STEPPS Subject [STEPPS] Successful neighborhood meeting -- another one coming?
TAB A
DEFENDANT PETER C.S. ADAMS
DEFENDANT STEVEN ORR
DEFENDANT ANTHONY SICILIANO
DEFENDANT HAROLD WOLFE
DEFENDANT GINGER ESTY
DEFENDANT CYNTHIA LAURORA
DEFENDANT DENNIS GIOMBETTI
DEFENDANT JANE OR JOHN DOE I