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Home My WebLink AboutMiscellaneous - 9 BRADSTREET ROAD B AHRAWY LAW OFFICES Estate Planning & Litigation 2 July 22, 2005 3. -r->".Z r CSM TOWN OF NORTH ANDOVER > BUILDING DEPARTMENT y 120 Main Street north Andover, MA. 01845 Re: Joyce A. Warchol V. Kevin J. Barry d/b/a Barry Bros. Painting & Daniel Gibney Essex Superior Court C.A. No. 2004-1255 C Dear Sir/Madam: Enclosed herewith please find NOTICE TO TAKE KEEPER OF THE RECORDS DEPOSITION along with SCHEDULE A. An appearance can be avoided by providing the documents requested on the attached SCHEDULE A to this office on or before July 29, 2005 . Thank you for your courtesy operation in this matter. Very tr y ou s, AHRAWY RAB/im enclosures 55 Main Street P.O. Box 455 North Andover, MA 01845-0455 Phone: (978) 682-1141 FAX: (978) 686-1130 Ramsey A. Bahrawy, Esq. /Attorney-at-Law BahrawyLaw@aol.com RECEIVES JOYCE E BRADSHAW OWN CLF'RK A COMMONWEALTH OF MASSACHUSETTS ESSEX, SS . SUPERIOR COURT CIVIL ACTION NO. : 2004-1255 C *************************** * JOYCE WARCHOL, * Plaintiff, * V. * NOTICE TO TAKE KEEPER OF * OF THE RECORDS DEPOSITION. KEVIN J. BARRY d/b/a * PURSUANT TO MRCP 30. BARRY BROTHERS PAINTING AND DANIEL GIBNEY Defendants . * *************************** To: TOWN OF NORTH ANDOVER KEEPER OF THE RECORDS BUILDING DEPARTMENT 120 Main Street North Andover, MA. 01845 Please take notice that pursuant to Massachusetts Rules of Civil Procedure, Rule 30 (b) (6) , the plaintiff will take a Deposition of Keeper of the Records, Town of North Andover, 120 Main Street, North Andover, Massachusetts, pursuantto the applicable provisions of the Massachusetts Rules of Civil Procedure, before, Doherty Court Reporting Notary Public in and for the Commonwealth of Massachusetts, or before some other officer authorized by law to administer oaths. He/she is required to bring with him/her those documents listed on the Attached Schedule A regarding 9 Bradstreet Road, North Anodver, MA. ill RECIENED JOYCE DR40W": The oral examination will continue from day to day until complete . The Plaintiff, Joyce Warchol, BQhttornZe 'Ria msey A. Bahra BBO# 309230 BAHRAWY LAW OFFICES. 55 Main Street North Andover, MA 01845 (978) 682-1141 RECE)VED JOYCE BRADSHAW TOWN CLERM SCHEDULE A 1 . The content of any file relative to 9 Bradstreet Road, North Andover, MA maintained by the North Andover Building Department . 2 . Any and all Applications for Building Permits for construction to be performed at 9 Bradstreet Rd. , North Andover, MA, including but not limited to: a. The identity of any and all contractors and owners applying for a Building permit, including copies of State Licenses. b. Any and all demolition permits, Debris Disposal Forms, Workers Compensation Affidavits, sketches, plans, drawings, proposals, mortgage plot plans or other plot plans, any and all documents which identify the material to be used, Form U and any and all other documents including notes of inspectors, any and all correspondence, relating to construction at 9 Bradstreet Road North Andover, MA. ; 3 . Any and all documents which refer or relate to communications between the Town of North Andover and Kevin J. Barry, Jr. , Daniel J. Gibney, Justin T. Hart, Al Macarillo, Jim Quinlan, Francis Gibney, Attorney Raymond Vivenzio, Attorney Kevin Scanlon, Attorney Randy Spencer and Joyce Warchol from January 1, 2002 to the present time. 4 . Any and all affidavits relating to construction at 9 Bradstreet Road North Andover, MA. BAHRAWY LAW OFFICES Estate Planning & Litigation 4�c-s July 22, 2005 TOWN OF NORTH ANDOVER BUILDING DEPARTMENT 120 Main Street north Andover, MA. 01845 Res Joyce A. Warchol V. Kevin J. Barry d/b/a Barry Bros. Painting & Daniel Gibney Essex Superior Court C.A. No. 2004-1255 C Dear Sir/Madam: Enclosed herewith please find NOTICE TO TAKE KEEPER OF THE RECORDS DEPOSITION along with SCHEDULE A. An appearance can be avoided by providing the documents requested on the attached SCHEDULE A to this office on or before July 29, 2005 . Thank you for your courtesy operation in this matter. Very tr y ou s, i I AHRAWY RAB/im enclosures 55 Main Street P.O. B��A 55 North Andover, 01845-0455 Phone: (978) 6 2-1141 FAX: (978) 68 -1130 Ramsey A. Bahrawy, Esq. /Attorney-at-Law B ahrawyLaw @ ol.com RECENtS OYCt BRADSHAW Nr-K COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. SUPERIOR COURT CIVIL ACTION NO. : 2004-1255 C JOYCE WARCHOL, * Plaintiff, * V. * NOTICE TO TARE KEEPER OF * OF THE RECORDS DEPOSITION. KEVIN J. BARRY d/b/a * PURSUANT TO MRCP 30. BARRY BROTHERS PAINTING AND DANIEL GIBNEY * Defendants. * To: TOWN OF NORTH ANDOVER KEEPER OF THE RECORDS BUILDING DEPARTMENT 120 Main Street North Andover, MA. 01845 Please take notice that pursuant to Massachusetts Rules of Civil Procedure, Rule 30 (b) (6) , the plaintiff will take a Deposition of Keeper of the Records, Town of North Andover, 120 Main Street, North Andover, Massachusetts, pursuant to the applicable provisions of the Massachusetts Rules of Civil Procedure, before, Doherty Court Reporting Notary Public in and for the Commonwealth of Massachusetts, or before some other officer authorized by law to administer oaths. He/she is required to bring with him/her those documents listed on the Attached Schedule A regarding 9 Bradstreet Road, North Anodver, MA. RECEIVED JOYCE $RADSH TOWN CURK `i 2? .. The oral examination will continue from day to day until complete. The Plaintiff, Joyce Warchol, By h ttorne amsey A. Bahra BBO# 309230 BAH.RAWY LAW OFFICES. 55 Main Street North Andover, MA 01845 (978) 682-1141 MEW& JOYS BRAO.HA r LX SCHEDULE A 1 . The content of any file relative to 9 Bradstreet Road, North Andover, MA maintained by the North Andover Building Department . 2 . Any and all Applications for Building Permits for construction to be performed at 9 Bradstreet Rd. , North Andover, MA, including but not limited to: a. The identity of any and all contractors and owners applying for a Building permit, including copies of State Licenses . b. Any and all demolition permits, Debris Disposal Forms, Workers Compensation Affidavits, sketches, plans, drawings, proposals, mortgage plot plans or other plot plans, any and all documents which identify the material to be used, Form U and any and all other documents including notes of inspectors, any and all correspondence, relating to construction at 9 Bradstreet Road North Andover, MA. ; 3 . Any and all documents which refer or relate to communications between the Town of North Andover and Kevin J. Barry, Jr. , Daniel J. Gibney, Justin T. Hart, Al Macarillo, Jim Quinlan, Francis Gibney, Attorney Raymond Vivenzio, Attorney Kevin Scanlon, Attorney Randy Spencer and Joyce Warchol from January 1, 2002 to the present time. 4 . Any and all affidavits relating to construction at 9 Bradstreet Road North Andover, MA. RECEIVED RECEIVED jo, Yn BRADS*�HA ), YyfEE{B ADS}^,HAW il y.p tl x[ k F{�R �{ COMMONWEALTH OF MASSACHUSETTS ESSEX, SS . SUPERIOR COURT CIVIL ACTION NO. : 2004-1255 C *************************** * JOYCE WARCHOL, * Plaintiff, * V. * NOTICE TO TAKE KEEPER * OF THE RECORDS DEPOSITION. KEVIN J. BARRY d/b/a * PURSUANT TO MRCP 30. BARRY BROTHERS PAINTING AND DANIEL GIBNEY * Defendants . * *************************** To: TOWN OF NORTH ANDOVER KEEPER OF THE RECORDS BUILDING DEPARTMENT 120 Main Street North Andover, MA. 01845 Please take notice that pursuant to Massachusetts Rules of Civil Procedure, Rule 30 (b) (6) , the plaintiff will take a Deposition of Keeper of the Records, Town of North Andover, 120 Main Street, No. Andover, Massachusetts on August 1, 2005 at 10:00 AM, pursuant to the applicable provisions of the Massachusetts Rules of Civil Procedure, before, Doherty Court Reporting Notary Public in and for the Commonwealth of Massachusetts, or before some other officer authorized by law to administer oaths . He/she is required to bring with him/her those documents listed on the Attached Schedule A regarding 9 Bradstreet Road, North Anodver, MA. The oral examination will continue from day to day until complete . The Plaintiff, Joyce Warchol, By her orney, C ams A. Bahrawy 309230 BAHRAWY LAW OFFICES. 55 Main Street North Andover, MA 01845 (978) 682-1141 SCHEDULE A 1 . The content of any file relative to 9 Bradstreet Road, North Andover, MA maintained by the North Andover Building Department . 2 . Any and all Applications for Building Permits for construction to be performed at 9 Bradstreet Rd. , North Andover, MA, including but not limited to: a. The identity of any and all contractors and owners applying for a Building permit, including copies of State Licenses . b. Any and all demolition permits, Debris Disposal Forms, Workers Compensation Affidavits, sketches, plans, drawings, proposals, mortgage plot plans or other plot plans, any and all documents which identify the material to be used, Form U and any and all other documents including notes of inspectors, any and all correspondence, relating to construction at 9 Bradstreet Road North Andover, MA. ; 3 . Any and all documents which refer or relate to communications between the Town of North Andover and Kevin J. Barry, Jr. , Daniel J. Gibney, Justin T. Hart, Al Macarillo, Jim Quinlan, Francis Gibney, Attorney Raymond Vivenzio, Attorney Kevin Scanlon, Attorney Randy Spencer and Joyce Warchol from January 1, 2002 to the present time. 4 . Any and all affidavits relating to construction at 9 Bradstreet Road North Andover, MA. 0 CERTIFICATE OF SERVICE I, Ramsey A. Bahrawy, Esquire, hereby certify that on July 20, 2005 I served a copy of the following: 1 . KEEPERS OF THE RECORD DEPOSITION NOTICE by mailing, regular mail, postage prepaid, directed to: Richard L. Fox, Esq. CARRAGHER, FOX & ROARK, P.C. 229 Billerica Road Chelmsford, MA 01824-3603 and Melissa J. Lewandowski, Esq. GLEASON LAW OFFICES, P.C. 163 Merrimack Street Haverhill, MA 01830 41 Z" . BAHRAWY /`t'e z"OSS t� RE i V Q JIM BRADSHAW TOWN CLERK JOYCE-$RADSHAW TOWN CLERK COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. SUPERIOR COURT CIVIL ACTION NO. : 2004-1255 C * JOYCE WARCHOL, * Plaintiff, * V. * NOTICE TO TAKE KEEPER KEVIN J. BARRY d/b/a * OF THE RECORDS DEPOSITION. PURSUANT TO MRCP 30. BARRY BROTHERS PAINTING AND DANIEL GIBNEY * Defendants . * To: TOWN OF NORTH ANDOVER KEEPER OF THE RECORDS BUILDING DEPARTMENT 120 Main Street North Andover, MA. 01845 Please take notice that pursuant to Massachusetts Rules of Civil Procedure, Rule 30 (b) (6) , the plaintiff will take a Deposition of Keeper of the Records, Town of North Andover, 120 Main Street, No. Andover, Massachusetts on August 1, 2005 at 10:00 AM, pursuant to the applicable provisions of the Massachusetts Rules of Civil Procedure, before, Doherty Court Reporting Notary Public in and for the Commonwealth of Massachusetts, or before some other officer authorized by law to administer oaths. He/she is required to bring with him/her those documents listed on the Attached Schedule A regarding 9 Bradstreet Road, North Anodver, MA. 1 The oral examination will continue from day to day until complete . The Plaintiff, Joyce Warchol, By her o rney, C ams Bahrawy 309230 BAHRAWY LAW OFFICES. 55 Main Street North Andover, MA 01845 (978) 682-1141 SCHEDULE A 1 . The content of any file relative to 9 Bradstreet Road, North Andover, MA maintained by the North Andover Building Department . 2 . Any and all Applications for Building Permits for construction to be performed at 9 Bradstreet Rd. , North Andover, MA, including but not limited to: a. The identity of any and all contractors and owners applying for a Building permit, including copies of State Licenses . b. Any and all demolition permits, Debris Disposal Forms, Workers Compensation Affidavits, sketches, plans, drawings, proposals, mortgage plot plans or other plot plans, any and all documents which identify the material to be used, Form U and any and all other documents including notes of inspectors, any and all correspondence, relating to construction at 9 Bradstreet Road North Andover, MA. ; 3 . Any and all documents which refer or relate to communications between the Town of North Andover and Kevin J. Barry, Jr. , Daniel J. Gibney, Justin T. Hart, Al Macarillo, Jim Quinlan, Francis Gibney, Attorney Raymond Vivenzio, Attorney Kevin Scanlon, Attorney Randy Spencer and Joyce Warchol from January 1, 2002 to the present time. 4 . Any and all affidavits relating to construction at 9 Bradstreet Road North Andover, MA. CERTIFICATE OF SERVICE I, Ramsey A. Bahrawy, Esquire, hereby certify that on July 20, 2005 I served a copy of the following: 1 . KEEPERS OF THE RECORD DEPOSITION NOTICE by mailing, regular mail, postage prepaid, directed to: Richard L. Fox, Esq. CARRAGHER, FOX & ROARK, P. C. 229 Billerica Road Chelmsford, MA 01824-3603 and Melissa J. Lewandowski, Esq. GLEASON LAW OFFICES, P.C. 163 Merrimack Street Haverhill, MA 01830 BAHRAWY AYCE BRADS AW TCWN Ct FRK AYCEBRADs Aw J1 ry COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. SUPERIOR COURT CIVIL ACTION NO. : 2004-1255 C *************************** * JOYCE WARCHOL, * Plaintiff, * V. * NOTICE TO TAKE KEEPER * OF THE RECORDS DEPOSITION. KEVIN J. BARRY d/b/a * PURSUANT TO MRCP 30. BARRY BROTHERS PAINTING AND DANIEL GIBNEY * Defendants . * *************************** To: TOWN OF NORTH ANDOVER KEEPER OF THE RECORDS BUILDING DEPARTMENT 120 Main Street North Andover, MA. 01845 Please take notice that pursuant to Massachusetts Rules of Civil Procedure, Rule 30 (b) (6) , the plaintiff will take a Deposition of Keeper of the Records, Town of North Andover, 120 Main Street, No. Andover, Massachusetts on August 1, 2005 at 10:00 AM, pursuant to the applicable provisions of the Massachusetts Rules of Civil Procedure, before, Doherty Court Reporting Notary Public in and for the Commonwealth of Massachusetts, or before some other officer authorized by law to administer oaths. He/she is required to bring with him/her those documents listed on the Attached Schedule A regarding 9 Bradstreet .Road, North Anodver, MA. i i The oral examination will continue from day to day until complete. The Plaintiff, Joyce Warchol, By her ;ABahrawy orney, ams 300 BAHRAWY LAW OFFICES. 55 Main Street North Andover, MA 01845 (978) 682-1141 SCHEDULE A 1 . The content of any file relative to 9 Bradstreet Road, North Andover, MA maintained by the North Andover Building Department . 2 . Any and all Applications for Building Permits for construction to be performed at 9 Bradstreet Rd. , North Andover, MA, including but not limited to: a. The identity of any and all contractors and owners applying for a Building permit, including copies of State Licenses . b. Any and all demolition permits, Debris Disposal Forms, Workers Compensation Affidavits, sketches, plans, drawings, proposals, mortgage plot plans or other plot plans, any and all documents which identify the material to be used, Form U and any and all other documents including notes of inspectors, any and all correspondence, relating to construction at 9 Bradstreet Road North Andover, MA. ; 3 . Any and all documents which refer or relate to communications between the Town of North Andover and Kevin J. Barry, Jr. , Daniel J. Gibney, Justin T. Hart, Al Macarillo, Jim Quinlan, Francis Gibney, Attorney Raymond Vivenzio, Attorney Kevin Scanlon, Attorney Randy Spencer and Joyce Warchol from January 1, 2002 to the present time. 4 . Any and all affidavits relating to construction at 9 Bradstreet Road North Andover, MA. CERTIFICATE OF SERVICE I, Ramsey A. Bahrawy, Esquire, hereby certify that on July 20, 2005 I served a copy of the following: 1. KEEPERS OF THE RECORD DEPOSITION NOTICE by mailing, regular mail, postage prepaid, directed to: Richard L. Fox, Esq. CARRAGHER, FOX & ROARK, P.C. 229 Billerica Road Chelmsford, MA 01824-3603 and Melissa J. Lewandowski, Esq. GLEASON LAW OFFICES, P.C. 163 Merrimack Street Haverhill, MA 01830 r . BAHRAWY