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HomeMy WebLinkAboutMiscellaneous - 1049 TURNPIKE STREET 4/30/2018 (5)G z G 1.0 AAIvff" Nv� COM. NO� 752 1/3 �:kr. V LEONARD KOPELMAN DONALD G. PAIGE ELIZABETH A. LANE JOYCE FRANK JOHN W. GIORGIO BARBARA J. SAINT ANDRE JOEL B. BARD EVERETTJ. MARDER PATRICK J. COSTELLO JOSEPH L. TEHAN, JR. WILLIAM HEWIG 111 THERESA M. DOWDY DEBORAH A. ELIASON KOPELMAN ATT( Post-ItTm brand fax transmittal memo 7671 Eof pages ► 3 Tor BOSTON, MASSACHUSETTS 02110-1137 Fr Co. BOSTON OFFICE Co. /f MARY L. GIORGIO FAX (617) 951-2735 KATHLEEN E.-CONNOLLY F ' G Fax #, O'ff� 101..._....,..` ._..._,_, DAVID J. DON ESKI SANDRA CHARTOK BOSTON, MASSACHUSETTS 02110-1137 (LANA M. QUIRK BRIAN W. RILEY BOSTON OFFICE _ JOHN J. KENNEY, JR. (617) 951-0007 MARY L. GIORGIO FAX (617) 951-2735 KATHLEEN E.-CONNOLLY JOHN G. GANNON NORTHAMPTON OFFICE - KURT B. FLIEGAUF MICHELE E. RANDAZZO (413) 585-8632 PETER J.FEUERBACH AARON M. TOFFLER WORCESTER OFFICE ANNE C. PREISIG (508) 752-0203 January 24, 1996 Mr. Robert Nicetta Building Commissioner North Andover Town Hall 120 Main Street North Andover, MA 01845 Re: Charles Piscatelli, et al. v. D. Robert Nicetta, as he is the Building Commissioner of North Andover, et al. Land Court Misc. Case No. 224771 Dear Mr. Nicetta: Pursuant to our telephone conversation on January 23, enclosed please find a fully executed copy of the Order on Motion for Preliminary Injunction regarding the above -referenced case. If you have any additional questions, please feel free to call me. CAB/bjc Enc. : ii � ^, { .JAN 2 51 Very truly yours, 6�1�11414a Cheryl Ann Banks PRINTED ON RECYCLED PAPER �/ 17 ESSEX, SS. COMMONWEALTH OF MASSACHUSETTS LAND COURT CIVIL ACTION NO. 224771 CHARLES PISCATELLI and WILLIAM ) K. BARRETT, TRUSTEES OF TEN ) FORTY NINE REALTY TRUST, ) Plaintiffs ) V. ) D. ROBERT YVICETTA, AS HE IS ) BUILDING COMMISSIONER AND ZONING ) ENFORCEMENT OFFICER FOR THE TOWN ) OF NORTH ANDOVER, AND THE TOWN ) OF NORTH ANDOVER, ) Defendants ) ORDER ON MOTION FOR PRELIMINARY INJUNCTION This matter came on to be heard and, by agreement of the parties, it is hereby ordered and adjudged: = 1. The defendant, D. Robert Nicetta, as he is building commissioner and zoning enforcement officer for the Town of North Andover, is enjoined from refusing to issue a building permit authorizing installation of a new heating system, completion of the removal of the existing chimney and patching the _ole in the roof at 1049 Turnpike Street in North Andover solely on the grounds of the pending lawsuit of Kmiec et al v. North Andover Zoning Board of Appeals, et al., Essex Superior Court Civil Action No. 95-2207; 2. Replacement of the heating system, completion of the removal of the chimney and patching the hole in the roof are repairs which are not governed by the North Andover Zoning By-law, nor by Chapter 40A, Section 6; • 3. To the extent that the plaintiffs have requested authorization to make other interior alterations to the premises, the parties have agreed that these interior alterations will be presented to the Zoning Board of Appeals for a finding that the alterations are not substantially more detrimental to the neighborhood than the existing building. The plaintiffs have agreed to apply to the Zoning Board of Appeals for this finding without waiving their rights in this lawsuit, or in any other lawsuit, to argue that the North Andover Zoning By-law does not require such a finding in the first instance. By the Court (Rilborn, J.). Attest: Charles W. Trombly Recorder Dated: January 19 , 1996 ATF163A3/8894-5 109 PVI 17.25 TOTAL: s :17.25 *** U.S. POSTAL SERVICE*** � Z- -.TH ANDOVER BRANCH ANDOVERMA 01845-9998 -__________________ DATE: 01112196 04:42:42 PM --------------------------- --------------------------- -log -------------------------- ________-__________________109 PYI' 17.25 TOTAL: s* 17.25 ___________________________ ' THANK YOU :4-4-44 COMMONWEALTH OF MASSACHUSETTS LAND COURT DEPARTiNMNT OF THE TRIAL COURT Essex LAND COURT CIVIL ACTION Charles Piscatelli and William K. Barrett, N0.224771 Trustaoc of Ten Forty Nine Realty Trnst , Plaintiff (s) D. Robert Nicetta, as he is Building Commissioner and Inning FnforraMent Offirer -nd- the —TQLM of Knrth Defendant (s) Andover SUMMONS AND ORDER. OF NOTICE To the above-named Defendant:D.Robert Nicetta You are hereby summoned and required to serve upon Atty. Catherine J. Savoie plaintiff's attorney, whose address is 100 Charles River Plaza, Boston 02114 'an answer to the complaint which is herewith served upon you, within 20 days after service of this summons upon you, exclusive of the day of service. If you fail to do so, judgment by default will be taken against you for the relief demanded in the complaint. You are also required to file your answer to the complaint in the office of the Recorder of this court at Boston either before service upon plaintiff's attorney or within a reasonable time thereafter. Unless otherwise provided by Rule 13(a), your answer must state as a counterclaim any claim which you may have against the plaintiff which arises out of the transaction or occurrence that is the r subject matter of the plaintiff's claim or you will thereafter be barred from making such claim in any other action. WE ALSO NOTIFY YOU that application has been made in said action, as appears in the complaint, for a preliminary injunction and that a hearing upon such application will be held at the Land Court in said Boston on Wednesday the seventeenth day of January A.D. 19 96 at 10:00 o'clock A.M., at which you may appear and show cause why such application should not be granted. Witness, Robert V. Cauchon , Chief Justice, at Boston, the tenth day of January in the year of our Lord one thousand nine hundred and ninety—six. - l 1 y'v J - 1N � e r er. NOTES. � 1. This summons is issued pursuant to Rule 4 of the Massachusetts Rules of Civil Procedure. 2. When more than one defendant is involved, the names of all defendants should appear in the caption. If a separate summons is used for each defendant, each should be addressed to the particular defendant. FORM LCS-6 (5)93) 4 TRUE CO?y ATTEST: Oepury sheriff COMMONWEALTH OF MASSACHUSETTS ESSEX, SS. LAND COURT CIVIL ACTION NO. aa477 / CHARLES PISCATELLI and WILLIAM K. BARRETT, TRUSTEES OF TEN FORTY NINE REALTY TRUST, Plaintiffs V. D. ROBERT NICETTA, AS HE IS BUILDING COMMISSIONER AND ZONING ENFORCEMENT OFFICER FOR THE TOWN OF NORTH ANDOVER, AND THE TOWN OF NORTH ANDOVER, Defendants COMPLAINT AND REQUEST FOR A PRELIMINARY INJUNCTION 1. This is an action brought pursuant to G. L. c. 240, S14A by the owner of a pre-existing, nonconforming structure located in North Andover, Massachusetts for a judicial determination of the extent to which the North Andover Zoning By-law affects the plaintiffs' proposed repairs to the structure and minor interior alterations within the structure. The plaintiffs also seek preliminary and permanent injunctive relief against the defendants to prevent them from wrongfully enforcing the North Andover Zoning By-law to prevent the plaintiffs from making immediately necessary repairs and minor interior alterations. 2. The plaintiffs, Charles Piscatelli and William F. Barrett, are trustees of the Ten Forty Nine Realty Trust, owners of the structure at issue. I/ 3. The defendant, D. Robert Nicetta, is the duly appointed and authorized building commissioner and zoning enforcement officer for the Town of North Andover. 4. The defendant, the Town of North Andover, is a municipal corporation duly organized under the laws of the Commonwealth of Massachusetts and located in the County of Essex. 5. The structure at issue, located at 1049 Turnpike Street (Route 114), North Andover, Massachusetts, is a two-story wood frame single family home situated on a parcel (approximately one acre) in the Industrial 1 Zoning District of the Town of North Andover. A true and accurate copy of the North Andover Zoning By- laws revised as of 1995 is attached to the Affidavit of William K. Barrett as Exhibit "A". 6. The plaintiff purchased the house in March of 1995 with the intent of moving the offices of the plaintiff William Barrett's construction/development company into the building. 7. In the Industrial 1 District, under Section 4.132 of the North Andover Zoning By-law, business, professional, and other office uses are permitted as of right. Residential uses are not permitted in the Industrial 1 District as of right. 8. The house, however, is nonconforming as to the front and side setback requirements of the by-law. Under footnote 1 to the Table of Dimensional Requirements in the North Andover Zoning By- law, there is a 100 -foot front setback requirement for structures in the Industrial 1 District located on Route 114. The house at -2- 1049 Turnpike Street is on Route 114 and is approximately 15 feet from the street. The Table requires a 50 -foot sideyard requirement for structures in the Industrial 1 District. The distances from the side lot lines are: approximately 42 feet from the right lot line and approximately 36 feet from the left lot line. 9. The structure is lawfully nonconforming because it was built in approximately 1928 and the North Andover zoning by-law was first adopted at the annual town meeting of March 13, 1943. 10. On August 7, 1995, Ten Forty Nine Realty Trust submitted an application to the Town of North Andover Zoning Board of Appeals requesting authorization to expand the existing house by adding an exterior staircase, finishing the existing 441 square feet on the second floor and adding 270 square feet to the second floor. 11. On September 12, 1995, the Board of Appeals held a hearing on the application to expand a pre-existing nonconforming use. The hearing was continued to September 19, 1995 and on September 20, 1995, the Board issued an opinion finding that the proposed changes to the pre-existing, nonconforming structure "shall not be substantially more detrimental than the existing nonconforming structure to the neighborhood." A true and accurate copy of the Board's decision is attached to the Barrett Affidavit as Exhibit Xll.(� 12. Thereafter, an abutting neighbor, Agnes Kmiec, filed an action in the Essex Superior Court pursuant to Mass. G. L. c. 40A, §17, challenging the Board's decision. -3- 13. In order to avoid costly litigation and substantial delay in using the building, .on December 12, 1995, plaintiff William Barrett submitted a request to withdraw the special permit application at issue in the Essex Superior Court litigation from the North Andover Zoning Board of Appeals. A true and accurate copy of this withdrawal is attached to the affidavit of William 'Barrett as Exhibit " However, the North Andover Zoning Board of Appeals, at their regular meeting, voted to deny the plaintiff's request to withdraw the application for special permit. 14. On December 13, 1995, plaintiff William Barrett filed two separate applications for internal work to be performed on the house to enable his business to move into the house and to protect the house from exposure to the elements. Because the work and repairs requested in the applications are internal, none of the requested work will increase the nonconforming nature of the structure. 15. The first building permit requested authorization to install a new heating system with forced hot air and air conditioning into the building. 16. There is currently no working heating system in the building. The water system in the building brings water from the well into the basement. Without a heating system, the water pipes are likely to burst, causing substantial damage to the interior of the building. Barrett sought a permit to authorize the installation of a new heating system to prevent the situation. -4- 17. The second application requested authorization to perform the following work: ' (1) remove the existing chimney; (2) remove or open a wall to a new kitchenette; (3) enlarge the opening between the reception area and the main hall; and (4) install interior partitions (none structural) on the second floor to allow for a small storage room and one office. True and accurate copies of the building applications filed on December 13, 1995 are attached to the Affidavit of plaintiff c William Barrett as Exhibits "" and ". 18. Plaintiff requested authorization to remove the existing chimney because the chimney has decomposed and is in danger of further decomposing and disintegrating. 19. The roof is currently open over a portion of the chimney that has already been removed. The open roof is covered with a tarp; however, because of heavy snowfall during this winter, snow is coming through the tarp and going into the building. 20. Further substantial damage to the chimney will occur if the chimney is not removed and further substantial damage to the interior finish of the house including the walls, ceilings and floors will occur if the snow is allowed to enter through the roof in the location of the chimney. 21. On December 26, 1995, the building inspector for the Town of North Andover, D. Robert Nicetta, denied both building permit -5- applications Barrett filed on December 13, 1995. A true and accurate copy of Mr. Nicetta's denial is attached to the affidavit of William Barrett as Exhibit 'IF'. 22. One of the reasons stated by Mr. Nicetta for the denial of the applications is that: "The subject property is under litigation by Agnes M. Kmiec (Civil Suit No. 95-220) v. the North Andover Zoning Board of Appeals and, as such will not be issued a building permit until the civil suit has been decided." 23. Since the plaintiff's construction/ development company has not had an office on Turnpike Road, plaintiff has lost valuable exposure to potential customers, suffered great inconvenience and imposed inconvenience on its customers, contractors, workers and others due to being forced to conduct its business from a location that has less exposure to the public, is less conveniently located, and is inadequate for the needs of the business- 24. usiness-24. Plaintiff William K. Barrett has suffered severe emotional distress, and continues to suffer severe emotional distress, due to the building inspector's refusal to allow him to make necessary repairs to the building. As the winter progresses, and weather becomes more severe, Barrett has been forced to watch his building go to waste because he cannot make the repairs, causing significant emotional distress. 25. Section 9.1 of the North Andover Zoning By-laws provides: Any lawfully nonconforming building or structure and any lawfully nonconforming use of a building or land may be continued in the. same kind or manner and to the same extent as the time it became lawfully nonconforming, but such building or use shall not at any time be changed, extended, or cm enlarged, except for a purpose permitted in the zoning district in which such building or use is situated . . . . (emphasis added) 26. Under the North Andover Zoning By-law, a change, extension, or enlargement of a pre-existing nonconforming structure is permitted as of right if the change, extension, or enlargement is for a purpose permitted under the zoning district in which the building is situated. 27. Since the proposed repairs and minor alterations in the plaintiff's December 13 building permit applications are for the purpose of conducting an office use, which is permitted as of right in the Industrial 1 District in which the structure is located, the building inspector, in denying the permit on the grounds of the existing litigation, acted in excess of his authority. 28. Nowhere does the North Andover Zoning By-law prohibit or limit repairs to a pre-existing, nonconforming. structure in any way. 29. The building inspector, in denying a building permit application for necessary repairs to the building on the basis of pending litigation concerning the expansion of the building, acted in excess of his authority. 30. G. L. c. 40A, §6 provides that a zoning ordinance or by- law shall apply to any alteration of a pre-existing nonconforming structure "except where alteration . . . to a single or two family residential structure does not increase the nonconforming nature of said structure." -7- 31. Because the proposed work and repairs are strictly internal, as a matter of law they do not increase the nonconforming nature of the single family structure, which is nonconforming solely by virtue of insufficient setbacks. 32. Section 9.2 of the North Andover Zoning By-law has no applicability to plaintiffs' requested repairs and minor interior alterations to their structure because Section 9.2 pertains only to nonconforming uses and structures housing nonconforming uses and does not pertain to nonconforming structures housing permitted uses. 33. The criteria set forth in paragraphs 3 and 4 of Section 9.2 of the North Andover Zoning By-law are invalid because they are less tolerant of nonconforming uses and structures than G. L. c. 40A, §6 which sets forth the minimum tolerance to be accorded to nonconforming uses and structures. 34. For the reasons set forth above, an actual controversy exists between the plaintiffs and the defendants regarding the plaintiffs' rights under the North Andover Zoning By-law to perform necessary repairs, and to perform minor internal alterations to the lawful, pre-existing, nonconforming structure at issue. 35. Unless granted the relief sought herein, the plaintiffs will suffer immediate irreparable injury in that they will be unable to use their building as provided under G. L. c. 40A, §6 and the North Andover Zoning By-law, §9.1. 36. Unless granted the relief sought herein, the plaintiffs will suffer immediate irreparable injury in that the building will go to waste if continued exposure to the elements occurs, in particular, if vast amounts of snow enters the building through the hole in the roof and if the heating system is not replaced and the pipes freeze and burst. 37. Unless granted the relief sought herein, the plaintiffs will suffer immediate irreparable injury to their business because they will be prevented from conducting their business at a convenient location and in a building adequate to meet the needs of the business. 38. Unless granted the relief sought herein, plaintiff William K. Barrett will continue to suffer immediate irreparable harm insofar as he has incurred and will continue to incur severe emotional distress due to the defendants' refusal to permit him to make necessary repairs to his building. WHEREFORE, plaintiffs pray: A. That this Court enter a declaratory judgment, declaring: 1. The requested work and repairs in the December 13, 1995 building permit applications are specifically authorized, without a finding by the North Andover Zoning Board of Appeals, in Section 9.1 of the North Andover Zoning By-law because the proposed use is a lawful use as of right under the zoning by-law; 2. Insofar as the proposed work and repairs contained in the December 13, 1995 building applications request authorization to make necessary repairs to the structure, as opposed to a change, expansion or alteration of the structure, said repairs are not prohibited by the North Andover Zoning By-law, and are permitted as of right under G. L. c. 40A, §6; 3. Pursuant to G. L. c. 40A, §6, the work and repairs requested in the December 113, 1995 applications for building permits do not increase the nonconforming nature of a single-family residential structure and therefore the North Andover Zoning By-law does not apply to said work and repairs; 4. Section 9.2 of the North Andover Zoning By-law applies only to nonconforming uses and structures housing nonconforming uses and does not apply to nonconforming structures housing a permitted use .and, accordingly, does not apply to plaintiffs' request for repairs and minor interior alterations to enable a permitted use; 5. Section 9.2 of the North Andover Zoning By-law, paragraphs 3 and 4 are less tolerant of nonconforming uses than Chapter 40A, Section 6 and, therefore, said paragraphs are invalid and unenforceable. B. That this Court award the following temporary, preliminary, and permanent injunctive relief to the plaintiffs: 1. The defendants are enjoined from denying the two December 13, 1995 building permit applications submitted by the plaintiffs on the grounds that the work and repairs are not permitted under the North Andover Zoning By-law or G. L. c. 40A,_§6; 2. The defendants are enjoined from denying the building permit applications of December 13, 1995 on the grounds that the prior litigation concerning an expansion of a nonconforming use is pending in the Essex Superior Court; 3. The defendants are ordered to make a zoning determination, consistent with this order, that the work and repairs requested to be authorized in the December 13, 1994 building permit applications are authorized by the North Andover Zoning By-law and G. L. c. 40A, §6; 4. The defendants are enjoined from acting in any manner to use the North Andover Zoning By-law as an excuse or pretext to prevent plaintiffs from performing the repairs and work which are the subject of the December 13, 1995 building permit applications; 5. The defendants are enjoined from applying the provisions of Section 9.2 of the North Andover -10- Zoning By-law to the plaintiffs' proposed repairs and minor interior alterations; and 6. The defendants are enjoined from applying paragraphs 3 and 4 of Section 9.2 to the plaintiff's proposed repairs and minor interior alterations because paragraphs 3 and 4 of Section 9.2 are invalid and unenforceable. Respectfully submitted, CHARLES PISCATELLI and WILLIAM K. BARRETT, TRUSTEES OF TEN FORTY NINE REALTY TRUST, By their attorneys, Dated: January 10, 1996 c4r,�Z�� _11�_ Catherine J Savoie, BBO 544599 Posternak, Blankstein & Lund 100 Charles River Plaza Boston, MA 02114 (617) 973-6100 ATF16OF5/8894-5 -11- Town of North Andover . OFFICE OF COMMUNITY DEVELOPMENT AND SERVICES KENNETH R MAHONY Director December 21, 1995 146 Main Street North Andover, Massachusetts 01845 (508) 688-9533 Mr. William Barrett Ten Forty Nine Realty Trust 701(c) Salem Street North Andover, MA 01845 C�Op� Re: Request for withdrawal for petition # 042-95 Dear Mr. Barrett: This letter serves as a response to your request for withdrawal of your petition without prejudice for property located at 1049 Turnpike Street. The Board cannot grant your request because a decision has been filed. The petition can only be withdrawn prior to the issuance of a decision. If you have any questions please feel free to contact the Department. Sincerely, i William Sullivan Zoning Board of Appeals Chairman BOARD OF APPEALS 688-9541 BUILDING 683-9545 CONSERVATION 688-9530 HEALTH 688-9540 PLANNING 688-9535 Julie Parrino D. Robert Nicetta Michael Howard Sandra Stair Kathleen Bradley Colwell TOWN OF NORTH ANDOVER REQUEST FOR LEGAL SERVICES NAME: D. Robert Nicetta • L9101 TITLE: Building Commissioner VDEPARTMENT Building/Community Development & Services DESCRIPTION OF REQUEST: (Include such information as "request for legal opinion" or "relates to pending litigation." Is this a request of a committee or an individual member's concern; and is the request high - low priority and explain why. Please attach all relevant documentation.) RLe-1-ates__to,pendi-ng-l_-it-igation . RE: Trustees --of :Ten -Forty-Nine :�eal,tZTrust TIME FRAME: (By what date is a response needed; Please explain.) As'soon as possible (Hearing scheduled for 1/17/96) SUBMIT COMPLETED REQUEST FORM TO OFFICE OF SELECTMEN FOR PROCESSING Your request for legal services relative to was: Forwarded to Town Counsel Date Returned Date:— Reason: ate:Reason: Town Manager Town of North Andover OFFICE OF COMMUNITY DEVELOPMENT AND SERVICES 146 '2M= Streit North Andover, Massachusetts 01345 TO: Robert Nicetta, Building Inspector FROM: Sandra Starr, Health Administrate DATE: January 12, 1996 RE: 1049 Turnpike Street ' nt 0_ _. v _... . I have received your memo of January 11, 1996 with the attached Certificate of Analysis from Biomarine of Gloucester stating to be a water analysis of well water at 1049 Turnpike Street. I had not seen a water analysis associated with this site prior to your memo. I had a discussion with Mr. Barrett in December of 1995 in which I stated that when he was ready, either Susan Ford or I would come out to 1049 Turnpike Street and take a water sample from the tap for analysis. (I will also need to see the actual location of the well on the site to ascertain setbacks to any sewage disposal system and to determine if additional water tests for potential contaminants are appropriate. With an old shallow dug well this is extremely important and necessary to determine potability and safety of the water.) To date I have not received a request for this from Mr. Barrett. S0ARD0F.-1LPPE.US 688-9541 BUILDL`G 683-9545 CO`SER':AON 688-9530 HEALTH 688-9540 PUNNING 688-9535 s Town of North AndoverN0RTH OFFICE OF 3�oh`t °,�°0 COMMUNITY DEVELOPMENT AND SERVICES x 146 Main Street °' \ - • KENNETH R MAHONY North Andover, Massachusetts 0184 "SSACHUS�< Director (508) 688-9533 TO: Sandra Starr, Bcar . of _ ea_t:- Agent FR0M O'ert Nicetta, wilding Ccmmissioner DATE: January 11, 19 �S RE: 1049 TURNPIKE ,.TFc= - ;vi l=iam K. Barrett d/b/a Colonial Village Develccmen- Please advise if ycu a_- , __. _ecei_t of a ccpy of the attached Certi�lCate Of Lila V.^—__ �_Oi ,mC- arine Of lOUCeSt2r, MA Wlt�. regard to subject lccaticn. I= r_ot, I have attached a copy for your comment. In addition, kindly re-pcnd as tc - e present status of your letter -regarding potable water a- 104-9 Turnpike Strut. Thank you. /gb BOARD OF APPEALS 688-9541 BUILDING 688-9545 CONSERVATION 688-9530 HEALTH 688-9540 PLANNING 688-9535 Julie Parrino D. Robert Nicena Michael Howard Sandra Starr Kathleen Bradley Colwell KENNETH R. MAHONY Director Town of North Andover M°RTM, OFFICE OF 3?°e ``oto COMMUNITY DEVELOPMENT AND SERVICES - ". 146 Main Street North Andover, Massachusetts 01845 �9SSACMUS�t�c (508) 688-9533 December 26, 1995 Mr. William K. Barrett, Trustee Ten Forty -Nine Realty Trust 701C Salem Street North Andover, MA 01845 RE: Building Permit Application 1049 Turnpike Street Dear Mr. Barrett: The Building Permit application as submitted indicates that the structure at 1049 Turnpike Street is not connected to the town water or sewer system. In checking with the Board of Health, I have been advised that there is neither potable water nor an approved sewerage disposal system at the site. Therefore, your application for a Building Permit is DENIED. Additionally, the subject property is under litigation by Agnes M. Kmiec (Civil Suit No. 95-220) vs. the North Andover Zoning Board of Appeals and, as such, will not be issued a Building Permit until the Civil Suit has been decided. Yours truly, D. Robert Nicetta, Building Commissioner & Zoning Enforcement Officer c/Kevin Mahoney, Interim Town Manager BOARD OF APPEALS 688-9541 BUILDING 688-9545 CONSERVATION 688-9530 HEALTH 688-9540 PLANNING 688-9535 Julie Purim - D. Robat Niwe is WKhs.el Howard Sandra Stmt Katbloen Bradley Colwell Town of North Andover NQRTM OFFICE OF 3?Qb tjLtD O,tiOQL COMMUNITY DEVELOPMENT AND SERVICES ° a - • 146 Main Street KENNETH R. MAHONY North Andover, Massachusetts 01845 9ss CHU Director (508) 688-9533 December 26, 1995 Mr. William K. Barrett, Trustee Ten Forty -Nine Realty Trust 701C Salem Street North Andover, MA 01845 RE: Building Permit Application 1049 Turnpike Street Dear Mr. Barrett: The Building Permit application as submitted indicates that the structure at 1049 Turnpike Street is not connected to the town water or sewer system. In checking with the Board of Health, I have been advised that there is neither potable water nor an approved sewerage disposal system at the site. Therefore, your application for a Building Permit is DENIED. Additionally, the subject property is under litigation by Agnes M. Kmiec (Civil Suit No. 95-220) vs. the North Andover Zoning Board of Appeals and, as such, will not be issued a Building Permit until the Civil Suit has been decided. Yours truly, D. Robert Nicetta, Building Commissioner & Zoning Enforcement Officer DRN:gb c/Kevin Mahoney, Interim Town Manager BOARD OF APPEALS 688-9541 BUILDING 688-9545 CONSERVATION 688-9530 HEALTH 688-9540 PLANNING 688-9535 Julie Parrino D. Robert NiceGa Michael Howard Sandra Starr Kathleen Bradley Colwell November 22, 1995 William K. Barrett, Trustee Ten Forty Nine Realty Trust 701C Salem Street North Andover, MA Re: Building Permit Application received 11/13/95 for 1049 Turnpike Street Dear Mr. Barrett: Pursuant to our discussion, the following information must be completed prior to any action being taken on the above referenced application: 1. All distances, lot information 2. Existing foundation and framing information 3. Water and Sewer connections 4. More clarification/completeness of plans. Please confirm that this application will supersede any previous applications received by this Department on 10/10/95 and 10/27/95. A copy of this application is attached for your convenience. Sincerely, Richard A. Colantuoni, Local Inspector c/R. Nicetta, Bldg. Commissioner SENDER: 'y • Complete items 1 and/or 2 for additional services. 41 • Complete items 3, and 4a & b. • P'nnt your name and address on the reverse of this form so that we can 0 return this card to you. m • Attach this form to the front of the mailpiece, or on the back if space doc; riot permit. r• Write "Return Receipt Requested" on the mailpiece below the article number " • The Return Receipt will show to whom the article was delivered and the date delivered. 3. Article Addressed to: 4a. 1 m I also wish to receive the following services (for an extra fee): > 1. ❑ Addressee's Address N 2. ❑ Restricted Delivery •L Consult postmaster for fee. d le Number cc CL . 4b. Service Type rp ❑ Registered ,-� VVIQIE O1� El 6. SighE n 0 PS Form YJ Certified ❑ Express Mail az ❑ Insured rr ❑ COD 6 ❑ Return Receipt for 05 Merchandise 7. Date of Delivery 8. Addressee's Address (Only if requested w and fee is paid) e co H , December 1991 *U.S.GPO: 1993-352-714 DOMESTIC RETURN RECEIPT UNITED STATES POSTAL SERVICE Official Business PENALTY FOR PRIVATE USE TO AVOID PAYMENT OF POSTAGE, $300 Print your name, address and ZIP Code here here ,,Iov 2 2 14� c C,t/wvl.e,�L O 00 M P 354 489 733 Receipt for Certified Mail No Insurance Coverage Provided tl� IMREDSTATES Do not use for International Mail OOSTAI SERVICE (See Reverse) e t to Ceet,and State ain.4 ZIP Code � 0 p.�/ O 7 Postage Certified Fee Special Delivery Fee Restricted Delivery Fee Return Receipt Showing to Whom & Date Delivered Return Receipt Showing to Whom, Date, and Addressee's Address TOTAL Postage & Fees 7s Postmark or Date M (aVaAgy) 26c®mr'0OOE m6 q _ \ID \\\ 22 §$@ \ §§) \ \ \\\\ \ E (mak dE kj a5@ - \\ \\ \45 �\ �\ §k � �)_ E \> \ §§ )(\ El > E - 2 u § \S § Q {9- °}j fcr )_ k� k}\ \/ k}[U 2§ /- - I *\LU $ -- — —;_§ § c)( &5 a@Im ¥I of a Town of North Andover . OFFICE OF COMMUNITY DEVELOPMENT AND SERVICES 146 Main Street KENNi; rx R. MAHONY North Andover, Massachusetts 01845 Director (508) 688-9533 November 15, 1995 William K. Barrett, Trustee Ten Forty Nine Realty Trust 701C Salem Street North Andover, MA Re: Building Permit #95-122 of 4/12/95 Dear Mr. Barrett: In regard to your letter of 11/14/95 referencing above Building Permit, please be advised of tine following: The subject Permit was issued for vinyl siding and replacement windows. Any additional work at this location has not been permitted and would have been performed without proper building permit. This action would be in violation of 780 CMR, 113.1, which reauires that permits be obtained yrior to any work being performed. in accordance with 780 CMR, 122.1 this will serve as written notification to immediately cease and desist any work not permitted on the premises and IMMEDIATELY file the necessary, permits for interior and chimney demolition work. Pursuant to 780 CMR 126, you may appeal this order within 45 days of the receipt of same. Failure to abate these VIOLATIONS will result in complaints being filed against you as provided for in 780 CMR 121.0. Si cerely, is ara o a Local Inspecto RAC:gb c/R. Nicetta, Bldg. Commissioner METHOD OF SERVICE: Certified Mail, Return Receipt Requested BOARD OF APPEALS 688-9541 BUIL.DINQ* 6M9545 CONSERVATION 68&9530 HEALTH 688-9540 PLANNING 688-9535 Julie Par iao D. Robert Nicaua Michael Howard Sandra Steer Kathlm Bradley Colwell TO: Sandra Starr, Board of Health Agent FROM: Robert Nicetta, Building Commissioner DATE: January 11, 1996 RE: 1049 TURNPIKE STREET - William K. Barrett d/b/a Colonial Village Development Please advise if you are in receipt of a copy of the attached Certificate of Analysis from Biomarine of Gloucester, MA with regard to subject location. If not, I have attached a copy for your comment. In addition, kindly respond as to the present status of your letter regarding potable water at 1049 Turnpike Street. Thank you. /gb 7, A