Professional Documents
Culture Documents
12 FM 2 Lu: Sherry Leventhal, Dale Adler, Stacey Mccarthy
12 FM 2 Lu: Sherry Leventhal, Dale Adler, Stacey Mccarthy
1 •' "■ V
COMMONWEALTH OF MASSACHUSETTS
12 fM 2= lU
NORFOLK,ss. SUPERIOR COURT DEPT.
T! ' F.H ' •■' OF THE TRIAL COURT
' "H'jKi'ulK C'j'JNl '■ Case No. 18-1517
Plaintiffs.
V.
Defendants,
36953149.1
Restrains Defendants, their officers, agents, servants, employees, attorneys, and
all other persons in active concert or participation with them who receive notice
expenditures: (a) for schematic or other design of a ninth school that will rely on
the use of "Baldwin Park" (aka Baldwin Playground) for recess, physical
education, or other educational purposes; (b) for any action to develop a ninth
school on the site called "Baldwin North" unless and until the use of "Baldwin
Constitution ("Article 97"); (c) for any action to develop a ninth school on the site
called "Baldwin North" unless and until the use of "Baldwin Park" for recess,
applicable law, and (d) that will otherwise continue or promote the development
of a ninth school at Baldwin North, including but not limited to seeking a debt
Memorandum In Support of Emergency Motion for Preliminary Injunction and the Affidavit of
Pursuant to Superior Court Rule 9A(d)(1), the undersigned counsel for Plaintiffs hereby
certify that they conferred with Town Defendants' counsel on March 11, 2019 and counsel to the
36953149.1
individual Oak Street defendants on March 12, 2019 regarding the subject of this Motion. The
Town Defendants oppose the relief requested herein and the individual defendants take no position
on the motion. Town Defendant's counsel expressed a preference for a hearing on Plaintiffs'
Emergency Motion on March 27, 2019, with Defendants' opposition, if any, due March 25, 2019.
The undersigned counsel for Plaintiffs hereby certifies that they have made a good faith effort to
contact by telephone and confer with counsel for Defendant Jonathan Levi Architects LLC
regarding the subject of this Emergency Motion, but received no response as of the time of filing.
By: 77,
Stephen Wald (BBO #512350)
Robert F. Callahan, Jr. (BBO #685728)
800 Boylston Street, Suite 2500
Boston, Massachusetts 02199
Tel: (617) 267-2300
Fax: (617) 267-8288
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing was mailed, postage prepaid, and emailed on
this 12th day of March, 2019 to the attorneys of record of each other party.
Stephen Wald
36953149.1