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Date Filed 12/9/2022 4:03 PM
Superior Court - Middlesex
Docket Number 2181CV01362
L2
COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, ss. SUPERIOR COURT DEPARTMENT
DOCKET NO. 2181-CV-01362
MAPLE RIDGE ESTATES HOMEOWNERS
ASSOCIATION TRUST, by its Trustees,
Plaintiff,
Vv. RECEIVED
12/9/2022
NORRIS A. SCONDRAS
AND ANDREA SCONDRAS,
Defendants,
PLAINTIFF’S MOTION FOR
ASSESSMENT OF DAMAGES
The Plaintiff, the Maple Ridge Estates Homeowners Association Trust, by its Trustees,
by its Attorneys, pursuant to Mass. R. Civ. P. 55, hereby states that this Honorable Court has
entered Default Judgments against the Defendants for the relief sought in its Complaint on
November 9, 2022. The Default was pursuant to the Defendants having failed to answer and/or
defend this action.
Furthermore, the Plaintiff, pursuant to pursuant to Mass. R. Civ. P. 55(b)(2), 54(b) and
55(b)4, moves that this Honorable Court assess damages and enter findings and orders, in the
form attached hereto, with regard to the following: (1) as damages, the amount of the
homeowners association trust’s lien, including collection costs, pursuant to the Declaration of
Trust and the Rules and Regulations of the Association; and (2) advertising and sale of the
home/lot within the association. In support thereof, the Plaintiff attaches the Affidavit of Trustee
in Regard to Documents; and the Affidavit of Trustee in Regard to Calculation of Damages.
Date Filed 12/9/2022 4:03 PM
Superior Court - Middlesex
Docket Number 2181CV01362
WHEREFORE, the Plaintiff respectfully requests that this Honorable Court assess
damages, and enter Findings and Orders.
Respectfully submitted,
Plaintiff,
Maple Ridge Estates Homeowners
Association Trust, by its Trustees
By its Attorneys,
A] Patrick1. Gamelin, Esq.
Frank A. Flynn, Esq.
BBO # 551668
Patrick R. Gamelin, Esq.
BBO # 663855
Flynn Law Group
185 Devonshire Street, Suite 401
Boston, MA 02110
(617) 988-0633
frank@flynnlaw-ne.con
patrick(@flynnlaw-ne.com
DATE: December 6, 2022
Date Filed 12/9/2022 4:03 PM
Superior Court - Middlesex
Docket Number 2181CV01362
CERTIFICATE OF SERVICE
I, Patrick R. Gamelin, Esq., Attorney for the Plaintiff, hereby certify this 7th day of
December, 2022, that I have served the Defendants Norris A. Scondras and Andrea Scondras,
with a copy of the Plaintiff's Motion for Default Judgment, Assessment of Damages, and Entry
of Findings and Orders, by mailing a copy of the same, first class mail, postage prepaid, to the
Defendants, Norris A. Scondras and Andrea Scondras, at 44 Shakespeare Street, Tyngsboro, MA
01879, with Notice that the Middlesex County Superior Court, will thereafter notify the parties
by first class mail of the hearing date and time for said Motion.
sf Patrick2. Gamelin, Cay,
Patrick R. Gamelin, Esq.
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Date Filed 12/9/2022 4:03 PM Superior Court - Middlesex Docket Number 2181CV01362 L2 COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, ss. SUPERIOR COURT DEPARTMENT DOCKET NO. 2181-CV-01362 MAPLE RIDGE ESTATES HOMEOWNERS ASSOCIATION TRUST, by its Trustees, Plaintiff, Vv. RECEIVED 12/9/2022 NORRIS A. SCONDRAS AND ANDREA SCONDRAS, Defendants, PLAINTIFF’S MOTION FOR ASSESSMENT OF DAMAGES The Plaintiff, the Maple Ridge Estates Homeowners Association Trust, by its Trustees, by its Attorneys, pursuant to Mass. R. Civ. P. 55, hereby states that this Honorable Court has entered Default Judgments against the Defendants for the relief sought in its Complaint on November 9, 2022. The Default was pursuant to the Defendants having failed to answer and/or defend this action. Furthermore, the Plaintiff, pursuant to pursuant to Mass. R. Civ. P. 55(b)(2), 54(b) and 55(b)4, moves that this Honorable Court assess damages and enter findings and orders, in the form attached hereto, with regard to the following: (1) as damages, the amount of the homeowners association trust’s lien, including collection costs, pursuant to the Declaration of Trust and the Rules and Regulations of the Association; and (2) advertising and sale of the home/lot within the association. In support thereof, the Plaintiff attaches the Affidavit of Trustee in Regard to Documents; and the Affidavit of Trustee in Regard to Calculation of Damages. Date Filed 12/9/2022 4:03 PM Superior Court - Middlesex Docket Number 2181CV01362 WHEREFORE, the Plaintiff respectfully requests that this Honorable Court assess damages, and enter Findings and Orders. Respectfully submitted, Plaintiff, Maple Ridge Estates Homeowners Association Trust, by its Trustees By its Attorneys, A] Patrick1. Gamelin, Esq. Frank A. Flynn, Esq. BBO # 551668 Patrick R. Gamelin, Esq. BBO # 663855 Flynn Law Group 185 Devonshire Street, Suite 401 Boston, MA 02110 (617) 988-0633 frank@flynnlaw-ne.con patrick(@flynnlaw-ne.com DATE: December 6, 2022 Date Filed 12/9/2022 4:03 PM Superior Court - Middlesex Docket Number 2181CV01362 CERTIFICATE OF SERVICE I, Patrick R. Gamelin, Esq., Attorney for the Plaintiff, hereby certify this 7th day of December, 2022, that I have served the Defendants Norris A. Scondras and Andrea Scondras, with a copy of the Plaintiff's Motion for Default Judgment, Assessment of Damages, and Entry of Findings and Orders, by mailing a copy of the same, first class mail, postage prepaid, to the Defendants, Norris A. Scondras and Andrea Scondras, at 44 Shakespeare Street, Tyngsboro, MA 01879, with Notice that the Middlesex County Superior Court, will thereafter notify the parties by first class mail of the hearing date and time for said Motion. sf Patrick2. Gamelin, Cay, Patrick R. Gamelin, Esq.