Complaint,Petition: Town Of Douglas By And Through Kenneth Frasier, Its Building Commissioner vs. Ball, Donald A.

On February 16, 2024 a Complaint,Petition was filed involving a dispute between Town Of Douglas By And Through Kenneth Frasier, Its Building Commissioner, and Ball, Donald A., for Actions Involving the State/Municipality in the District Court of Worcester County.

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Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

COMMONWEALTH OF MASSACHUSETTS

WORCESTER, ss. SUPERIOR COURT DEPARTMENT
CIVIL ACTION NO.

TOWN OF DOUGLAS by and
through KENNETH FRASIER,
its Building Commissioner,

Plaintiff,

DONALD A. BALL, ESQ., Special
Personal Representative of the
Estate of Louis C. Tusino,

Defendant.

CIVIL COMPLAINT

I Nature of the Action

1 This action is brought by the Town of Douglas, acting by and through its Building

Commissioner (generally, the “Town”) to enforce an Order for Demolition and Removal of Non-

Complying Structure (the “Demolition Order,” a true and accurate copy of which is annexed as

Exhibit A). The Demolition Order, which was made by the Town’s Zoning Board of Appeals

(the “ZBA”) on November 5, 2014, was judicially affirmed by the Appeals Court in Tusino v.

Zoning Bd. of Appeals of Douglas, 90 Mass. App. Ct. 89, 92 (2016), and was the subject of other

related litigation by neighboring property owner Joseph Bylinski (“Bylinski”) seeking

enforcement of the Demolition Order (a true and accurate copy of Bylinski’s recorded Second

Amended Complaint seeking enforcement of the Demolition Order is annexed as Exhibit B).!

! See also Bylinski v. Building Comm’r. of Douglas, 97 Mass. App. Ct. 1113 (2020) (unpublished summary decision);
Tusino v. Zoning Bd. of Appeals of Douglas, 90 Mass. App. Ct. 89 (2016); Guaranteed Builders, Inc. v. Zoning Bd.
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

2 Most recently, this Court overturned a decision of the Massachusetts Board of

Electricians’ Appeals and thus reinstated the Town’s denial of an electrical permit at the Property

(the “Electricians’ Board Appeal,” Civil Action No. 218CV01073A). The very existence of the

Electrician’s Board Appeal — i.e., tacit acknowledgement by Tusino that the illegal structure on

the Property ordered demolished by the ZBA in 2014 is still standing — underscores the Town’s

need for injunctive relief from this Court to enforce the Demotion Order.

Il. Jurisdiction and Venue

3 Jurisdiction is properly conferred upon this Honorable Court pursuant to its powers

under G.L. c. 40A, § 7, G.L. c. 212, § 4, and G.L. c. 214, § 1.

4 Venue is proper in Worcester County pursuant to G.L. c. 214, § 5 and GL. ¢. 223,

§§ land 8.

Ii. Parties/Ownership of the Property

5 The Town, acting by and through the Building Commissioner as its Zoning

Enforcement Officer, is a municipal corporation with its principal office located at 29 Depot Street,

Douglas, MA 01516.

6. Defendant Donald A. Ball, Esq., Special Personal Representative of the Estate of

Louis C. Tusino, is a natural person with address of 300 Main Street, Third Floor, Worcester, MA

01608 (the “SPR”).
7
The record owner of the Property is Louis C. Tusino (“Tusino”) as evidenced by a

quitclaim deed recorded in the Worcester County Registry of Deeds at Book 12415, Page 325 (a

true and accurate copy of the aforesaid deed is annexed as Exhibit C).

of Appeals of Douglas, 85 Mass. App. Ct. 1101 (2014) (unpublished summary disposition); Bylinski v. Frasier, 2021
WL 3360933 (Land Ct. 2021); Bylinski v. Lench, 2017 WL 6261528 (Land Ct. 2017); Bylinski v. Reynolds, 2014
WL2719553 (Land Ct. 2014); Guaranteed Buildings, Inc. v. Heany, 2013 WL 1558769 (Land Ct. 2013) Guaranteed
Builders & Developers, Inc. v. Bylinski, 2012 WL676222 (Sup. Ct. 2012) (Worcester Superior Court Docket No.
0985CV02052B).
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

8 Tusino, formerly a resident of the Town, died on or about October 17, 2021.

9 The disposition of Tusino’s estate is the subject of pending litigation in the Probate

and Family Court. (See Worcester Probate and Family Court Docket No. 21P3604EA, a copy of

the docket for which is annexed as Exhibit D.)

10. The SPR was appointed special personal representative of Tusino’s estate by

Order(s) of the Probate and Family Court dated April 13, 2022. The SPR’s appointment was most

recently extended for a period of 90 days on January 23, 2024 (a true and accurate copy of the

aforesaid order is annexed as Exhibit E).

IV. Statement of the Facts ”

11. The Property is in a residential zoning district and thus subject to zoning

requirements that:

(1) buildable lots have road frontage of at least 200 feet and at least 90,000 square
feet of lot area; and (2) the structures built on the lots maintain minimum front yard
setbacks of 50 feet and minimum side yard setbacks of 25 feet.

(SID, Exhibit F, p.2.)
12. The Property does not meet the requirements for the construction of a single-

family dwelling, because the lot has an approximate area of only 6,531 square feet and frontage

of only 47.5 feet. (SID, Exhibit F, p.2.)

13. On July 8, 2008, the Town’s former building commissioner, Adelle Reynolds

(“Commissioner Reynolds”) issued a permit to build a single-family dwelling on the Property.

The structure built upon the Property “is not fully constructed” and “violates the zoning

requirements for side and front setbacks.” (SJD, Exhibit F, p.2.)

? Facts alleged herein which are taken from this Court’s Memorandum of Decision and Order on Plaintiff’s Motion
for Summary Judgment in the related Electricians’ Board Appeal Matter, Town of Douglas, et al. v. Tusino, et al.,
Worcester Superior Court Civil Action No. 2185CV01073A (the “Summary Judgment Decision,” a true and accurate
copy of which is annexed as Exhibit F) are denoted: “SJD, p._.”
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

14. On February 9, 2009, after discovering that a building permit was issued,

Bylinski, the neighboring property owner, asked Commissioner Reynolds to revoke the

building permit she had issued. Commissioner Reynolds refused. On February 25, 2009,

Bylinski appealed that refusal to the ZBA, an appeal which was constructively granted, resulting

in a building permit revocation of June 5, 2009. (SJD, Exhibit F, pp.2-3.)

15. On September 3, 2009, Tusino, through his entity Guaranteed Builders, Inc.

(“GBI”), filed an appeal of the aforesaid constructive permit revocation pursuant to G.L. c. 40A,

§ 17. This Court found that the Property indeed lacks frontage area sufficient for construction of

a single-family home and affirmed the revocation following a two-day jury-waived trial, as was

stated in this Court’s (a) Findings of Fact, Rulings of Law, and Order for Judgment dated

February 2, 2012 and (b) Judgment on Finding of the Court of even date (see Guaranteed

Builders and Developers Inc. v. Haire, et al, 09985CV02052, docket entries 13 and 14) 3

Therefore, the constructive revocation of the building permit issued by Commissioner Reynolds

has long been final and cannot be challenged. (SJD, Exhibit F, p.3; see also Tusino v. Zoning Bd

of Appeals of Douglas, 90 Mass. App. Ct. 89, 90 (2016).)

16. Thereafter, Tusino and his corporation(s) further attempted to legitimize their

illegal construction activities on the Property via a February 14, 2012 application for a variance,

which the ZBA denied on June 19, 2012. Tusino appealed the ZBA’s denial to the Land Court,

the Land Court dismissed the appeal, and the Appeals Court upheld the Land Court’s ruling on

February 21, 2014, noting Tusino had “continued construction of the house in violation of the

zoning ordinance, without a variance, in disregard of the challenge to the building permit.” As

3 While Tusino/GBI filed a Notice of Appeal on March 2, 2012, Tusino withdrew his appeal on August 2, 2012. (See
Guaranteed Builders and Developers Inc. v. Haire, et al, 0985CV02052, docket entries 15 and 16.) Accordingly, the
permit revocation is final, was upheld by this Court on its merits, and is not subject to challenge.
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

the Appeals Court similarly noted in a more recent decision, “despite the successful challenge to

his building permit and his inability to obtain a variance, Tusino had continued construction of

the house.” (SJD, Exhibit F, p.3 (citing Tusino, 90 Mass. App. Ct. at 90.)

17. On November 19, 2014, the ZBA issued its Demolition Order, ordering that the

structure on the Property be demolished within 120 days. Tusino attempted to appeal the

Demolition Order to the Uxbridge District Court and to the Appeals Court, but those Courts

sided with the Board and upheld the Demolition Order. Accordingly, the Demolition Order is

now final. (SJD, Exhibit F, p.4 (citing Tusino, 90 Mass. App. Ct. at 92.).)

18. Notwithstanding the finality of the constructive revocation of Tusino’s building

permit and the finality of the ZBA’s Demolition Order (i.e., both were judicially affirmed),

“Tusino disregarded the several court orders and did not demolish and remove the structure from

the [P]roperty.” (SJD, Exhibit F, p.4.)

19, In May 2018, Tusino again sought a variance and again was denied by the ZBA.

Tusino appealed the denial to the Worcester Superior Court (Civil Action No. 19-00175), and on

November 13, 2019, this Court affirmed the denial. Tusino did not pursue any further appeal

thereafter. (SJD, Exhibit F, p.4.)

20. On February 24, 2021, Tusino caused to be filed with the Town’s building

department an application for a permit to perform electrical work, seeking to “wire new house

complete with furnace and basement” on the partially constructed structure on the Property that

the ZBA ordered demolished in 2014. This permit application, together with a subsequent

electrical permit application Tusino filed in May of 2021, was denied, and ultimately, the latter

denial was reversed by the Board of Electricians’ Appeals and reinstated by this Court by grant

of Summary Judgment dated December 18, 2023. (SJD, Exhibit F, pp.4-9.)
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

21. The Town now files this action to obtain an injunction and thereby effectuate the

ZBA’s final, judicially affirmed Demolition Order with respect to the illegal structure presently

standing upon the Property.

V. Causes of Action

Count 1
Enforcement Demolition Order Pursuant to G.L. c. 40A, § 7

22. The Town repeats and reasserts the allegations set forth in Paragraph Nos. 1 through

21, above, as if fully set forth herein.

23. Pursuant to Section 9.1.2 of the Town’s Zoning Bylaw and G.L. c. 40A, § 7, the

Building Commissioner is charged with enforcement of the Town’s Zoning Bylaw.

24. The structure which is located upon the Property was ordered demolished by the

ZBA in 2014, an order which was judicially affirmed, and accordingly, the Town is entitled to

injunctive relief authorizing the Town to demolish the illegal structure.

WHEREFORE, the Town asks that this Honorable Court: (i) award the Town temporary

and permanent injunctive relief authorizing the Town to enter upon the Property and demolish the

structure(s) upon the Property, thereby bringing the Property into compliance with the Demolition

Order; (ii) award the Town its attorney’s fees and expenses incurred in pursuing enforcement as

aforesaid; and (iii) grant such further and other relief as deemed just and proper.

Vv. Prayer for Relief

For the foregoing reasons, the Town respectfully prays that this Honorable Court grant the

relief requested above.
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

Plaintiff,
by its attorneys,

Dated: February 16, 2024 /s/ Stephen J. Chaplin
Stephen J. Chaplin (BBO# 685571)
Jason R. Talerman (BBO# 567927)
Mead, Talerman & Costa, LLC
730 Main Street, Suite 1F
Millis, MA 02054
774-993-5003
steve @mtclaw yers.com
jay@mtclawyers.com
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

EXHIBIT A
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number
‘

Town of Douglas
Zoning Board of Appeals
29 Depot Street, Douglas, MA 01516
\
T: (508) 476-4000 +TTY 508-476-1619 ¢ F: (508) 476-4012
i

DECISION ON APPEAL AND PETITION FOR ENFORCEMENT.
nd (
ORDER FOR DEMOLITION AND REMOVAL OF NON-COMPLYING '
STRUCTURE
G.L. C. 40A, §87, 8, 14 AND 15

WG pV
PETITIONER: Joseph Bylinski (the “Petitioner”) wil 2
PROPERTY: qe
PROPERTY OWNER:
103 Shore Road (the “Property”)
Louis C. Tusino oN
DATE: November 5, 2014
CASE NO, 2014-10

This issue first arose in 2009 when the Property Owner Louis Tusino or his agent began
to do work on the Property subject to a building permit for a single family house issued
by the Building Commissioner. Shortly after the commencement of work on the
Property, the Petitioner sought revocation of the building permit from the Building
Commissioner, alleging the Property was non-conforming and not entitled to any
grandfathering protection; and that, therefore construction could not comply with the
Zoning Bylaws. The Building Commissioner declined enforcemerit and an appeal to the
ZBA ensued. Such appeal was constructively approved, resulting in the revocation of the
building permit. During these and later proceedings, the Property Owner continued with
the construction of the house on the Property, at his peril.

Several legal proceedings followed. First, the Property Owner appealed the revocation of
his building permit to the Superior Court. After a trial, the Owner lost that case and
judgment was entered in favor of Bylinski, finding that the house was illegal. The Owner
initially appealed that judgment but later dismissed the appeal. At around the same time,
Bylinski filed a separate action in the Land Court seeking an order requiring the
demolition of the house on the Property. That matter was stayed while the Property
Owner sought a variance from the ZBA for the house. The variance was denied and \
Owner appealed first to the Land Court, and later to the Appeals Court. Both such courts
denied the Owner’s appeals. Then, in the Land Court, Bylinski sought a final judgment.
Although Bylinski received a judgment in its favor, concluding that the House was
illegal, the Court stated that an order for demolition was premature and that a request for
an order for demolition would be required.

On June 26, 2014, the Petitioner, via Counsel, wrote to the Building Commissioner to
formally request that “the removal of the building that has been constructed on the
property.” By letter dated September 2, 2014, the Building Commissioner denied the
Petitioner’s request for enforcement.
Decision 14.1105.doc The Town of Douglas is on Eu [Opportunity Provider and
'

(Third) Motion for Summary Judgment
!
Appendix Page 63
}
}
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number
4

ly Town of Douglas
Zoning Board of Appeals
29 Depot Street, Douglas, MA 01516
Ge T: (508) 476-4000 ¢TTY 508-476-1619 ¢ F: (508) 476-4012 i

In review of the facts of this matter, the Board finds that the Property in question does not f
constitute a valid building lot and that the house constructed thereon is illegal. The Board
finds that the Courts have fully concluded that the house is illegal. All rights by any
party to appeal any such judgments have expired. Accordingly, the.ZBA and the
Building Commissioner are foreclosed from concluding that the Property or the house
constructed thereon is legal.

Based upon all of the foregoing facts, the ZBA unanimously finds that the Building
Commissioner was in error by failing to grant the Petitioner’s enforcement request.
Accordingly, the Board hereby unanimously orders and directs, pursuant to its
powers under G.L. c. 40A, §14, that the Property Owner remove or demolish the
house on the Property. In accordance with this Order, the Property Owner shall,
within thirty (30) days that this Order is served upon him, via mail, file for
appropriate permits for the removal and/or demolition of the House; and shall i
complete such demolition and removal within 120 days from the date that this
Order is so served.

This Order may not be construed to require the Town to undertake such removal or
demolition in the event that the Property Owner fails to do so. Nor may this Order limit
the Petitioner’s rights to seek direct injunctive relief in the event that the Property Owner
fails to comply with this Order.

re ue Dated: L/- /9- QOlY

Dh Helly Jd
Ss
Imes

agit
%
“DOUGLAS
NOV
19 2014.
Tepnaresp 1S TOWN CLERK
Johp fombara
5

Filed with the Town Clerk on //1/9./Y

Eileen F, Damore, Asst. Town Clerk

*This Decision may be appealed in accordance with M.G, L., Chapter 40A.
Decision 14.1105.doc The’ Town of Douglass an Equal Opportunity Provider and
foyer

(Third) Motion for Summary Judgment
Appendix. ‘Page 64
\|
{
Date Filed 2/16/2024 3:21 PM
Su rior Court - Worcester
Dodket Number, ,

TOWN OF DOUGLAS
MASSACHUSETTS
_ 01516
TOWN CLERK

Petitioner: Joseph Bylinski
Owner: Louis. Tusino
Address: 103 Shore Road, Douglas, MA 01516
Location: 103 Shore Road, Douglas, MA 01516
Deed Reference: Book: 12415, Page: 325

| hereby certify that a copy of the decision of the Zoning Board
of Appeals of the Town of Douglas related to the application of

JOSEPH BYLINSKI

for an Appeal was filed in this office on
and that no notice of appeal was filed during the twenty (20)
days next day after that date.

Filed with the Town Clerk on

Christine E. G. Furno, Town Clerk Eileen F. Damore, Asst. Town Clerk

‘S:\Pair\cdd\zba\admin\2014-10 Bylinski, 103 Shore Road - Appeal\Notice of Appeal.doc

!
‘
(Third) Motion for Summary Judgment
Appendix Page 65
4
'
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

EXHIBIT B
Date Filed 2/16/2024 3:21 PM Bk: 50741 Pg: 97
Superior Court - Worcester
Docket Number

-
i
COMMONWEALTH OF MASSACHUSETTS
LAND COURT TUF esa Ve
DEPARTMENT OF THE TRIAL COURT
Worcester, ss.

Joseph Bylinski,
UAC
Bk: 50741 Pg: 97
Page: 1 of 4 04/16/2013 01:45 PM WO

Plaintiff

Vv. 0S Misc. No. 408938 (RBF)

Adelle Reynolds, as she is the
Building Commissioner
of the Town of Douglas and
Guaranteed Builders &
Developers, Inc.

Defendants

SECOND AMENDED COMPLAINT

This is an action in the nature of a writ of mandamus to compel the Building

Commissioner of the Town of Douglas to enforce the provisions of the Douglas Zoning Bylaw,

and injunctive relief against Guaranteed Builders and Developers, Inc..

Joseph Bylinski is a resident of Chapel Hill, North Carolina.

Adelle Reynolds is the Building Commissioner of the Town of Douglas, with a principal

place of business at 29 Depot Street, Douglas, Massachusetts.

Guaranteed Builders & Developers, Inc. is a Massachusetts business corporation with a

principal place of business at 14 West Street, Douglas, Massachusetts.

In her capacity as Building Commissioner, Ms. Reynolds is charged with enforcement of

the Zoning By-laws of the Town.

WRI (AHI S- aS
Date Filed 2/16/2024 3:21 PI Bk: 50741 Pg: 98
Superior Court - Worcester
Docket Number

Mr. Bylinski is the owner of property located at 105 Shore Road in Douglas,

Massachusetts, which is improved by a single family residence.

Adjacent to Mr. Bylinski’s property at 105 Shore Road, is a parcel of land identified as

103 Shore Road.

The parcel of land at 103 Shore Road does not meet the requirements for the construction

ofa single family dwelling under the provisions of the Douglas Zoning By-law.

In particular, the Douglas Zoning By-law requires that lots on Shore Road have at least

200 feet of frontage and area of not less than 90,000 square feet in order to qualify for

the construction of a single family dwelling,

The parcel of land at 103 Shore Road has 47.5 feet of frontage and approximately 6,531

square feet of area, substantially less than the amount required.

10 The parcel of land at 103 Shore Road is locted within a subdivision known as Wallum

Lake Terrace, which was created by a series of plans recorded prior to the adoption of

subdivision control by the Town of Douglas.

11 The parcel of land was owned in common with remaining lots in the Wallum Lake

Terrace subdivision by the developer of the subdivision until after the adoption of

subdivision control by the Town of Douglas.

12. The Wallum Lake subdivision has never been approved pursuant to the subdivision

control law.

13 Despite the fact that the parcel of land at 103 Shore Road has substantially less frontage

and area than required by the Zoning By-laws of the Town of Douglas and has never

been approved as a lot pursuant to the subdivision control law, on July 8, 2008, Ms.
‘Date Filed 2/16/2024 3:21 PI Bk: 50741 Pg: 99
Superior Court - Worcester
Docket Number

Reynolds issued Guaranteed Builders and Developers, Inc. a building permit to construct

a single family dwelling on the parcel.

14. On or about February 7, 2009, Guaranteed Builders began excavation at 103 Shore Road

and upon inquiry Mr. Bylinski discovered that a building permit had issued for the

property.

15. On February 9, 2009, Mr. Bylinski requested that Ms. Reynolds revoke the building

permit.

16. By correspondence dated February 19, 2009, Ms. Reynolds refused to revoke the

building permit.

17. On February 25, 2009, Mr. Bylinski filed an application with the Zoning Board of

Appeals of the Town of Douglas appealing from his failure to obtain enforcement of the

Zoning By-laws from the Building Commissioner.

18. On June 5, 2009, Mr. Bylinski’s appeal to the Zoning Board of Appeals was

constructively granted and the building permit revoked.

19. Notice of the grant of his appeal and revocation of the building permit was filed with the

Douglas Town Clerk on June 9, 2009.

20. On July 20, 2009, the Town of Douglas issued Guaranteed Builders a permit to perform

electrical work at the premises, and construction activity continued.

21. On September 3, 2009, Guaranteed Builders and Development, Inc. appealed from the

construction grant and revocation of the building permit.

22. By a Judgment dated January 31, 2012, and entered on February 2, 2012, the Superior

Court affirmed the revocation of the building permit.
Date Filed 2/16/2024 3:21 PM Bk: 50741 Pg: 100
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Docket Number

23. Despite the revocation of the building permit, the building illegally constructed remains

on the premises and Ms. Reynolds has neglected and refused take any action to enforce

the Zoning By-law.

24. WHEREFORE, Joseph Bylinski requests:

a. That Guaranteed Builders and Developers, Inc. be permanently enjoined from

constructing a dwelling on the property at 103 Shore Road, and be ordered to

remove improvements made to the property at 103 Shore Road, Douglas,

Massachusetts.

That an injunction issue directing the Building Commissioner to take such action

as may reasonably be required to compel removal of any improvements made to

the property at 103 Shore Road, Douglas, Massachusetts.

Respectively Submitted
For the Plaintiff
By his attorney,

QS
Henry J. Lane BBO# 283480
Lane and Hamer, P.C.
100 Main Street
Whitinsville, MA 01588
Dated: February 3, 2012 Tel. No. 508-234-4400
hlane@laneandhamer.com
Tm2910.004

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ATTEST: WORC. Anthony J. Vigliotti, Regisier
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

EXHIBIT C
ite Filed 2/16/2024 3:21 PM
perior Court - Worcester
» L
cket Number

Guaranteed Builders and
Developers Inc.
& corporation duly established under the laws of Massachusetts
and having its usual place of business at RFD 311-H West Street, E. Douglas,
of Worcester County, Massachusetts, in consideration of

Nineteen Thousand Five Hundred ($19,500.00)

1
grantsto Louis C. Tusino

2
of King Street, Uxbridge, MA
with quitelaim rovrnanta

J the land in Douglas,
and described as follows:
Worcester County, Commonwealth of Massachusetts, bounded

Beginning at a stake 930 feet south along the west side of Shore Road from
granite bound at the southwest of the beach area as shown on “Plan of Shore
Road and Birch Hill Road” which plan is recorded in the Worcester Registry
of Deeds in Plan Book 206, Plan 117; thence following the west side of said
Shore Road along an arc, 47.5 feet to an iron stake; thence westerly following
7 to an iron stake at the East Shore of
i a radia! line 120 feet, more or less,
Wallum Lake; thence northerly, along the East Shore of Wallum Lake 50 feet,
more or less, to an iron stake; thence easterly along a radial line 455 ft.
more or less, to the point of beginning.

-S
Being the same premises conveyed to Guaranteed Buil ders and Developers Inc.
by deed of Wallum Lake Terrace, Inc, dated September 1, 1989, recorded with
the Worcester Registry of Deeds, Book 12351, Page 96.

3 The above described conveyance does not constitute all or substantially all
setts.
of the assets of the grantor located in the Commonwealth of Massachu
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ite Filed 2/16/2024 3:21 PM .
perior Court - Worcester
cket Number

200 124157266326

In witness Whereof the said Guaranteed Builders and Developers Inc.
presents to be signed, acknowledged and
hag caused its corporate seal to be hereto affixed and these
delivered in ita name and behalf by Ann C. Burnham
its Treasurer/Clerk hereto duly authorized, this 23rd
day of October in the year one thousand nine hundred and eighty-nine

Signed and sealed in presence of

Le
Phil Voue
by Daniel Viera-President
Pout 2 Sex + :
? ~ ‘ i Gh Le ont
Ann C, bu nha m-Treasurer/Clerk -

The Commonwealth
of Haxsachnsetts
Worcester 8, October 23, 1989

and Ann C. Burnham
‘Then personally speared the above na med Daniel Vieira

and acknowledged the foregoing instrument to be the free act and deed of the above named
Daniel Vieira and Ann C. Burnham
before me

4 Nine Ce ty be Gtk
Public
Tustice
of the Peace
‘My commission expires my 2s, wg
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E57; WORC., Anthony J. Vigltotti, Regi
hoe
Ali

ee
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number

EXHIBIT D
Date Filed 2/16/2024 3:21 PM
Superior Court - Worcester
Docket Number __ vc vs nn cn secon
'WO21P3604EA In the matter of: Tusino, Louis Carmen

Case Type:
Estates and Administration
Case Status:
Active
File Date
11/03/2021
DOM Track:

Initiating Action:
Formal Probate of Will with Appointment of Personal Representative
Status Date:
04/14/2022
Case Judge:
German, Hon. Geoffrey R
Next Event:
02/28/2024

Property Information |
01: 516
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we se sc sy
‘All information Party Event ‘Docket “Disposition f

Party information
“Tusino, Louis Carmen
se
nt
Alias
° 10/17/2021 co a coe
Ae arty Attorney

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Document Filed Date

February 16, 2024

Case Filing Date

February 16, 2024

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Complaint,Petition: Town Of Douglas By And Through Kenneth Frasier, Its Building Commissioner vs. Ball, Donald A.

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