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Date Filed 6/27/2024 9:48 PM 5a 6
‘Superior Court - Middlesex
Tle @ Bern
Docket Number
= 4
7 a
\ COMMONWEALTH OF MASSACHUSETTS
ERAS LO *
MIDDLESEX, SS. SUPERIOR COURT DEPT
WOBURN DIVISION
DOCKET NO. (NEW)
- AUBICV@AG
DONALD H. AMES, IIT and
BEHN C. REYNOLDS, on behalf of and for the benefit of
NORTHEAST FACILITY SOLUTIONS, LLC
Plaintiffs
v. RECEIVED MG
METROWEST CLEANING SYSTEMS, INC., 06/27/2024
CONEXUS BUILDING SOLUTIONS, INC.,
ADELINO FERREIRA
Defendants
MOTI ON OF THE PLAIN
e e TIFFS, DONA LD e
H. AMES,
OE ED II,
LU. AND
AND BEHN
BEHN C.
C. REYN OLDS
REYNO LDS,
ON BEHALF OF AND FOR THE BENEFIT OF
NORTHEAST FACILITY SOLUTIONS, LLC.
FOR A PRELIMINARY INJUNCTION - METROWEST CLEAN
ING SYSTEMS, INC.
NOW COME THE PLAINTIFFS, Donald H. Ames, III (“Ames”)
and Behn C. Reynolds
(‘Reynolds”), on behalf of and for the benefit of Northeast Facilit
y Solutions, LLC
(“Northeast”), to respectfully move this Honorable Court to
issue a preliminary injunction
pursuant to Mass.R.Civ.P. 65(b) to prohibit the defendant MetroWest
Cleaning Systems, Inc.
(“MetroWest”), from violating the non-competition agreement
the defendant Adelino Ferreira
(“Ferreira”) signed on September 30, 2023, and to order MetroWest
to cease all business
activities that compete with those of Northeast, within the
restricted territory of the six states of
New England, in as much as MetroWest is the “alter ego” of Ferreira.
See, Alexander &
Alex: ander, Inc. v. Danahv, 21 Mass. App. Ct. 488, 500, 488
N.E.2d 22, 30 (1986).
IN SUPPORT THEREOE, the plaintiffs state that Ferreira mainta
ins control of MetroWest
even though Ferreira sold all of MetroWest’s assets to Northe
ast. In further support, the
Date Filed 6/27/2024 9:48 PM
Superior Court - Middlesex
Docket Number
= Aplaintitts refer this Honorable Court to the Verified Complaint filed concurrently with this
motion.
WHEREFORE, the plaintiffs, Donald H. Ames, III and Behn C. Reynolds, on behalf of and
for the benefit of Northeast Facility Solutions, LLC, request that this Honorable Court issue
a
preliminary injunction pursuant to Mass.R.Civ.P. 65(b) prohibiting the defendant MetroWest
Cleaning Systems, Inc., from violating the terms and conditions of the non-competition
agreement the defendant Adelino Ferreira signed.on September 30, 2023, by ordering Metro West
Cleaning Systems, Inc., to cease all business activities that compete with those of Northeast,
within the restricted territory of the six states of New England.
Respectfully submitted,
The Plaintiffs, Donald H. Ames, ITI, and
Behn C. Reynolds, on behalf of and for the
benefit of Northeast Facility Solutions, LLC
No ‘acility Solutions, LLC
ir att mey,
Dahiel B. Walsh
B.B.O. No. 638261
dwalsh@walshlegal.com
Daniel Walsh & Associates, P.C.
40 Court Street, 3 Floor
Plymouth, MA 02360
Tel. No. (508) 732-0023
Tel. No. (508) 732-0023
Dated: June 28, 2024
Preview
Date Filed 6/27/2024 9:48 PM 5a 6 ‘Superior Court - Middlesex Tle @ Bern Docket Number = 4 7 a \ COMMONWEALTH OF MASSACHUSETTS ERAS LO * MIDDLESEX, SS. SUPERIOR COURT DEPT WOBURN DIVISION DOCKET NO. (NEW) - AUBICV@AG DONALD H. AMES, IIT and BEHN C. REYNOLDS, on behalf of and for the benefit of NORTHEAST FACILITY SOLUTIONS, LLC Plaintiffs v. RECEIVED MG METROWEST CLEANING SYSTEMS, INC., 06/27/2024 CONEXUS BUILDING SOLUTIONS, INC., ADELINO FERREIRA Defendants MOTI ON OF THE PLAIN e e TIFFS, DONA LD e H. AMES, OE ED II, LU. AND AND BEHN BEHN C. C. REYN OLDS REYNO LDS, ON BEHALF OF AND FOR THE BENEFIT OF NORTHEAST FACILITY SOLUTIONS, LLC. FOR A PRELIMINARY INJUNCTION - METROWEST CLEAN ING SYSTEMS, INC. NOW COME THE PLAINTIFFS, Donald H. Ames, III (“Ames”) and Behn C. Reynolds (‘Reynolds”), on behalf of and for the benefit of Northeast Facilit y Solutions, LLC (“Northeast”), to respectfully move this Honorable Court to issue a preliminary injunction pursuant to Mass.R.Civ.P. 65(b) to prohibit the defendant MetroWest Cleaning Systems, Inc. (“MetroWest”), from violating the non-competition agreement the defendant Adelino Ferreira (“Ferreira”) signed on September 30, 2023, and to order MetroWest to cease all business activities that compete with those of Northeast, within the restricted territory of the six states of New England, in as much as MetroWest is the “alter ego” of Ferreira. See, Alexander & Alex: ander, Inc. v. Danahv, 21 Mass. App. Ct. 488, 500, 488 N.E.2d 22, 30 (1986). IN SUPPORT THEREOE, the plaintiffs state that Ferreira mainta ins control of MetroWest even though Ferreira sold all of MetroWest’s assets to Northe ast. In further support, the Date Filed 6/27/2024 9:48 PM Superior Court - Middlesex Docket Number = Aplaintitts refer this Honorable Court to the Verified Complaint filed concurrently with this motion. WHEREFORE, the plaintiffs, Donald H. Ames, III and Behn C. Reynolds, on behalf of and for the benefit of Northeast Facility Solutions, LLC, request that this Honorable Court issue a preliminary injunction pursuant to Mass.R.Civ.P. 65(b) prohibiting the defendant MetroWest Cleaning Systems, Inc., from violating the terms and conditions of the non-competition agreement the defendant Adelino Ferreira signed.on September 30, 2023, by ordering Metro West Cleaning Systems, Inc., to cease all business activities that compete with those of Northeast, within the restricted territory of the six states of New England. Respectfully submitted, The Plaintiffs, Donald H. Ames, ITI, and Behn C. Reynolds, on behalf of and for the benefit of Northeast Facility Solutions, LLC No ‘acility Solutions, LLC ir att mey, Dahiel B. Walsh B.B.O. No. 638261 dwalsh@walshlegal.com Daniel Walsh & Associates, P.C. 40 Court Street, 3 Floor Plymouth, MA 02360 Tel. No. (508) 732-0023 Tel. No. (508) 732-0023 Dated: June 28, 2024