Document for Walter Mcgrail, As President Of The Board Of Trustees Of The Collegiate Charter School Of Lowell vs. Department Of Children And Families et al

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                                Date Filed 6/21/2024 1:19 PM
  ‘Superior Court - Middlesex
  Docket Number 2481CV00888

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                                                      COMMONWEALTH OF MASSACHUSETTS                 |

                         MIDDLESEX, ss.                                        SUPERIOR COURT DEPARTMENT
                                                                             _ CIVIL ACTION NO.: 2481CV00888


                         WALTER MCGRAIL, as PRESIDENT OF THE
                         BOARD OF TRUSTEES OF THE
                         COLLEGIATE CHARTER SCHOOL OF LOWELL                                                      RECEIVED
                              Plaintiffs,
                                                                                                                 6/21/2024
                      ¥.


                      DEPARTMENT OF CHILDREN AND FAMILIES and
                      MARY CULOSI,


                                                           COMPLAINT FOR CONTEMPT

                                 NOW comes the Plaintiff, Walter McGrail, in his representative capacity on behalf of and

                     as President of the Board of Trustees (the “Board”) of the Collegiate Charter School of

                     Lowell       (““CCSL”        or the “School”),   in accordance with the provision     of Rule 65.3

                     Mass.R.Civ.P.          and the    Memorandum     of Decision and Order on Plaintiffs Motion       for

                     Preliminary Junction dated May             15, 2024 and seeks and order of Civil Contempt due to

                     violations      of the preliminary       injunction by the Department   of Children   and Families

                     (“DCF”) and Mary. Culosi,             DCF and Ms. Culosi continue to undermine and interfere with

                     the day-to-day operations of CCSL and the good order of the school.

                     1          Introduction

                     1          “The plaintiff, Walter McGrail, in his capacity as President of the Board of Trustees

                                of the Collegiate Charter School of Lowell ("CCSL"),           filed this action secking

                                declaratory relief against the Department of Children and Families ("DCF") and its

                                employee, Mary Culosi ("Culosi"). The facts that bring the parties before this Court

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