On December 01, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
Cbno,
Cbno Dracut.Com,
Cbno Tyngsboro.Com,
Cbno Tyngsborough.Com,
Commonwealth Internet Services,
Redican, Jr,
and
Apollo Group Management, Llc - New York, Ny,
Brown, Gloria J,
Brown, Michael W,
Century 21 Gj Brown Realty, Inc,
Century 21 Real Estate, Llc,
Gj Brown Realty, Inc F K A Cendant Corp,
Realogy Holdings Corp - Madison, Nj,
Refnet,
for Contract / Business Cases
in the District Court of Middlesex County.
Preview
: a SO NL
COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, ss SUPERIOR COURT DEPARTMENT
CIVIL ACTION NO. 1681CV03445 AKA 16-3445
CBNO Raymond R Redican, Jr (CIS) et al yy
PLAINTIFF'S )
v. )
GJ BROWN REALTY, INC., et al., )
, DEFENDANT )
PLAINTIFF'S MASSACHUSETTS GENERAL LAW CHAPTER 268 SECTION 1, SECTION
1A, SECTION 13C MOTION
1. Plaintiff's in 1681CV03445 are refiling the Perjury charges against Attorney Kevin Sean
Sullivan BBO# 547306 pursuant to MASSACHUSETTS GENERAL LAW CHAPTER 268
SECTION 1, SECTION 1A, SECTION 13C of which A main ingredient is the INTENT of
Chelmsford, Massachusetts Atty. Kevin Sean Sullivan BBO# 547306. This is PLAINTIFF'S
MASSACHUSETTS GENERAL LAW CHAPTER 268 SECTION 1, SECTION 1A,
SECTION 13C Perjury MOTION Against Attorney Kevin S. Sullivan BBO#
547306.
2. Honorable Joshua |. Wall ruled the previously filed motion wasnt (titled or) filed pursuant
to any rule of Massachusetts Civil Procedure. Ray Redican Jr. received improper guidance
on how to file the previous perjury motion against Atty. Sullivan. It is however
interesting to point out Hon. Wall's statment ...it was also established plaintiff made a
complaint with the BBO. Hon. Wall goes on to state "The complaint failed to survive thefirst state of BBO scrutiny." The reason the BBO gave Redican (which the court has on
file) was the Superior Court had to first make a finding Kevin Sullivan engaged in
unprofessional conduct or professional misconduct.
3. Possibly Jude Wall is stating the complaint failed to survive the first state of BBO scrutiny
because per his ruling Atty. Sullivan did not act unprofessionally. | disagree and
repectfully pray to this court for a real and detailed ruling regarding the intent of Kevin
Sullivan in consciously knowingly committing premeditated perjury as part of a
calculated deliberate intent to decieve this court as having to do with the material issue
at hand during that part of this case which he (Sullivan) has been successful in doing up
until right now.
4. Without regurgitating the contents of the motion we are resubmitting a mirror copy of
what the court already has from last time except for this new title and these three
pages.
5. Subscribed & Sworn under the Pains & Penalties of Perjury shis/! day of July 2018.
6. CERTIFICATE OF SERVICE
7. |, Raymond R. Redican Jr. (CIS), [on behalf of all Plaintiff('s)] hereby certify on this l o .
, day of July 2018, | served a True & Correct copy of the above upon the parties in this
action by mailing, postage prepaid, to:
Attorney Patrick J. Markey, Esq BBO# 563542
Markey Barrett P.C.
1 Monarch Place
1414 Main St, Suite 830
Springfield, MA 01144
413-273-7362
PMarkey@MarkeyBarrett.com
DEFENDANTS, GJ BROWN REALTY, INC., GLORIA BROWN (deceased/estate of) & Michael Brown.
Atty. Kevin Sullivan (BBO #547306) 9 Fletcher St Suite A Chelmsford MA 01824Gordon Rees Scully Mansukhani LLP
21 Custom House St, 5th Floor
Boston, MA 02110
Jay S. Gregory BBO #546708
857-504-2021 JGregory@GRSM.com
Tara Elizabeth Lynch, Esq. BBO #677831
857-504-2022 TLynch@GRSM.com ,
DEFENDANTS CENTURY 21 REAL ESTATE LLC, REALOGY HOLDINGS CORP., & APOLLO GLOBAL
(Ln fien (cx)
CBNO Raymond R Redican, JR. (CIS)
PO BOX 8416 Lowell, MA 01853 USA
CBNO DRACUT.COM (CIS)
CBNO TYNGSBORO.COM (CIS)
CBNO TYNGSBOROUGH.COM (CIS)
CBNO Commonwealth Internet Services (CIS)
Raymond R. Redican Jr. (CIS)
Document Filed Date
August 01, 2018
Case Filing Date
December 01, 2016
Category
Contract / Business Cases
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Preview
: a SO NL COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, ss SUPERIOR COURT DEPARTMENT CIVIL ACTION NO. 1681CV03445 AKA 16-3445 CBNO Raymond R Redican, Jr (CIS) et al yy PLAINTIFF'S ) v. ) GJ BROWN REALTY, INC., et al., ) , DEFENDANT ) PLAINTIFF'S MASSACHUSETTS GENERAL LAW CHAPTER 268 SECTION 1, SECTION 1A, SECTION 13C MOTION 1. Plaintiff's in 1681CV03445 are refiling the Perjury charges against Attorney Kevin Sean Sullivan BBO# 547306 pursuant to MASSACHUSETTS GENERAL LAW CHAPTER 268 SECTION 1, SECTION 1A, SECTION 13C of which A main ingredient is the INTENT of Chelmsford, Massachusetts Atty. Kevin Sean Sullivan BBO# 547306. This is PLAINTIFF'S MASSACHUSETTS GENERAL LAW CHAPTER 268 SECTION 1, SECTION 1A, SECTION 13C Perjury MOTION Against Attorney Kevin S. Sullivan BBO# 547306. 2. Honorable Joshua |. Wall ruled the previously filed motion wasnt (titled or) filed pursuant to any rule of Massachusetts Civil Procedure. Ray Redican Jr. received improper guidance on how to file the previous perjury motion against Atty. Sullivan. It is however interesting to point out Hon. Wall's statment ...it was also established plaintiff made a complaint with the BBO. Hon. Wall goes on to state "The complaint failed to survive thefirst state of BBO scrutiny." The reason the BBO gave Redican (which the court has on file) was the Superior Court had to first make a finding Kevin Sullivan engaged in unprofessional conduct or professional misconduct. 3. Possibly Jude Wall is stating the complaint failed to survive the first state of BBO scrutiny because per his ruling Atty. Sullivan did not act unprofessionally. | disagree and repectfully pray to this court for a real and detailed ruling regarding the intent of Kevin Sullivan in consciously knowingly committing premeditated perjury as part of a calculated deliberate intent to decieve this court as having to do with the material issue at hand during that part of this case which he (Sullivan) has been successful in doing up until right now. 4. Without regurgitating the contents of the motion we are resubmitting a mirror copy of what the court already has from last time except for this new title and these three pages. 5. Subscribed & Sworn under the Pains & Penalties of Perjury shis/! day of July 2018. 6. CERTIFICATE OF SERVICE 7. |, Raymond R. Redican Jr. (CIS), [on behalf of all Plaintiff('s)] hereby certify on this l o . , day of July 2018, | served a True & Correct copy of the above upon the parties in this action by mailing, postage prepaid, to: Attorney Patrick J. Markey, Esq BBO# 563542 Markey Barrett P.C. 1 Monarch Place 1414 Main St, Suite 830 Springfield, MA 01144 413-273-7362 PMarkey@MarkeyBarrett.com DEFENDANTS, GJ BROWN REALTY, INC., GLORIA BROWN (deceased/estate of) & Michael Brown. Atty. Kevin Sullivan (BBO #547306) 9 Fletcher St Suite A Chelmsford MA 01824Gordon Rees Scully Mansukhani LLP 21 Custom House St, 5th Floor Boston, MA 02110 Jay S. Gregory BBO #546708 857-504-2021 JGregory@GRSM.com Tara Elizabeth Lynch, Esq. BBO #677831 857-504-2022 TLynch@GRSM.com , DEFENDANTS CENTURY 21 REAL ESTATE LLC, REALOGY HOLDINGS CORP., & APOLLO GLOBAL (Ln fien (cx) CBNO Raymond R Redican, JR. (CIS) PO BOX 8416 Lowell, MA 01853 USA CBNO DRACUT.COM (CIS) CBNO TYNGSBORO.COM (CIS) CBNO TYNGSBOROUGH.COM (CIS) CBNO Commonwealth Internet Services (CIS) Raymond R. Redican Jr. (CIS)