Motion-Secondary: The Lowell Five Cent Savings Bank vs. Yenoh Corporation et al

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                                jo.)

COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX, SS. SUPERIOR COURT DEPARTMENT

DOCKET NO: 1681CV00282

LOWELL FIVE CENT SAVINGS BANK

VS

VS

Plaintiff

Filed Aawovary 220) 9

Ass} Chere

A-TUCARD SELF STORAGE LLC AND
TUCARD LLC

)

)

)

)

YENOH CORPORATION AND )
FRANK M. POLAK. )
Defendants )

)

)

)

)

)

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Reach And Apply Defendants

—)

AFFIDAVIT OF COMPLIANCE AND NO OPPOSITION
_ EE MUM ELIANCE AND NO OPPOSITION

I, John J. Hartigan, Esq., being duly swom hereby say and depose as follows:

- [am an attomey licensed to practice law in the Commonwealth of Massachusetts and

represent the Reach and Apply Defendants, Tucard LLC and A-Tucard Self Storage LLC
in the above-entitled matter,

. I served the Reach and Apply Defendants’ Motion to Vacate Judgment and Request for

Hearing upon the parties through counsel of record via my correspondence dated
December 13, 2018, a copy of which is attached hereto as Exhibit 1.

. Thave received no Opposition to the Motion to Vacate Judgment from the Plaintiff,

Lowell Five Cents Saving Bank.

- Ihave received no Opposition to the Motion to Vacate Judgment from the Defendants,

Yenoh Corporation, Frank M. Polak, and FMP Trustee of FMP Realty.

. The time frame within which any Opposition was to be provided has expired.ty

6. Ihave complied with the requirements of Superior Court Rule 9A.

der the penalties of perjury.

KE Bes
ard ALC and A-Tucard Self Storage D)EXHIBIT 1LAW OFFICE OF

JOHN J. HARTIGAN, P.C.
COUNSELLOR ATLAW  ~
97 CENTRAL STREET, SUITE 204

LOWELL, MASSACHUSETTS 01852

. . Telephone: (978) 441-0054

Facsimile: (978) 441-0056
vevi@hart

December 13, 2018
FIRST CLASS MAIL.

Douglas E. Hausler, Esquire _
Lampert, Hausler & Rodman PC
10 North Road

Chelmsford, MA 01824

FIRST CLASS MAIL ~

Maurice P. Mason, Jr. Esquire . ue
147 E. Merrimack Street
Lowell, MA 01852-1208

RE: LOWELL FIVE CENT SAVING BANK
vs. YENOH CORPORATION, ET AL.”
DOCKET NO.: 1681CV00282

Gentlemen:

In furtherance to our respective conversations whercin J related my recent discussions with the
clerk of the L-2 Session, I endlose and serve upon you pursuant to Superior Court Rule 9A the below
listed documents:

* Motion for Reach-And-Apply Defendants, Tucard LLC and A-Tucard Self Storage
LLC, to Vacate Judgment dated October 26, 2018; and

° Request for Hearing

Please return your Opposition, if any, within the time frame dictated by the applicable Rule so
that I may include the same with my filings.

Further be advised that I intend to include in this filing the “9A Package” dated November

ce: ‘Client