Party Statement: Jordan L. Shapiro In his/her capacity Escrow Holder vs. Geer, Doris et al

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                     COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX, ss                                  SUPERIOR COURT
                                               CIVIL ACTION NO.        1881CV02451



JORDAN L. SHAPIRO
        Plaintiff,

Vv.


DANIEL GEER, et al.
        Defendants


 PLAINTIFF IN CROSSCLAIM DANIEL GEER’S AFFIDAVIT IN OPPOSITION
          TO THE ACCOUNTING SUBMITTED BY DORIS GEER


        Now comes Daniel Geer, plaintiff in crossclaim in this case, and submits the

following objections to the affidavit submitted by Doris Geer in response to the Court’s

Order of December 20, 2018:

1. The format is wrong. Doris has submitted a narrative rather than an accounting. The

correct format should be an affidavit that verifies the information on a spreadsheet

showing money in and out, organized by year. Doris told people to pay cash. See

affidavit attached. There are no totals for money paid or received. I never told anyone

not to pay rent. I paid rent for the whole time was living at the house.

2. Crucial details are missing. Who paid the $50,090 in mortgage payments?

3. Doris did not follow the guidelines set forth in the Order. The Order instructs Doris to

itemize taxes, mortgage loan payments, utilities, insurance, maintenance repair,

renovation, upkeep, and who incurred these costs.     She has not li
                                                                              CLERIC   OF  COURTS
                                                                                          CE

                                                                           FOR THE COUN OF MIODLESEX
                                                                                       TY
at the property.

                                                                                FEB 11.2019


                                                                              FuEEP

SIGNED UNDER THE PAINS AND PENALTIES OF PERJURY THIS                      7

DAY OF FEBRUARY, 2019.




                                    Ne Sun            Daniel Geer




                                            By hisA         ys


                                                        4 Cx br
                                            DAVID M HASS (BBO# 542237)
                                            LAW OFFICES OF BURTON J. HASS
                                            640 Main Street
                                            Malden, MA 02148
      2/7                                   781-322-3900
Dated: January-4, 2019



                             CERTIFICATE OF SERVICE

       I, DAVID M. HASS, hereby certify that on this date, I served a copy of the within
document upon all parties by mailing a copy thereof, postage prepaid, to:

Jordan L. Shapiro, Esq.
Shapiro & Hender
P.O. Box 392
Malden, MA 02148

Kenny Mazonson, Esq.
640 Main Street
Malden, MA 02148
.




    640 Main Street
    Malden, MA 02148

    Charles Rotundi, Esq.
    79 State Street
    Newburyport, MA 01959

                                 Hv           AVL.
                              DAVID M. HASS
    Dated: February 7, 2019