On February 02, 2021 a
Hearing
was filed
involving a dispute between
Endpoint, Llc,
and
The Woods, Llc,
for Contract / Business Cases
in the District Court of Middlesex County.
Preview
COMMONWEALTH OF MASSACHUSETTS
MIDDLESEX, SS. TRIAL COURT OF MASSACHUSETTS
WOBURN SUPERIOR C T
DOCKET NO. NV
) RECEIVED
ENDPOINT, LLC ) 2/2/2021 IP
Plaintiff ) .
) EX PARTE MOTION FOR
-v- ) REAL ESTATE ATTACHMENT
) r
THE WOODS, LLC. )
Defendant )
)
NOW COMES PLAINTIFF, EndPoint, LLC, by its attorneys, CullenCollmore, plic, and
respectfully moves this Honorable Court ex parte under Mass. R. Civ. P. 4.1 to be granted an
attachment in the amount of SEVENTY-FIVE THOUSAND DOLLARS ($75,000.00) on all real
estate owned by Defendant or in which Defendant has an ownership interest.
As grounds therefor, Plaintiff states that it furnished to Defendant environmental
consulting services to assist Defendant in its development of property at 94 Butler Avenue in
Wakefield Massachusetts between September 2017 and March 2019. Plaintiff has submitted
invoices to Defendant totaling $49,970.12 for such services and there is no dispute payment is due
and owing to Plaintiff for the services rendered. There is also no dispute that Defendant promised
to pay Plaintiff for the services rendered and that, despite this promise, Defendant has failed to pay
Plaintiff. Defendant agreed that interest of 1.5% per month would accrue on outstanding invoice
balances and that it would pay Plaintiff's costs of collection, including reasonable’ attorneys’ fees.
See Affidavit of Richard J. Wozmak, filed herewith. When final judgment enters in this action, it
is anticipated that Defendant will owe Plaintiff more than $75,000.00. 88, Superior Court
The within matter is set down for hearing
nin on 2-9 aL. d-Counroam via 200M
at 109 3p 1u019a. 2408-9 420
Attested,
Avststaiis Clann
& Haagen J.
Document Filed Date
February 02, 2021
Case Filing Date
February 02, 2021
Category
Contract / Business Cases
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