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  • Endpoint, Llc vs. The Woods, Llc Construction Dispute document preview
  • Endpoint, Llc vs. The Woods, Llc Construction Dispute document preview
						
                                

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.