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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

ud tut ye Fe A h COMMONWEALTH OF MASSACHUSETTS TRIAL COURT OF MASSACHUSETTS Yl 4 VReU 19» a B Ss g ~ WOBURN SUPERIOR COURT = DOCKET NO. SRS S33 cin S Ys ; RECEIVED SX 35 ENDPOINT, LLC ) 2/2/2024 uP && Plaintist ) > x ) EX PARTE MOTION FOR x . * ) REALESTATE ATTACHMENT ) Ss > THE WOODS, LLC. ) S BS Defendant ) = Be gs 2 NOW COMES PLAINTIFF, EndPoint, LLC, by its attorneys, CullenCollmore, pile, and 2 3. S respectfully moves this Honorable Court ex parte under Mass. R. Civ. P. 4.1 to be granted an Ret 3 ~& attachment in the amount of SEVENTY-FIVE THOUSAND DOLLARS ($75,000 .00) on all real Re estate owned by Defendant or in which Defendant has an ownership interest. 8x = y As grounds therefor, Plaintiff states that it furnished to Defendant environmental 38 consulting services 1o assist Defendant in its development of property at 94 Butler Avenue in yz S Wakefield Massachusetts between September 2017 and March 2019. Plaintiff has submitted 3 0 invoices to Defendant totaling $49,970.12 for such services and there is no dispute payment is due Me A hoe Hf 75: 000 « and owing to Plaintiff for the services rendered. There is also no dispute thatDefendant 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. £ Il 5 em 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. is Roa | nam pr eoua