On December 27, 2017 a
Party Statement
was filed
involving a dispute between
H1 Lincoln, Inc.,
and
849 South Washington Street, Llc,
849 South Washington Stret Realty Trust Under Declaration Of Trust Dated June 9, 2000, Alfredo Dos Anjos, Trustee,
855 South Washington Street Realty Trust Under Declaration Of Trust Dated October 2, 2008, Alfredo Dos Anjos, Trustee,
865 South Washington Street Realty Trust Under Declaration Of Trust Dated May 14, 1998, Alfredo Dos Anjos, Trustee,
Cooper Avenue Realty Trust Under Declaration Of Trust Dated May 14, 1998, Alfredo Dos Anjos, Trustee,
South Washington Street, Llc,
for Administrative Civil Actions
in the District Court of Hampden County.
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COMMONWEALTH OF MASSACHUSETTS
DEPARTMENT OF THE TRIAL COURT
HAMPDEN, ss.
H1 LINCOLN, INC. D/B/A MAJESTIC
HONDA,
Plaintiff/Defendant-in-Counterclaim
VS.
SOUTH WASHINGTON STREET, LLC,
AND
SUPERIOR COURT
CIVIL ACTION NO. 17-899
849 SOUTH WASHINGTON STREET, Stieoe 5
> . oO,
Defendants/Plaintiffs-in- Fir} cotNry
Counterclaim Map 4 70)
I, Michael G. McDonough, attorney for the plaintiff in the above-captioned matter, on
oath, depose and say:
1.
On February 15, 2019, a copy of the enclosed Plaintiffs Motion to Amend Real
Estate Attachment and for Other Relief Pertaining to Payment of Rent into
Escrow (Memorandum of Law Incorporated) was sent via first-class mail and via
email to the attorneys for the defendants in this action.
Defendants’ Opposition to Plaintiff's Motion to Amend Real Estate Attachment
and for Other Relief Pertaining to Payment of Rent into Escrow was received on
March 4, 2019.
On March 4, 2019, Plaintiffs Reply to Defendants’ Opposition to Plaintiff's
Motion to Amend Real Estate Attachment and for Other Relief Pertaining to
Payment of Rent into Escrow (Memorandum of Law Incorporated) was sent via
first-class mail and via email to the attorneys for the defendants in this action.
In the Reply, the Plaintiff notified the Defendants of the Plaintiff's withdrawal of
its request for the Court’s ordering of payments into an escrow account.
However, the request for an increase in the amount of the real estate attachment
stands.
tow5. This Affidavit is in compliance with Superior Court Rule 9A(b)(2).
Signed under the pains and penalties of perjury, this 4" day of March, 2019.
THE PLAINTIFF,
H1 LINCOLN, INC.,
By Its Attorneys,
c éE G. McDonough, BBO #682128
Egan, Flanagan and Cohen, P.C.
67 Market Street, P.O. Box 9035
Springfield, MA 01102-9035
(413) 737-0260; Fax (413) 737-0121
Email: jie@efclaw.com; mgm@efclaw.com
CERTIFICATE OF SERVICE
I certify that a true copy of the above document was served upon the attorneys of record
for each other party by email and by first-class mail, postage prepaid, on March 4, 2019.
k
Michael G. McDonough
17052-170828\36 1522,
Document Filed Date
March 04, 2019
Case Filing Date
December 27, 2017
Category
Administrative Civil Actions
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COMMONWEALTH OF MASSACHUSETTS DEPARTMENT OF THE TRIAL COURT HAMPDEN, ss. H1 LINCOLN, INC. D/B/A MAJESTIC HONDA, Plaintiff/Defendant-in-Counterclaim VS. SOUTH WASHINGTON STREET, LLC, AND SUPERIOR COURT CIVIL ACTION NO. 17-899 849 SOUTH WASHINGTON STREET, Stieoe 5 > . oO, Defendants/Plaintiffs-in- Fir} cotNry Counterclaim Map 4 70) I, Michael G. McDonough, attorney for the plaintiff in the above-captioned matter, on oath, depose and say: 1. On February 15, 2019, a copy of the enclosed Plaintiffs Motion to Amend Real Estate Attachment and for Other Relief Pertaining to Payment of Rent into Escrow (Memorandum of Law Incorporated) was sent via first-class mail and via email to the attorneys for the defendants in this action. Defendants’ Opposition to Plaintiff's Motion to Amend Real Estate Attachment and for Other Relief Pertaining to Payment of Rent into Escrow was received on March 4, 2019. On March 4, 2019, Plaintiffs Reply to Defendants’ Opposition to Plaintiff's Motion to Amend Real Estate Attachment and for Other Relief Pertaining to Payment of Rent into Escrow (Memorandum of Law Incorporated) was sent via first-class mail and via email to the attorneys for the defendants in this action. In the Reply, the Plaintiff notified the Defendants of the Plaintiff's withdrawal of its request for the Court’s ordering of payments into an escrow account. However, the request for an increase in the amount of the real estate attachment stands. tow5. This Affidavit is in compliance with Superior Court Rule 9A(b)(2). Signed under the pains and penalties of perjury, this 4" day of March, 2019. THE PLAINTIFF, H1 LINCOLN, INC., By Its Attorneys, c éE G. McDonough, BBO #682128 Egan, Flanagan and Cohen, P.C. 67 Market Street, P.O. Box 9035 Springfield, MA 01102-9035 (413) 737-0260; Fax (413) 737-0121 Email: jie@efclaw.com; mgm@efclaw.com CERTIFICATE OF SERVICE I certify that a true copy of the above document was served upon the attorneys of record for each other party by email and by first-class mail, postage prepaid, on March 4, 2019. k Michael G. McDonough 17052-170828\36 1522,