13 CHERRY STREET, #1 - DOCUMENTS-SALEM DISTRICT COURT LA ROSA/TOLAND LAW OFFICES
2 MAIN STIZ 17 UT /SUUP"325
ST'ONEIIAM, MASSAUJUSE"ITS 02180
FAX:(781)933-0145
LTLawOffice@ aol.com
PETER T. TOLAND, ESQ.
Direct Line:(781)933-1726
November 20, 2025
Keeper of Records, c/o RECEIVE®
Salem Board of Health
98 Washington Street NOV 2 5 2025
Salem, MA 01970 CITY OF SALEM
BOARD OF HEALTH
Re: Kristin Rydgren v. Gregory Curtin
Civil # 2136 CV 348 (Salem District Court)
Dear Sir/Madam:
The above-named matter will be coming up for Trial on December 16,2025 at 9AM, at the
Salem District Court,56 Federal Street,Salem,MA 01970. A copy of the re-scheduled Trial notice
is enclosed with a copy of the original Subpoena for your attendance, served on you previously,for
you to produce certified copies of the records requested in the Subpoena. This letter will serve to
confirm our reminder call to your office that the subpoena for your testimony at Trial in the above-
referenced matter is still in effect.
We will notify you if the Trial date is rescheduled or if your testimony is not required on the
first day of the trial. Thank you for your assistance in this matter.
Very tryl ours,
Peter T. Toland
PTT/tp
Encl. As noted
Via Certified Mail, Return Receipt Requested
DOCKET NUMBER Trial Court of Massachusetts
Jury Trial (CV) Order 2136CV000348 Department
CASE NAME Kristin Rydgren v. Gregory Curtin
ATTORNEY(OR PRO SE PARTY)TO WHOM THIS COPY OF TRIAL ORDER IS ISSUED COURT NAME&ADDRESS
Peter T Toland, Esq. Salem District Court
LaRosa/Toland Law Offices 56 Federal Street
2 Main St Salem, MA 01970
SUITE 325
STONEHAM, MA 02180
DATE&TIME JURY TRIAL IS SCHEDULED JUDGE ISSUING ORDER
Jury Trial (CV)
COURT CONTACT PERSON
12/1612025 at 09:00 AM
COURT CONTACT PERSON PHONE NUMBER
Jury Trial Session
After pre-trial conference/conciliation and upon scheduling of this matter for(Jury Trial (CV)) at the above named court on the
date and time indicated above, it is ORDERED as follows:
1. Witness Lists: Counsel for each party shall submit a list of witnesses expected to testify at trial, containing the name
and address of each prospective witness, to the trial judge at the beginning of the trial. Persons not included in such lists
may be precluded from testifying, in the discretion of the trial judge.
2. Agreed Exhibits: Counsel for each party shall confer in advance of the trial for the purpose of agreeing to exhibits for
trial. All agreed exhibits shall be pre-marked by counsel with exhibit labels bearing numerical designations (i.e. Exhibit 1,
Exhibit 2, etc.). Counsel shall submit a list of Agreed Exhibits, containing the exhibit numbers and summary description
of the exhibits, to the trial judge at the beginning of the trial.
3. Proposed Exhibits: All proposed exhibits on which counsel do not agree shall be pre-marked by counsel for the offering
party with exhibit labels bearing alphabetical designations for identification (i.e. Plaintiffs Exhibit A for ID, etc.). Each
counsel shall submit a list of proposed exhibits, containing the exhibit letters and summary descriptions of the exhibits, to
the trial judge at the beginning of the trial. Any exhibit offered at trial which is neither agreed to nor identified on the
proposed exhibits list may be precluded, in the discretion of the trial judge.
4. Stipulations: Counsel for each party shall confer in advance of the trial for the purpose of stipulating to all material facts
which are not in dispute. Counsel shall submit a list of any stipulations to the trial judge at the beginning of the trial.
5. Audio-Visual Expert Witness Depositions for Trial: To reduce the expense of litigation and to avaoid delay of trial
because of unavailability of expert witnesses, leave is hereby granted for any party, upon notice to opposing counsel and
in accordance with Mass. R. Civ. P. 30A(m),to conduct audio-visual depositions of their treating physician or other expert
witnesses in lieu of oral testimony at trial. Notwithstanding Mass. R. Civ. P. 30A(m)(2) & (4), notice of the audio-visual
deposition may be served simultaneously with service of the witness'curriculum vitae and written report, and evidentiary
objections shall be filed with the trial judge at the beginning of the trial. Any objections to this procedure shall be filed and
heard as discovery motions in advance of the trial date.
6. Summaries of Voluminous Exhibits: Counsel are encouraged to prepare summaries of voluminous exhibits, such as
medical records and bills, to assist the trial judge's review of the facts. See Proposed Mass. R. Evid. 1006 (1980).
7. Non-Massachusetts Authorities: Counsel who submit any requested rulings of law,jury instructions or memoranda of
law which cite federal or other non-Massachusetts cases and statutes are requested to append copies of such cases or
statutes for the convenience of the trial judge.
8. Proposed Jury Instructions: In cases to be tried to a jury, counsel are directed to file any requested jury instructions
with the court before the trial begins, without prejudice to supplementation of such request at the close of the evidence.
For the convenience of the trial judge, requested jury instructions shall be consecutively numbered with instructions
concerning separate topics listed on separate pages.
9. Continuances: To expedite decision by the Justice assigned to the session, or, if that J.ustice is not available, by the
First Justice, any motions for continuance of the trial date shall include affidavits of counsel in accordance with Mass. R.
Civ. P.40 and shall be sent directly to the attention of the court contact person named above. Trial dates may be
continued for good cause only.
10.. Settlement: Counsel in cases which settle before the trial date shall notify the court contact person named above to
permit the scheduling of other cases for trial.
DATE ISSUED CLERK-MAGISTRATE
06/25/2025 C-M Brian J Costa
043:02/22/2021 www.mass.gov/courts Date/Time Printed: 06-25-2025 11:04:50
f
COMMONWEALTH OF MASSACHUSETTS
ESSEX,ss. SALEM DISTRICT COURT
CIVIL No. 2136 CV 348
KRISTIN RYDGREN,
Plaintiff
v.
GREGORY CURTIN,
Defendant
SUBPOENA FOR APPEARANCE AT TRIAL/
SUBPOENA DUCES TECUM
TO: KEEPER OF THE RECORDS/
Salem Board of Health
98 Washington Street
Salem, MA 01970
YOU ARE HEREBY REQUIRED, in the name of the Commonwealth of Massachusetts,to appear
before the Salem District Court, held at 56 Federal Street, Salem Massachusetts, within and for
the Commonwealth of Massachusetts on or before the 20' day of May, 2024 at 9:00 a.m., and
from day to day thereafter,until.the action hereinafter named is heard by said court,to give evidence
of what you know relating to a civil action then and there to be heard and tried between the above-
named parties, and you are further required to bring the item(s) listed in the accompanying
"Attachment to Subpoena Duces Tecum"with you.
HEREOF FAIL NOT,as you will answer your default under the pains and penalties of the law in that
behalf made and provided.
DATED AT Stoneham, Massachusetts, the day of April, 2025.
Lillian LaRosa,Notary Public
---My'commission expires: 1.1/20/2026
PLEASE NOTE: ALL RECORDS REQUESTED HEREIN ARE TO BE DELIVERED TO
THE OFFICE OF ATTORNEY PETER T. TOLAND, AT LA ROSA/TOLAND LAW
OFFICES,2 MAIN STREET,SUITE 325,STONEHAM,MA 02180 BEFORE THE ABOVE-
NOTED TRIAL DATE, PLEASE CALL 781-933-1726 IF YOU HAVE ANY QUESTIONS
REGARDING THIS SUBPOENA.
1
I
i
1
ATTACHMENT TO SUBPOENA DUCES TECUM
You are required to bring with you the following documents/certified,true and complete copies of
the following documents at the time and place specified in the attached Subpoena:
Certified, true and complete copies of all state Sanitary Code inspection reports pertaining
to the property at 13 Cherry Street#1, Salem, MA 01970, Inspection date: April 29, 2019
Conducted by Sanitarian Janice Arta and directed to the property owner,Gregory Curtin,of
36 Glendale Avenue, Marblehead,MA 01945.
COMMONWEALTH OF MASSACHUSETTS
Salem District Court
Docket/Case/esummons ID No:2136CV348
I hereby certify and return that today,April 17,2024, at 12:05 PM, I summoned the within named witness Keeper of Records,City of Salem-
Board of Health to appear and give testimony(or produce)as within directed, by delivering in hand to Maureen Davis, person authorized to
accept at the time of service, a true and attested copy of the within Subpoena.Said service was effected at: City of Salem-Board of Health, 98
Washington Street, Salem, MA,01970.
Sig d un,V the pains and penalties of perjury today,April 17,2024. ,
Ch�isropher P. Chigas,Constable
& Disinterested Person over Age 18.
Capitol Constable Service, LLC Service:$50.00
29 Lowell Street,Suite 3
Peabody, MA,01960
800-977-0427 978-977-0427 Business
978-977-0122 FAX
http://constableservice.com
2
..o, t„ oDg 0 w 0
0? O 3 ps T ° 0.5 * m (�
�1 m to (� 3 o0 m0 m
n �q
p COS S: a _a � m M � O m
'� 9 0
ru OD
1 -.I W � aC maa 2 � 47, m
[n 4h. m
o om v mM N
CD Ln
,
Er 3
IFm .
O
ro
CD W m fit. O
w W m
M O
M - SU 06 A9
.�. ,� CD
ay ni
f" BK �tnm� �y ]7 p M
_CD
ru
a � o
Ir
CD ' FL
o m �' ' _ T PU
CD
CIL
art ... O
Z H
3 ❑❑ ❑❑❑ m;w 0
amm onmz f 3 �1
r�o
n
m �cc�m 0
Fa� m3 p�
c O n m ® ❑❑
° o o� 3 3- ❑❑
° c R'a E 1- oz o y D
m Z � � � ° N oCLCD
m
6Z-5Z l L09d bZ£Zg
ss
�P Usto
9ZOZ 'OZ AON
L08W dW `NkineOM
woq A-tot
OlVd 3E)F/1SOd S n
CITY OF SALEM, MASSACHUSETTS
BOARD OF HEALTH
98 WASHINGTON STREET,3R°FLOOR
SALEm,MA 01970
TEL. (978)741-1800
KIMBERLEY DRISCOLL health(a?salem.com DAVID GREENBAUM,RS
MAYOR HEALTH AGENT
June 7, 2019
Harold Nunez
13 Cherry Street#1
Salem, MA 01970
Dear Mr. Nunez:
In response to a complaint from you regarding sanitary code violations in your apartment located at 13
Cherry Street#1, Salem, MA the Salem Board of Health conducted an inspection April 29, 2019 and cited
several violations. We ordered the landlord to correct these violations.
Your landlord, Gregory Curtin, has made several attempts to correct the violations only to be refused
access to the unit by you.
As you are not allowing the landlord to correct the violations you are now in violation of the Board of Health
order and the State Sanitary Code.
As such, the Salem Board of Health considers this matter closed and will take no further action at this time.
Please feel free to contact me should you have any questions or concerns.
For thum Board of alth
l
. A
David Greenbaum
Health Agent
Cc: Gregory Curtin
1 i n W1,u kj
CITY OF SALEM, MASSACHUSETTS
BOARD OF H&-�LTH
98 WASHINGTON STREET,3"°FI OOIt Prevdn promote.ProtOet.
T[IL. (978)741-1800
KIMBERLEY DRISCOLL health ti__salem.com
DAVLU GREENBAUM,Its
MAYOR HEALTH AGENT
April 30,2019
Gregory Curtin
36 Glendale Avenue
Marblehead,MA.01945
VIA CERTIFIED MAIL: 7012 3050 00012959 8433
Dear Sir/Madam
In accordance with Chapter 111,Sections 127A and 127B 9f the Massachusetts General Laws, 165 CMR 400.000;
State Sanita4y Code,Chapter 1: General Administrative Procedures and 105 CMR 41.0.000: State Sanitary Code,
Chapter 11: Minimum Standards of Fitness for Human Habitation,an inspection was conducted of the property 13
Cherry Street#1 permitted by occupant Harold Nuilez conducted by Janice Orta,Sanitarian on April.29,2019
at 11:00 am. ,
Notice: if this rental unit is occupied by a child or children under the age of 6 years,it is the property owner's
responsibility to notify tenants of lead related reports and tests,and to ensure that this unit complies fully with 105
CMR 460:000:Regulations for Lead Poisoning Prevention and Control. For further information or to request an
inspection,contact the Salem Board of Health at 978-741-1800.
You arc hereby ORDERED to make a good-faith effort to correct the violations listed on the enclosed inspection
report and to take all positive action to prevent these-violations from occurring again in the future.
Failure on your part to comply within the time sp�cified on the enclosed inspection report will result in a complaint
being sought against you in Trial Court. Time for compliance begins with receipt of this Order.
Should you be aggrieved by this Order,you have.the right to request a hearing before the Board of Health. A
request for said hearing must be received in writing in the office of the Board of Health within 7 days of receipt of
this Order. At said hearing,you will be given an opportunity to be heard and to present witness and documentary
evidence as to why this Order should be modified or withdrawn.You may be represented by an attorney. Please
also be informed that you have the right to inspect and obtain copies of all relevant inspection in investigation
reports,orders and other documentary information in the possession of this Board,and that any adverse party has the
right to be present at the hearing.
Please be advised that the conditions noted may enable the occupant(s)to use one or more of the statutory remedies
available to them as outlined in the enclosed inspection report form.
For the Board of Health Reply To•
l
Davi /{j Jan
�u 1�
Health Agent Sanitarian
cc: Tenant
ou a Tate '
CM Oti S.A -m. MAS.SACH'US�E',-urs '
BcmRD OF HE-UM-1 f
98 WASRINGTON STREF.'r,3R"FL(7OR pPublkHe fth
,rm.. (978)741-1800 ,
KIMBERLEY DRISCOLL healthAsalem.com,
MAYOR D,1VID GREI NBAUM,RS
HE ALTII AGENT
State Sanitary: Code, 'Chapter II : 10.5 CAR 410.000
Minimum Stapdfiards of Fitness for Human Habitation'
Occupant: Harold Nunez Occupant Phone: (978) 751-2596
Occupant Address: 1'3 Cherry Street#1
Salem, MA. 01970
Owner,Address: 36 Glendple Avenue Owner/Manager: Gregory Curtin
Marblehead, MA. 01945
Inspection Date: April 29, 2019 Inspection Time: 11:00 am
Conducted By: Janice Orta Accompanied By: Occupant ()
Specified Time Re #6410. Violation(s)
Based upon a tenant complaint°a permitted inspection was conducted in
t accordance with Article II of the State Sanitary Code, 105 CMR 410.000. Upon
Inspection the followin were noted: . '
24 Hours <351 Light in living room currently not working. Repair or replace light. Owner has 24
hours to correct violation.
24 Hours .500 Dropped ceiling in bathroom has a stain indicating a possible leak. Repair leak
so that is no longer leaking from above and replace stained dropped ceiling tile.
Owner has 24 hours to correct_ violation.
7 Days .500 Ceiling above dropped ceiling has a hole in the plaster. Fix and repair ceiling
plaster so that is in good condition. Owner has 7 days to orrect violation.
7 Days .500 Hallway wall to the right is cracked and loose. Repair wall so that is in good
condition. Owner has 7 days to correct violation.
7 Days .351 Outlet located in the hallway at the bottom next to the dining room has a broken
outlet cover. Repair of replace outlet cover so that is in good condition. Owner
has 7 days to correct violation.
24 Hours .500 Water'damage in bedroom near the dining room located above window to the
left. Repair leak and repaint ceiling. Owner has 24 hours to correct violation.
7 Days .500 Chipping paint in dining room by the window. Scrape and repaint ceiling so that
is in good condition. Owner has 7 days to correct violation.
24 Hours .550 (B) Mice droppings found underneath kitchen sink cabinet. Owner is to hire a
professionally licensed exterminator. Owner must send extermination report to
the Salem Board of Health after the extermination has taken place.
Exterminator is to return as often as needed to rid the building of mice.
Owner has 24 hours to correct violation. Owner has 24 hours to correct violation.
7 Days .351 Outlet by the kitchen sink is missing an outlet cover. Add a cover so that is in
good condition. Owner has 7 days to correct violation.
7 Days .500 Kitchen ceiling is unfinished. Fix and repair ceiling so that is in good conditions.
Owner has 7 days to correct violation.
24 Hours .500 Pipe located in the basement in currently leaking. Fix and repair leaky pipe so
Ua d be a 'true CaPY
that it is in good working order.. Owner has 24 hours'to correct violation.
One or more of the above violations may endanger or materially impair the health, safety and well-being of the
occupant(s)
Code Enforcement Inspector
Este es un document legal importante. Puede que afecte susiderechos. Puede adqulhruna traduccion de esta forma. ,
A
Tli
a
i
( COPY
MEMO
Date: June 24, 2019
To: Salem Police Department
From: David Greenbaum, Health Agent
RE: 13 Chen Street#1
This memo is to document conditions at 13 Cherry Street, #1, previously occupied
by Harold Nunez and family.
On Thursday, June 20, 2019 at 11:00am David Greenbaum, Health Agent and
Janice Orta, Sanitarian, accompanied by Officers Phelan and Rondinelli of the
Salem Police Department conducted a re-inspection of the premises located at 13
Cherry Street #1, Salem, MA. Also present was the property owner, Greg Curtin
and Mr. Harold Nunez who was in the process of moving out. This inspection was
conducted at the request of Mr. Nunez's attorney Neil McCarthy.
Upon entering the apartment Mr. Nunez pointed out a large hole in the horse hair
plaster in the living room. Mr. Nunez stated that this damage was there when the
apartment was originally inspected on April 29, 2019. Mr. Nunez did not show this
damage to the inspectors at that time. As we progressed through-the apartment we
observed extensive damage in the bathroom. This includes the ceiling being
completely tom down, the vanity had been removed and the tub surround walls had
been tom down to the studs. Additionally, the toilet had been cracked and water
was running all over the bathroom floor.
In the dining room there was also a large hole in the horse hair plaster that was not
shown to the inspectors at the time of the original inspection in April. The drawers to
the built-in cabinets had been removed and the drawer fronts had been put back in
place and screwed shut.
In the kitchen it appeared that a hole had been drilled in the trap for to the drain for
the kitchen sink and that the plumbing had been forcibly broken away from the sink
drains. There was a large puddle of water all over the kitchen floor.
We then went to the basement where we discovered that water was leaking into the
basement from the first-floor apartment. Mr. Nunez stated that when it rains the
water floods the basement. The water flooding into the basement was clearly not
r,fi. h a Tr Re Ca d
from the rain. Upon further investigation it was found that all the water valves on the
steam heat radiators were loosened or broken to allow water to leak onto the floors
of this unit and into the basement.
Mr. Nunez stated that the damages he was pointing out were all part of the original
complaint and inspection on April 29, 2019. It is the belief of the health department
that these damages did not exist at that time and that Mr. Nunez caused these
damages.
After some discussion with Mr. Nunez he agreed to move his remaining belongings
and return the key to the landlord. After two hours Mr. Nunez finished removing his
remaining belongings and left the premises.
= 4 a
�I