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255 JEFFERSON AVENUE - BUILDING INSPECTION JEFFERSON AVENUE ------ ---------------------------------------------------------------------- DEPOSMONSUBPOENA: DUCESUCUM WITH OMCER'S RERJRN OF SERVICE COMMONWEALTH OF MASSACHUSETTS' ttLf R,N 1 ESSEX,SS: SUPERIOR COURT 2011 :JAN I,2 . P .2,P C. A. No. 1677CV00215D JEAN SHEA BUDROW ) Plaintiff, ) V. VERIZON OF NEW ENGLAND, ) VERIZON COMMUNICATIONS, SEDGWICK CMS,and NATIONAL ) � . UNION FIRE INSURANCE(AIG), Defendants. ) TO: KEEPER OF RECORDS City of Salem Inspectional Services 120 Washington Street 3rd Floor Salem,MA 01970 YOU ARE HEREBY COMMANDED in the name of the Commonwealth of Massachusetts hi accordance with the provisions of Rule 45 of the Massachusetts Rules of Civil Procedure to produce for inspection, copying, testing, or sampling the items listed in the attached Schedule "A" to the Defendants in this matter by delivering the same to the office of Tucker, SaltzmanDver & O'ConnellLLP 50 Congress Street Boston, MA 02109 on or before the 31sT day of January 2017,at 10:00 A.M. Hereof fail not as you will answer your default under the pains and penalties in the j law in that behalf made and provided. Dated::January 2017 James R. Dyer- BBO#558929 Tucker,Saltzman, Dyer &O'Connell, LLP 50 Congress Street,Suite 430 Margu i e Hall,Notary Public Boston, MA 02109 My commission expires: 2/9/2018 (617) 986-4219 (Direct Line) dyer@tsd-lawfirni.com "-"1 , AGUE -I --A. 11ii'. } � NIki�GllERITF A, HAI.?. . Nota1Y Pubic dI GJMMUHWL T40F MAS^+1CHU5@'I'iS My Ccmmisalon L'xplros -wvmm�.wmsesum�yhw2-Bia�a�.xi,�! SCHEDULE "A" The keeper of records is required to produce copies of the following materials in regards to the property located at 255 Jefferson Street, Salem,MA 01970: a. All records regarding inspections of the property; b. All records regarding permits (including but not limited to building, plumbing and electrical permits) that were issued for the property,including all:applications for permits; c. All photographs of the property; d. All records regarding health code violations at the property; and e. All correspondence,including all letters,faxes, and electronic transmissions, regarding the property. PLEASE READ THOROUGHLY: If any request listed herein calls for information or the production of a document which you claim to be protected by any privilege or other limitation on disclosure,kindly provide herein a written statement as to the existence of the information or document and should also state each privilege or limitation claimed for each such information or document with a summary of all facts and circumstances upon which each such claim was based. WARNING- FAILURE WITHOUT ADEQUATE EXCUSE TO OBEY A SUBPOENA DULY SERVED MAY BE DEEMED A CONTEMPT OF THE COURT FROM WHICH THE SUBPOENA IS ISSUED OR A DISTRICT COURT IN THE COUNTY IN WHICH THE SUBPOENA IS SERVED,AND MAY BE PUNISHED BY FINE OR CONFINEMENT,OR BOTH, IF YOU HAVE ANY QUESTIONS OR REQUIRE AN EXTENSION IN ORDER TO COMPLY, CONTACT ADRIANNA HUGHES AT(617) 986-4201 PRIOR TO THE DATE ON WHICH YOU ARE TO PRODUCE DOCUMENTS. NOTE-APPEARANCE IS NOT NECESSARY, CERTIFIED AND COMPLETE RECORDS WILL BE ACCEPTED ON OR BEFORE January 31,2017 AT 10:00 A.M. Kindly send records to Tucker,Saltzman,Dyer &O'Connell,LLP,50 Congress Street,Boston, Suite 430,MA 02109. PLEASE CALL WITH ANY QUESTIONS AS TO WHAT NEEDS TO BE PRODUCED RESPONSIVE TO THIS SUBPOENA. QTY 1 OF SALEM PUBLICPROPERTY �+ 1011 JAN 12 P 2 23 DEPL�R�7'+���7�7-� KINMERLEYDRISOOLL ' RT?v J_'.I V 1 MAYOR 120 WASHINGTON STREET♦SALEM,MASSACHUSETTS 01970 TEL:978-745-9595 ♦FAx:978.740-9846 Notice of Building Code Violation 255 Jefferson Avenue October 9, 2013 Jean Budrow 1 South Hillside Street Stoneham, Ma. 02180 Ms. Budrow A recent visit to your property at 255 Jefferson Avenue revealed that large areas of the chain link fence along your driveway appear to have blown off in the recent storms or been damaged due to vehicular passage. You are in violation of The State Building Code 780CMR Section 5103 for failure to maintain your property until this condition is rectified. You are hereby ordered to begin to rectify these conditions within 14 days of receipt of this notice. Failure to do so may result in further actions being brought against you, up to and including the filing of criminal complaints at District Court. You have the right to appeal this order to the State Board of Building Regulations at One Ashburton Place, Boston, Ma. If you have any questions regarding this letter, please contact the Building Inspectors Office at (978) 745-9595, extension 5644. Sincerely, Michael lutrzykowski % %J Assistant Building Inspector/Local Inspector cc. file j. I i' of �$ttlem, yl t ;s •;�a—.• !1SYo ��LI�tjIC �JrI13JCrt71 �e�J2I1f U�l'1�( t����h'Y''���x3 �`o'M!x pO"� - �;1111�I111� �E�.1MrtttlCtlt 2D11 JAN 1.2 P 2* 2 One USrrrn July 28, 1978 P and D Realty Trust Rodney A. Maurice et al Trustee 63 Liberty Street Middleton, Massachusetts 01949 RE: 255 Jefferson Avenue Salem, Massachusetts 01970 Gentlemen: / Acting on a complaint inspections were made at the referenced address on July 27, and July 28, 1978. The inspection revealed several structural defects on the premises. The rear stairs are totally unsafe... no handrails, loose treads, and the stairway filled with tenants' household goods. The foundation below the bay window is broken and pulled away from the sill. There is also a large foundation crack at the right front corner. There are balusters missing from the front stair railing and the side porch needs some replacement of floor boards. Emergency lighting and proper "EXIT" signs shall be installed as required by the Massachusetts State Building Code. Upon receipt of this notice you are ordered to immediately obtain a building permit and to correct the conditions. Failure to comply with this order will result in legal action being taken against you by this Department and the City of Salem. Very truly yours, DANIEL F. MANSUR Assistant Building Inspector DFM/mlr Certified Mail #945325 Certificate No: 3-07 Commonwealth of Massachusetts City of Salem Building Electrical Mechanical Permits This is to Certify that the CONDOMINIUM located at Dwelling Type in the CITY OF SALEM - - --- - - -- - .. .....- ---- ..-_....__-.-....._--_...._.Address - Town/City Name IS HEREBY GRANTED A PERMANENT CERTIFICATE OF OCCUPANCY 255 JEFFERSON AVENUE This permit is granted in conformity with the Statutes and ordinances relating thereto, and expires ------ ---- ---- - ....__ . unless sooner suspended orrevoked. --- ----- -- _ _--- Expiration Date _------_ -----__-----__------_----- _ ------ ------- _-..... ft Issued On: Wed Sep 27, 2006 GeoTMS®2006 Des Lauriers Municipal Solutions,Inc. '""-----"---" ------ .N 0 JI �I _ b 0255 JEFFERSON AVENUES 03-07 GIS#: 3281 r- NWEALTH OF MASSACHUSETTS Map: 23 . Block: tali♦ " CITY OF SALEM Lot: 0091 " JANt 12 P 2: 23,1 ,1," . Category: REPAUZ/REPLACE r ") Permit# 03-07 BUILDING PERMIT Project# JS-2007-0047 $L Cost: $5,138.00 Fee Charged: $61.00 Balance Due: $:00 PERMISSION IS HEREBY GRANTED TO: Const. Class: Contractor: License: Use Group: DPS LIMITED DAVID P.SAIA Lot Size(sq.ft.): 6525 Zoning: _ BIR Own¢Y: Jean SheaBudrow � ,_� Units Gained: Applicant: Jean Shea Budrow Units Lost: ATJEFFERSON AVENUE Dig Safe#: ISSUED ON: 12-Jul-2006 AMENDED ON: EXPIRES ON: 12-Nov-2006 TO PERFORM THE FOLLOWING WORK: Rennovate(3)Kitchens POST THIS CARD SO IT IS VISIBLE FROM THE STREET Electric Gas Plumbing Building Underground: Underground: f/1 Underground: (n Excavation: Service: Meter: �I"A �T Footings: C Rough: Rough: �/ Rough: ^��(j.�� Foundation: V Utt _` //!!rI , Final: at: Final: ? I Rough Frame: ,. A..�., 06 Fireplace/Chimney: D.P.W. Fire Health Insulation: Meter: Oil: {' L C,(�✓i Final:©/t /i1R•i�" ���� — Houseti Smoke: �i�� Treasury: Water: :91arw: Sewer: (Sprinklers: I ^ I VO- THIS PERMIT MAY BE REVOKED BY THE CITY OF SALEM UPON VIOLATION OF ANY OF ITS RULES AND REGULATIONS. Signare: A �iiw.s- Fee Type: Receipt No: Date Paid:_ Check No: Amount: BUILDING REC-2007-000062 12-Jul-06 1626 $61.00 v �.3.,�. •na�� ism �.=rw� 74 , GeoTMS®2006 Des Lauriers Municipal Solutions,Inc. QTYOF SALEM I a+, �-� r•�j PUBLIC PROPERTY DEPARTMENT xfNBERLEYDRISmLL MAYOR 120 WASFUNGTON STREET♦ SALEaM,MASSACF U5EM 01970 TEL:978-745-9595 ♦FAx:978.740-9846 Notice of Building Code Violation 255 Jefferson Avenue October 9, 2013 Jean Budrow I South Hillside Street Stoneham, Ma. 02180 Ms. Budrow A recent visit to your property at 255 Jefferson Avenue revealed that large areas of the chain link fence along your driveway appear to have blown off in the recent storms or been damaged due to vehicular passage. You are in violation of The State Building Code 780CMR Section 5103 for failure to maintain your property until this condition is rectified. You are hereby ordered to begin to rectify these conditions within 14 days of receipt of this notice. Failure to do so may result in further actions being brought against you, up to and including the filing of criminal complaints at District Court. You have the right to appeal this order to the State Board of Building Regulations at One Ashburton Place, Boston, Ma. If you have any questions regarding this letter, please contact the Building Inspectors Office at (978) 745-9595, extension 5644. Sincerely, Michael lutrzykowski Assistant Building Inspector/Local Inspector cc. file V��oH o�r4.o r t LL Ctu o �zlLtlt, � s�cZ�u et#s 3 e,:Iropertu a=1 artntent 1 l ;uilbing BIT- epartiltent alulla 1. �8u(urre QJuc �ulcm (i tree" 7.15-02 13 July 28, 1978 P and D Realty Trust Rodney A. Maurice et al Trustee 63 Liberty Street Middleton, Massachusetts 01949 RE: 255 Jefferson Avenue Salem, Massachusetts 01970 Gentlemen: Acting on a complaint inspections were made at the referenced address on July 27, and July 28, 1978. The inspection revealed several structural defects on the premises. The rear stairs are totally unsafe... no handrails, loose treads, and the stairway filled with tenants` household goods. The foundation below the bay window is broken and pulled away from the sill. There is also a large foundation crack at the right front corner. There are balusters missing from the front stair railing and the side porch needs some replacement of floor boards. Emergency lighting and proper "EXIT" signs shall be installed as required by the Massachusetts State Building Code. Upon receipt of this notice you are ordered to immediately obtain a building permit and to correct the conditions. Failure to comply with this order will result in legal action being taken against you by this Department and the City of Salem. Very truly yours, DANIEL F. MANSUR Assistant Building Inspector DFM/mlr Certified Mail #945325 F;10. Certificate No: 3-07 Commonwealth of Massachusetts City of Salem Building Electrical Mechanical Permits This is to Certify that the CONDOMINIUM located at Dwelling Type - in the CITY OF SALEM - - ------------------------- ---------------- - Address Town/City Name IS HEREBY GRANTED A PERMANENT CERTIFICATE OF OCCUPANCY 255 JEFFERSON AVENUE This permit is granted in conformity with the Statutes and ordinances relating thereto, and expires unless sooner suspended or revoked. Expiration Date ----------------------- Issued On: Wed Sep 27, 2006 GeoTMSO 2006 Des Lauriers Municipal Solutions,Inc. ✓_"U""� ` w V i VL • rr Tn�r 7 /1 'W /'Y A T T 1 A 0255 JEFFERSON AVENUE 03-07 GIS#: 3281 COMMONWEALTH OF MASSACHUSETTS Map: 23 Block: CITY OF SALEM Lot. 0091 Category: REPARZ/REPLACE Permit# 03.07 BUILDING PERMIT Project# JS-2007-0047 Est.Cost: $5,138.00 Fee Charged: $61.00 Balance Due: $.00 PERMISSION IS HE, GRANTED TO: Const. Class: Contractor: License: Use Group: DPS LIMITED DAVID P.SAIA Lot Size(sq. ft.): 6525 Zoning: _ BIR =Owner- Shea Budrow Units Gained: Applicant: Jean Shea Budrow Units Lost: AT: 0255 JEFFERSON AVENUE_ Dig Safe#: I, ISSUED ON: 12-Jul-2006 AMENDED ON: EXPIRES ON: 12-Nov-2006 TO PERFORM THE FOLLOWING WORK. Rennovate(3),Kitchens POST THIS CARD SO IT IS VISIBLE FROM THE STREET Electric Gas Plumbing Building Underground: -Underground: (/ Underground: (p Excavation: Service: Meter: `-r ,_. �1 Footings: G. Rough: Rough: Rough: �j �� /l I1" •, Foundation: Final: al: Final: V + ✓� Rough Frame: a�y�....,,..,... Fireplace/Chimney: D.P.W. Fire Health Insulation: Meter: Oil: / 1, House It Smoke:Water; 'Anum: Treasury: Sewer: (Sprinklers: -(ar V0 THIS PERMIT MAY BE REVOKED BY THE CITY OF SALEM UPON VIOLATION OF ANY OF ITS RULES AND REGULATIONS. Signa urge: r,,,,WZ Fee Type: Receipt No: Date Paid: 1 Check No: - - 'Amount: BUB.DING REC 2007-000062 12-Jul-06 1626 $61_00 ' ' Y:LS'iiGNe•aaar:uy;xx�ts An, F�-3RC',t0fl- is 3EQ011BED 7454k,1115 Ext.385- GeoTMS®2006 Des l.auriers Municipal Solutions,Inc. P: ��CONU�IT YSRVE AO CITY OF SALEM BUILDING PERMIT 4�- 1�'RN'l5R`( ,y"y1ViW.XiPw►�Y.'i � :n�*., IRE1 wt'G+7'�ff�'1 � r,Y FIELD COPY y ° CITY Of SALEM BUILDING =°° SALEM, MASSACHUSETTS 01970 PERMIT .� VALIDATION 4Eoll"I DATE Dec. 9, _19 92 PERMIT No. 578-9.2 APPLICANT V. G370CM . ADDRESS 9taampscott,MA. - 829 IN0.1 (STREET) ICONIR'S LICENSE, Ooo PERMIT TO STpTNf, NUMBER (_I STORY DWELLIWY .OWELLIN0.FUNITS ??�7 11,11 0- IMIROVLMENTI NO. IIIIOIOSEO USE, ZONI AT ILOCPT,ONI 955 Teffergon Ave_ Ward 3 DISTRc DISTRICT B-1 (NO.) (STREET) BETWEEN - AND ICAOS> STREET) ICROSS STREETI LOT SUBDIVISION LOT BLOCK SIZE BUILDING IS.TO BE FT. WIDE BT FT. LONG BY FT, IN HEIGHT AND SHALL CONFORM IN CONSTRUCTION •A, TO TYPE USE GROUP BASEMENT WALLS OR FOUNDATION liiltl REMARKS: T i EaL..ll xjV1 siding IRREIOLUME ESTIMATED COST $ 5+.000.00 FEEM1T S 20.00 C�jfl)C SOU,.RL FEET, OWNER A^o;Ess Marb ehead,MA 01935 Leo E. Tremblay INSPECTOR OF BUILDINGS INSPECTION RECORD DATE NOTE PROGRESS - CRITICISMS •ND REMARK$ INSPECTOR