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04/10/2012 18:40 FAX 978 825 0088 JOHN H. CARR, JR. , ESQ. 0 001
JOHN H. CARR,JR., ESQ.
9 North Street
Salem, MA 01970
Phone: 978-825-0060
Fax: 978-825-0068
FACSIMILE COVER SHEET
FACSIMILE NUMBER: 978-740-0404
TO: Danielle McKnight
Salem Zoning Board of A$peals
120 Washington Street, 3' floor
Salem, MA 01970
RE: Thomas J. McKinnon, Jr., et al. v. Leslie Byme, et al.
Essex Superior Court Civil Action No. 2009-1545-C
DATE: April 10,2012
Pages including this cover page: Z.-
The
iThe information contained in this roesimile message is legally privileged and confidential information intended only for the use
of the individual or entity named above. If you arc not the recipient named above,you arc hereby notified that any
dissemination,distribution or copy of this facsimilo message is strictly probibited. If you have received this facsimile message in _
error,please notify me immediately by telephone and return the original message to me at the above address via the United States
Postal Serviee.
Thank you. ,
04/10/2012 18:40 FAX 978 825 0088 JOHN H. CARR, JR. , ESQ. 1?1002
John 11. Carr, Jr., Esq.
9 North Street
Salem,MA 01970
Phone: 978-825-0060
Fax: 978-825-0068
April 10, 2012
By Facsimile: 781-289-9468
James J. Cipoletta, Esq.
385 Broadway
Revere,MA 02151
RE: Thomas J. McKinnon,Jr., et al. v. Leslie Byrne, et al.
Essex Superior Court Civil.Action No, 2009-1545-C
Dear Jim:
I have still not received a reply to my 12:19 p.m. fax to you of Friday,April 6, 2012
(copy enclosed).
Yesterday I called Danielle McKnight, who is the Salem Planning Department employee
who serves as the liaison for the Salem.ZBA, and Danielle informed me that so far they
have not received or heard anything from you or Leslie regarding continuing the April
18,2012 continued hearing to the May ZBA meeting.
Enclosed is a copy of the fax I sent Danielle earlier this afternoon.
Again, would you kindly call me on my cell phone(978-807-3264)by tomorrow at noon
and let me know when you or Leslie will be contacting the Salem ZBA relative to
continuing the April 18, 2012 meeting, if you have not done so already.
Thank you.
Very truly yours,
John H. Carr,Jr.
Cc. Robin Stein, Esq.-By Facsimile: (978) 744-1279
Danielle McKnight, By Facsimile: 978-740-0404-cover letter only ✓
Mr. &Mrs. Thomas McKinnon&Melanie
04/10/2012 17:17 FAX 978 825 0088 JOHN R. CARR, JR. , ESQ. IA001
JOHN I i. CARR,JR., ESQ.
9 North Street
Salem, MA 01970
Phone: 978-825-0060
Fax: 978-825-0068
FACSIMILE COVER SHEET
FACSIMILE NUMBER: 978-740-0404
TO: Danielle McKnight
Salem Zoning Board of Appeals
120 Washington Street, 3r floor
Salem, MA 01970
RE: Thomas J. McKinnon, Jr., et al. v. Leslie Byrne, et al.
Essex Superior Court Civil Action No. 2009-1545-C
DATE: April 10, 2012
Pages including this cover page: 3
The information contained in this facsimile message is legally privileged and confidential information intended only for the use
or the individual or entity named above. If you are not the recipient named abovc,you are hereby noofled that my
dissemination,distribution or copy of this facsimile message is strictly prohibited. If you have received this facsimile message in
error,plisse notify me immediately by telephone and rerun the original message to me at the above address via the United Statcs
Postal Service.
Thank you.
i
04/10/2012 17:17 FAX 978 825 0088 JOHN H. CARR, JR. , ESQ. Z002
John J4. Carr, Jr., Esq-
9 North Street
Salem, MA 01970
Phone: 978-825-0060
Fax: 978-825-0068
April 10, 2012
By Facsimile: 978-740-0404
Danielle McKnight
Salem Zoning Board of Agpeals
120 Washington Street, 3` floor
Salem, MA 01970
RE_ Thomas J. McKinnon, Jr., et al. v. Leslie Byrne, et al.
Essex Superior Court Civil Action No. 2009-1545-C
Dear Danielle:
Pursuant to my telephone call to you at 11:17 a.m. yesterday morning, I am herewith
enclosing a copy of Attorney Cipoletta's 3:21 p.m. handwritten reply fax to me of
Tuesday, April 3, 2012, printed on the face of the same letter that I faxed to him at 5:45
p.m. the day before, wherein Mr. Cipoletta states that"She [Leslie Byrne 9 will be pushing
out the next ZBA until May."
Since Mr. Cipoletta assured the Board at the initial hearing on March 21, 2012 that he
would notify the Board as soon as possible if he would not be ready by the next meeting
of the ZBA on April 18, 2012, in which event the matter would be rescheduled to the
May meeting, I take him at his word and assume you will be receiving direct written
confirmation of the enclosed within the next day or so.
I am sure that neither Mr. Cipoletta nor his client intend unfair surprise, and will write
Jim immediately to hurry this along,but would you nevertheless call me on my cell
phone (978-807-3264)if you do not receive direct written confirmation by noon on
Thursday, April 12, 2012.
Thank you.
Ve o
John 14. Carr,Jr.
Ce. James Cipoletta,Esq.-By Fa ' 1e: 781-289-9468
Robin Stein, Esq.-By Facsimile: -744- 1279
Mr. & Mrs. Thomas McKinnon&Melanie
04/10/2012 17:17 FAb 978 825 0068 JOHN H. CARR, JR. , ESQ. 0 003
04/02/2012 19:73 FAIL 078 626 0088 V JOHN H. CARR, JR. , ESQ. Q002
John I1. Carr,Jr.,Esq.
9 North Street
Salem,MA 01970
Phone• 06
ax: 978-825-0068
i
Aprt12, 2012
By Facsimile: 781-289-9468
James J. Cipoletta Esq.
385 Broadway
Revere, MA 02151
RE: Thomas J. McKinnon,Jr., et al. v. Leslie Byrne, ar at.
Essex Superior Court Civil Action No. 2009-1545-C
Dear Jim:
When I called you a week ago to suggest that we work together in an attempt to come up
with a now design that both of our clients could live with,you agreed that that made
sense.
We left it that you were going to call Leslie Byrne, and would get back to me.
You were also going to let me know wledw Leslie had already spoken with her
architect, and whether sbe could have a new design by the next Salem ZBA meeting on
April 18, 2012 in any event.
It is now 5:45 p,m. on Monday, April 2,2012 and I have still not heard back from you.
Does that mean that Leslie is riot interested in my suggestion?
I would appreciate it if you would call me on my cell phone(978-807-3264) and let me
know either way.
9 Thanks.
X10 ire+ _ ��e t Spc,�� col otr c �,i toil
t is Nor
b t. o�T C� John H. Carr, Jr.
Ce. Robin Stein,Esq.-By Facsimile: (978) 7 - 279
Mr. &Mrs. Thomas McKinnon& Melanie
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FL a Is ie _/e.�s k.. w 4-&- U0.OKaL— 11asf5rJ .
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S� �lL�
oNmrq� CITY OF SALEM9 MASSACHUSETTS
BOARD OF APPEAL
120 WASHINGTON STREET, 3RD FLOOR
SALEM, MASSACHUSETTS 01970
TELEPHONE: 978-745-9595
W� FAX: 978-740-9846 - - -
KIMBERLEY DRISCOLL '1012 AUG —1 AD �
MAYOR
FILE #
CITY CLERK, SALEM, MASS•
July 31,2012
Decision
City of Salem Zoning Board of Appeals
Petition of LESLIE BYRNE, requesting a Special Permit under Sec. 3.3.5 of the
Salem Zoning Ordinance to alter and extend a nonconforming single-family house
on the property located at 16 SAUNDERS ST, Salem,MA(R2 Zoning District).
A public hearing on the above Petition was opened on March 21, 2012, pursuant to Mass
General Law Ch. 40A, � 11. The hearing was continued to April 18, 2012, May 16, 2012,
and June 20, 2012, but was not heard those dates and no evidence was taken. The hearing
was then continued to July 18, 2012 and closed on that date with the following Zoning
Board of Appeals members present: Rebecca Curran, Richard Dionne, Annie Harris,Jimmy
Tsitsmos and Bonnie Belair.
Petitioner seeks a Special Permit pursuant to Section 3.3.5,Nonconforming Single- and
Two-Family Residential Structures, of the City of Salem Zoning Ordinances.
Statements of fact-
1.
act:1. In a petition date-stamped March 5, 2012, petitioner Leslie Byrne requested a Special
Permit to alter and extend her nonconforming single family house with an addition
of 1 1/2 stories.
2. The petitioner was represented by Attomey James Cipoletta at the March 21, 2012
meeting, but represented herself at the July 18, 2012 meeting.
3. At the March 21, 2012 meeting,the Board heard testimony from several members of
the public who opposed the project,citing concerns about impacts to views, access
to light and air, fire safety, privacy, and decreased home values. The Board also
received several letters in opposition to the project, as well as three letters of support.
4. On March 21, 2012,the Board continued the hearing to April 18, 2012, requesting
that the petitioner look at revising the design to minimize the impact to abutters,
particularly those at 14 Saunders Street, who would be most affected by the project.
2
5. The matter was not heard on April 18, 2012, but was instead continued to May 16,
2012 and then to June 20, 2012; no evidence was taken on these dates. The hearing
was then continued to July 18, 2012.
6. At the July 18, 2012 meeting,the Board discussed revised plans submitted by the
petitioner showing a lowered height and a dormer design that reduced the mass from
the original proposal. At this hearing, the Board again heard testimony from abutters
opposing the project.
7. At the July 18,2012 meeting, Real Estate appraiser Steven G. Ozahowski, 156
Willow St., Hamilton, stated that the value of the property located at 14 Saunders
Street would be decreased by the proposed addition. A shadow study and solar
elevations were also submitted to show impacts to the home on 14 Saunders Street.
The Board of Appeal, after careful consideration of the evidence presented at the public
hearing, and after thorough review of the plans and petition submitted, makes the following
findings:
1. Desirable relief may not be granted, since the proposed addition would be
substantially more detrimental to the neighborhood than the existing
nonconforming structure. Due to the house's close proximity to the abutter
at 14 Saunders Street, the proposed addition is not appropriate for its
location,would impinge on privacy, and would otherwise negatively impact
abutters.
On the basis of the above findings of fact and all evidence presented at the public hearing
including, but not limited to,the Plans,Documents and testimony,the Zoning Board of
Appeals concludes:
1. A Special Permit under Sec. Section 3.3.5, Nonconforming Single- and Two-Family
Residential Structures, of the City of Salem Zoning Ordinances, is denied.
In consideration of the above, the Salem Board of Appeals voted 5-0 (Curran, Harris,
Dionne, Tsitsinos and Belair opposed, none in favor),to deny petitioner's request for a
Special Permit. The petition is denied.
Re ecca Curran, Chair
Salem Board of Appeals
A COPY OF THIS DECISION HAS BEEN FILED WITH THE PLANNING BOARD
AND THE CITY CLERK
Appeal from this decision,if any,shall be made pursuant to Section 17 of the Massachusetts
General Laws Chapter 40A, and shall be filed within 20 days of filing of this decision in the
3
office of the City Clerk Pursuant to the Massachusetts General Laws Chapter 40A, Section
11, the Variance or Special Permit granted herein shall not take effect until a copy of the
decision bearing the certificate of the City Clerk has been filed with the Essex South Registry
of Deeds.
f
PETITION IN OPPOSITION
TO THE APPLICATION
OF LESLIE BYRNE
FOR A SPECIAL PERMIT
TO EXPAND UPWARDS
AT 16 SAUNDERS STREET
SALEM, MASSACHUSETTS
We, the undersigned, are opposed to the original and revised application of Leslie A.
Byrne for a Special Permit to expand upwards at 16 Saunders Street, Salem,
Massachusetts, including for the following reasons:
1. The revised design still substantially blocks the air, light, and views of our
neighbors, the McKinnons, who own, live, and reside at 14 Saunders Street;
2. Ms. Byrne has other opportunities for expansion, which would not have such an
adverse affect on the McKinnon' property;
3. Ms. Byrne's architect was supposed to work closely with the McKinnons in an
attempt to work out a mutual-satisfactory design, but in the 3 months since the
last ZBA hearing in March, she and her architect have not even bothered to
contact the McKinnon;
4. Ms. Byrne purchased 16 Saunders Street long after the McKinnon purchased 14
Saunders Street, which was exactly the same size then as it is today;
5. Ms. Byrne knew or should have known that any future upward expansion by her
would block the light, air and views of the McKinnon, and could not be
accomplished as a matter of right. By proceeding with her purchase of 16
Saunders Street, she assumed the risk that she would not be able to obtain such
zoning relief in the future;
6. Ms. Byrne is being hypocritical, since she opposed the original plans to build new
housing at the bottom of Saunders Street because the then proposed townhouses
would have blocked her views. She only dropped her opposition once the
developer agreed to relocate both structures so they wouldn't block her views;
7. In particular, not only has Ms. Byrne not disclosed material facts to the
Board, she has led the Board to believe just the opposite, since she
affirmatively represented to both the neighbors and the ZBA, including at the
initial ZBA hearing this past March,that she plans to continue to live at 16
Saunders Street and needs the additional space in order to enable her to do so. Not
once did she disclose to either the neighbors or the ZBA the truth of the
matter,which is that on December 30, 2011, three months before the last
ZBA hearing in March 2012, she purchased a larger single-family home at 19
Dolloff Avenue in Beverly for$240,500.00, and on the same date signed a
Declaration Of Homestead "under the pains of perjury" stating that she is
occupying 19 Dolloff Ave(where she continues to reside) as her principal
residence. She has also recently rented 16 Saunders Street for a year
pursuant to a written lease to an unrelated third party;
8. The McKinnon are entitled to rely on the Salem zoning ordinance and the Salem
ZBA to protect the enjoyment of their property and their property values;
9. We ask the Board to uphold the rights of people who actually live in the
neighborhood, and not permit changes that adversely effect neighboring
properties in violation of the stated purposes of Article 1 of the Salem Zoning
Ordinance, especially changes that seem primarily designed to enrich absentee
landlords at the expense of Salem residents and taxpayers.
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ZONING DISTRICT — R2
PROPOSED
REQUIRED EXISTING ADDITION
FRONT 15 9t 9f
SIDE 10 4t 4t CROSS STREET CT.
REAR 3D 64t 62t i 12.5't r
MAP 36
LOT 78
AREA=
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COMMONWEALTH OF ELIZABETH MCCAMMON
MASSACHUSETTS THOMAS J. MCCAMMON, JR.
,-GARAGEROP
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PROPOSED . ' - �` n existing
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SAUNDERS STREET
PLOT PLAN OF LAND
16 SAUNDERS STREET
SALEM
PROPERTY OF
LESLIE BYRNE
SCALE 1 " - 20' MAY 22, 2009
NORTH SHORE SURVEY CORP.
14 BROWN ST., SALEM, MA
978-744-4800 #3235