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7 & 220 & 22 CLARK STREET & BARNES CIRCLE - ZBA 7 Clark St./20,.& 22 Barnes Circle-R-1 �I Paul -Ferragamo, Tr. C T cb a` (1Lct ofttlem, � ttssttcljusetts :,q s $Rnurd of �upeal FES 8 3 09 Pr'i `9q CITY r '-Is DECISION ON THE PETITION OF PAUL FERRAGAMO, TR. FERRAGAMO FAMILY TR. FOR VARIANCES AT 7 CLARK ST. , 20 BARNES CIRCLE & 22 BARNES CIRCLE (R-1) A hearing on this petition was held December 1, 1993 and continued until January 19, 1994 with the following Board Members present: Francis X. Grealish, Chairman; George Ahmed, Stephen Touchette and Stephen O'Grady. Notice of the hearing was sent to abutters and others and notices of the hearing were properly published in the Salem Evening News in accordance with Massachusetts General Laws Chapter 40A. Petitioner, owner of the property, is requesting a Variances to reconfigure the above three lots in order to create three buildable single family lots as follows : A variance from lot area from 15,000 sq.ft. to 11,400 sq.ft. and from lot width from the required 100 feet to 50 feet at 7 Clark St. A Variance from lot width from 100 feet to 59 feet at 22 Barnes Circle and from lot width from 100 feet to 66 feet at 20 Barnes Circle. Before hearing the merits of this petition, the Board of Appeal has to consider whether or not there is substantial and material change from a previous petition which was denied by this Board on June 17, 1992. The Board of Appeal, after hearing the evidence presented, and after receiving Consent from the City of Salem Planning Board, voted unanimously, 4-0, that there was substantial change, said change being the addition of land area from 5000 sq.ft. to 11,400 sq.ft. to 7 Clark St. The Board will hear the petition. The Variances which have been requested may be granted upon a finding by this Board that: 1. Special conditions and circumstances exist which especially affect the land, building or structure involved and which are not generally affecting other lands, buildings and structures involved. 2. Literal enforcement of the provisions of the Zoning Ordinance would involve substantial hardship, financial or otherwise, to the petitioner. 3. Desirable relief may be granted without substantial detriment to the public good and without nullifying or substantially derogating from the intent of the district or the purpose of the Ordinance. The Board of Appeal, after careful consideration of the evidence presented at the hearing, and after viewing the plans, makes the following findings of fact: DECISION ON THE PETITION OF PAUL FERRAGAMO TR. , FERRAGAMO FAMILY TRUST FOR VARIANCE AT 7 CLARK ST. , 20 BARNES CIRCLE a 22 BARNES CIRCLE, SALEM page two r tB 3 1. The plan submitted to the Board added a substantial amount 'oF land to 7 Clark St. bringing the total land area to 11,40W square .fe'et'as opposed to the 5,000 square feet originally submitted to the Board. This original petition was denied by the Board of Appeal. 2. The two remaining lots, 20 Barnes Circle and 22 Barnes Circle will have the required 15,000 square feet of lot area and the frontage of these lots will remain as they currently exist. 3. The proposed use, single family house lots, is consistent with the existing zoning. 4. The existing neighborhood consists mainly of single family homes and a substantial number of these homes are on lots that are significantly smaller that the lots proposed by the petitioner. 5. The topography of the land is irregular and such irregularity does not exist generally in the district. On the basis of the above findings of fact, and on the evidence presented at the hearing, the Board of Appeal concludes as follows: 1. Special conditions exist which especially affect the subject property but not the district in general. 2. Literal enforcement of the provisions of the Zoning Ordinance would involve substantial hardship to the petitioner. 3. Desirable relief can be granted without substantial detriment to the public good and without nullifying or substantially derogating from the intent of the district or the purpose of the Ordinance. Therefore, the Zoning Board of Appeal voted unanimously, 4-0, to grant the variance requested, subject to the following conditions: 1. Petitioner shall comply with all city and state statutes, ordinances, codes and regulations. 2. The proposed lots shall be reconfigured in strict accordance with the plans and dimensions submitted with the original petition dated September 30, 1993. 3. Petitioner shall comply with all requirements of the Salem Fire Department relative to smoke and fire safety. 4. Petitioner shall obtain a building permit from the City of Salem Building Inspector prior to beginning any construction . 5. Petitioner shall obtain the approval of the City of Salem Planning Board. DECISION ON THE PETITION OF PAUL FERRAGAMO, TR. FOR VARIANCES AT 7 CLARK ST. , 20 BARNES CIRCLE & 22 BARNES CIRCLE, SALEM page two pp 6 A pre-blast survey is to be conducted on Barnes Cii&,uBaAAP&i n" and Clark St. Chi, ,.. Variance Granted January 19, 1994 Francis X. Grealish, Chairman Board of Appeal 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 after the date of filing of this decision in the office of the City Clerk. Pursuant to 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 certification of the City Clerk that 20 days have elapsed and no appeal has been filed, or that, if such appeal has been filed, that it has been dismissed or denied is recorded in the South Essex Registry of Deeds and indexed under the name of the owner of record or is recorded and noted on the owner's Certificate of Title. Board of Appeal Titu of ttlem, � ttssttcljusetts i ae Pottra ofkv{7P2t1 FEB 8 3 os Ft 19q Circ SS DECISION ON THE PETITION OF PAUL FERRAGAMO, TR. FERRAGAMO FAMILY TR. FOR VARIANCES AT 7 CLARK ST. , 20 BARNES CIRCLE & 22 BARNES CIRCLE (R-1) A hearing on this petition was held December 1, 1993 and continued until January 19, 1994 with the following Board Members present: Francis X. Grealish, Chairman; George Ahmed, Stephen Touchette and Stephen O'Grady. Notice of the hearing was sent to abutters and others and notices of the hearing were properly published in the Salem Evening News in accordance with Massachusetts General Laws Chapter 40A. Petitioner, owner of the property, is requesting a Variances to reconfigure the above three lots in order to create three buildable single family lots as follows: A variance from lot area from 15,000 sq. ft. to 11,400 sq.ft. and from lot width from the required 100 feet to 50 feet at 7 Clark St. A Variance from lot width from 100 feet to 59 feet at 22 Barnes Circle and from lot width from 100 feet to 66 feet at 20 Barnes Circle. Before hearing the merits of this petition, the Board of Appeal has to consider whether or not there is substantial and material change from a previous petition which was denied by this Board on June 17, 1992. The Board of Appeal, after hearing the evidence presented, and after receiving Consent from the City of Salem Planning Board, voted unanimously, 4-0, that there was substantial change, said change being the addition of land area from 5000 sq.ft. to 11,400 sq.ft. to 7 Clark St. The Board will hear the petition. The Variances which have been requested may be granted upon a finding by this Board that: 1. Special conditions and circumstances exist which especially affect the land, building or structure involved and which are not generally affecting other lands, buildings and structures involved. 2. Literal enforcement of the provisions of the Zoning Ordinance would involve substantial hardship, financial or otherwise, to the petitioner. 3. Desirable relief may be granted without substantial detriment to the public good and without nullifying or substantially derogating from the intent of the district or the purpose of the Ordinance. The Board of Appeal, after careful consideration of the evidence presented at the hearing, and after viewing the plans, makes the following findings of fact: DECISION ON THE PETITION OF PAUL FERRAGAMO TR. , FERRAGAMO FAMILY TRUST FOR VARIANCE AT 7 CLARK ST. , 20 BARNES CIRCLE & 22 BARNES CIRCLE, SALEM page two FEB 3 09 1. The plan submitted to the Board added a substantial, amount '-64; land to 7 Clark St. bringing the total land area to 11,466 square-:fe'et' as opposed to the 5,000 square feet originally submitted to the Board. This original petition was denied by the Board of Appeal. 2. The two remaining lots, 20 Barnes Circle and 22 Barnes Circle will have the required 15,000 square feet of lot area and the frontage of these lots will remain as they currently exist. 3. The proposed use, single family house lots, is consistent with the existing zoning. 4. The existing neighborhood consists mainly of single family homes and a substantial number of these homes are on lots that are significantly smaller that the lots proposed by the petitioner. 5. The topography of the land is irregular and such irregularity does not exist generally in the district. On the basis of the above findings of fact, and on the evidence presented at the hearing, the Board of Appeal concludes as follows: 1. Special conditions exist which especially affect the subject property but not the district in general. 2. Literal enforcement of the provisions of the Zoning Ordinance would involve substantial hardship to the petitioner. 3. Desirable relief can be granted without substantial detriment to the public good and without nullifying or substantially derogating from the intent of the district or the purpose of the Ordinance. Therefore, the Zoning Board of Appeal voted unanimously, 4-0, to grant the variance requested, subject to the following conditions: 1. Petitioner shall comply with all city and state statutes, ordinances, codes and regulations. 2. The proposed lots shall be reconfigured in strict accordance with the plans and dimensions submitted with the original petition dated September 30, 1993. 3. Petitioner shall comply with all requirements of the Salem Fire Department relative to smoke and fire safety. 4. Petitioner shall obtain a building permit from the City of Salem Building Inspector prior to beginning any construction . 5. Petitioner shall obtain the approval of the City of Salem Planning Board. DECISION ON THE PETITION OF PAUL FERRAGAMO, TR. FOR VARIANCES AT 7 CLARK ST. , 20 BARNES CIRCLE & 22 BARNES CIRCLE, SALEM page two [[ 6 A pre-blast survey is to be conducted on Barnes CifA,4aAe4P G" and Clark St. CIT Variance Granted January 19, 1994 Francis X. Grealish, Chairman Board of Appeal 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 after the date of filing of this decision in the office of the City Clerk. Pursuant to 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 certification of the City Clerk that 20 days have elapsed and no appeal has been filed, or that, if such appeal has been filed, that it has been dismissed or denied is recorded in the South Essex Registry of Deeds and indexed under the name of the owner of record or is recorded and noted on the owner's Certificate of Title. Board of Appeal (Gita of "itttem, � ttssttcltusetts i 9 aQ 'Potts of Av}zenl FEB os Fr'i T3q C11V c _ ass DECISION ON THE PETITION OF PAUL FERRAGAMO, TR. FERRAGAMO FAMILY TR. FOR VARIANCES AT 7 CLARK ST. , 20 BARNES CIRCLE & 22 BARNES CIRCLE (R-1) A hearing on this petition was held December 1, 1993 and continued until January 19, 1994 with the following Board Members present: Francis X. Grealish, Chairman; George Ahmed, Stephen Touchette and Stephen O'Grady. Notice of the hearing was sent to abutters and others and notices of the hearing were properly published in the Salem Evening News in accordance with Massachusetts General Laws Chapter 40A. Petitioner, owner of the property, is requesting a 'Variances to reconfigure the above three lots in order to create three buildable single family lots as follows: A variance from lot area from 15,000 sq.ft. to 11,400 sq. ft. and from lot width from the required 100 feet to 50 feet at 7 Clark St. A Variance from lot width from 100 feet to 59 feet at 22 Barnes Circle and from lot width from 100 feet to 66 feet at 20 Barnes Circle. Before hearing the merits of this petition, the Board of Appeal has to consider whether or not there is substantial and material change from a previous petition which was denied by this Board on June 17, 1992. The Board of Appeal, after hearing the evidence presented, and after receiving Consent from the City of Salem Planning Board, voted unanimously, 4-0, that there was substantial change, said change being the addition of land area from 5000 sq.ft. to 11,400 sq.ft. to 7 Clark St. The Board will hear the petition. The Variances which have been requested may be granted upon a finding by this Board that: 1 . Special conditions and circumstances exist which especially affect the land, building or structure involved and which are not generally affecting other lands, buildings and structures involved. 2. Literal enforcement of the provisions of the Zoning Ordinance would involve substantial hardship, financial or otherwise, to the petitioner. 3. Desirable relief may be granted without substantial detriment to the public good and without nullifying or substantially derogating from the intent of the district or the purpose of the Ordinance. The Board of Appeal, after careful consideration of the evidence presented at the hearing, and after viewing the plans, makes the following findings of fact: DECISION ON THE PETITION OF PAUL FERRAGAMO TR. , FERRAGAMO FAMILY TRUST FOR VARIANCE AT 7 CLARK ST. , 20 BARNES CIRCLE & 22 BARNES CIRCLE, SALEM page two Eta d 3 1. The plan submitted to the Board added a substantial amount 'oj� land to 7 Clark St. bringing the total land area to 11,40 square feet as opposed to the 5,000 square feet originally submitted to the Board. This original petition was denied by the Board of Appeal. 2. The two remaining lots, 20 Barnes Circle and 22 Barnes Circle will have the required 15,000 square feet of lot area and the frontage of these lots will remain as they currently exist. 3. The proposed use, single family house lots, is consistent with the existing zoning. 4. The existing neighborhood consists mainly of single family homes and a substantial number of these homes are on lots that are significantly smaller that the lots proposed by the petitioner. 5. The topography of the land is irregular and such irregularity does not exist generally in the district. On the basis of the above findings of fact, and on the evidence presented at the hearing, the Board of Appeal concludes as follows: 1. Special conditions exist which especially affect the subject property but not the district in general. 2. Literal enforcement of the provisions of the Zoning Ordinance would involve substantial hardship to the petitioner. 3. Desirable relief can be granted without substantial detriment to the public good and without nullifying or substantially derogating from the intent of the district or the purpose of the Ordinance. Therefore, the Zoning Board of Appeal voted unanimously, 4-0, to grant the variance requested, subject to the following conditions: 1. Petitioner shall comply with all city and state statutes, ordinances, codes and regulations. 2. The proposed lots shall be reconfigured in strict accordance with the plans and dimensions submitted with the original petition dated September 30, 1993. 3. Petitioner shall comply with all requirements of the Salem Fire Department relative to smoke and fire safety. 4. Petitioner shall obtain a building permit from the City of Salem Building Inspector prior to beginning any construction . 5. Petitioner shall obtain the approval of the City of Salem Planning Board. DECISION ON THE PETITION OF PAUL FERRAGAMO, TR. FOR VARIANCES AT 7 CLARK ST. , 20 BARNES CIRCLE & 22 BARNES CIRCLE, SALEM page two FF Avpp 5�1 6 A pre-blast survey is to be conducted on Barnes CiAPe,uBaA0 seai and Clark St. C;T Variance Granted January 19, 1994 Francis X. Grealish, Chairman Board of Appeal 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 after the date of filing of this decision in the office of the City Clerk. Pursuant to 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 certification of the City Clerk that 20 days have elapsed and no appeal has been filed, or that, if such appeal has been filed, that it has been dismissed or denied is recorded in the South Essex Registry of Deeds and indexed under the name of the owner of record or is recorded and noted on the owner's Certificate of Title. Board of Appeal DATE OF 1'.EARIN0 / �)ETITIGHER LOCATION iOTION: 70 GRANT 2=/ SECOND TO DENY SECOND 10 RE-HEAR SECOND Q LEAVE T�W _SECOND '0 E SECOND POLL CALL PRESENT GRANT DENY WITHDRAWRE-HE �6NT NUE STEPHEN O'GRAD v GEORGE A. AHMED i FRANCIS GREALISH ILL / STEPHEN TOUCHETTE ASSOCIATE 'MEMBERS NIN CgHE 4RTHURECOUE CONDITIONS: 0/ jL � '"V142 - J ����OWfiq'gQI (11it-q � �9��zx of �Iem, ssarhuset#s g (Office of flie (ERV (Iluuncti 3T ., eg U.itn?dull S'��G+fINE January 19 , 1994 Mr. Francis X. Grealish Board of Appeal City of Salem Salem, Mass . Dear Mr. Grealish: I cannot be in attendance this evening due to a prior commitment. I would however like to inform the members of the Board that I have received several telephone calls from neighbors of the proposed 7 Clark Street lot reconfiguration who are opposed to the plan. It is my hope that the Board of Appeals will pay serious attention to the concerns of the neighborhood with this matter. Thank you for your attention. ,,Si ere C�z,2.- z.�. JOHN DONAHUE COUNCILLOR WARD THREE CITY CITY OF SALEM B�ARD OF SALEM OF APPEAL 0,, BOARD F APPEAL 715-9595 Elt 381 Will hold 145-9595 E�t. 38, Will hold alm blic hearing for all Persons inter- estedi,th a Public h'aringio,all ested in the Petition submitted by PAUL FERRA epetition Persons inter- GArtfO1TR.f0rvari submittedhYP GAM09 TR.for variance to allow property locate� at 7 CLARK S -9nCe to allow AULFERRA- at 7 'CLARK STJ20 BARNES CIRCLE/22 BAR. T./20 BARNES Cproperty located NES CIRCLE (R-1) to be reconf�jgured to allow NES CIRCLE (R-i) to be IRCLE/22 BA the three lots to be sold a'sthre elamilylots. the three lots reconf' R I IVED sIngle family lots, BERLl993AT6:00pM Y, DECEIVI- Said h to be sold as three -Igured to allow Slid hearing to be held IVED e S'`DA earmg to be held 'ES �ERI11993AT6-00pn.,O NESDAV,DECEM second floor. N LEVI GREEN, second floor. NE SALEM GREEN,' - .1 NE SA I FRANCIS X GREALISH, JR,, Chairman FRANCIS X GREALISH, jR., November 17, 24, 1' November 17, 24, 163 Chairman 993 SN36334 SN36334 CITY OF' SALEM BOARD OF APPiAl, 745-9595 Elt. 381 Will hold a Public hearing for all Pers est,ed in the petiti(m submitt ons inter- GAMO,TR.for varl. edbYPAULFERRA- ance to al at 7 CLARK ST/20 BARNE low property 10cated N S CIRCLE/22 BAR- I E S CIRCLE (R-1) to be reconfiguled to allow S he three lots to be sold as three single family lots. B aid harmg to be held WEDNESDAY, DECEAj_ ER I'l 993 AT 6:00 P.M.,ONE SALEIVT CREEN, second floor. FRANCIS X. GREALISH, JR., Chairman November 17, 24, 1993 SN36334 "� flit of Iem, 'Massadjusetts gvara of u}zenl yy C February 15, 1994 YOU ARE HEREBY NOTIFIED THAT AS OF February 08, 1994 THE DECISION OF THE BOARD OF APPEAL HAS BEEN FILED IN THE OFFICE OF THE CITY CLERK TO GRANT THE PETITION OF PAUL FERRAGAMO, TRUSTEE FOR A VARIANCES TO ALLOW 7 CLARK ST./20 BARNES CIRCLE AND 22 BARNES CIRCLE TO BE RECONFIGURED TO ALLOW CREATION OF THREE BUILDABLE SINGLE FAMILY LOTS. BOARD OF APPEAL BRENDA M. SUMRALL CLERK OF THE BOARD 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 MGL Chapter 40A, and shall be filed within 20 days after the date of filing of this decision in the office of the City Clerk. Pursuant to MGL Chapter 40A. , Section 11, the Variance/Special Permit granted herein shall not take effect until a copy of the decision bearing the certification of the City Clerk that 20 days have elapsed and no appeal has been filed, or that, if such appeal has been filed, that it has been dismissed or denied is recorded in the South Essex Registry of Deeds and indexed under the name of the owner of record or is recorded and noted on the owner's Certificate of title. Board of Appeal 9 C Mire Salem OrPEn January 7 , 1994 Frank Grealish Chairman Board of Appeal One Salem Green Salem, MA 01970 RE: 7 CLARK STREET Dear Mr . Grealish: On January 6, 1994, ' in accordance with Massachusetts General Law Chapter 40A, Section 16, the Salem Planning Board met to discuss the application of Paul Ferragamo for a "Determination of Specific and Material Change" to his plans for 7 Clark Street which was denied by the Board of Appeal on June 17, 1992 . Mr . Ferragamo' s amended plan increases the size the lot located at 7 Clark Street from 5,000 square feet to 11, 400 square feet . As required by State law for this petition to be resubmitted to the Board of Appeal within two ( 2) years of unfavorable action by the Board of Appeal, the Planning Board voted unanimously that "Specific and Material Changes" have been made to the petition which was denied by the Board of Appeal . Sincerely, W at-AA /3 Walter B. Power , III Chairman EX\DH\SMC7CLRK Ctu of "inlr t, f ossar4usei#s A Mue �$ fem (>6reen January 7, 1994 Frank Grealish Chairman Board of Appeal One Salem Green Salem, MA 01970 RE: 7 CLARK STREET Dear Mr . Grealish: On January 6, 1994, in accordance with Massachusetts General Law Chapter 40A, Section 16, the Salem Planning Board met to discuss the application of Paul Ferragamo for a "Determination of Specific and Material Change" to his plans for 7 Clark Street which was denied by the Board of Appeal on June 17 , 1992 . Mr . Ferragamo' s amended plan increases the size the lot located at 7 Clark Street from 5,000 square feet to 11,400 square feet. As required by State law for this petition to be resubmitted to the Board of Appeal within two ( 2) years of unfavorable action by the Board of Appeal, the Planning Board voted unanimously that "Specific and Material Changes" have been made to the petition which was denied by the Board of Appeal. Sincerely, W CLQ /3 -pdw-"A 1 Cjk Walter B. Power , III Chairman EX\DH\SMC7CLRK Coity of �5,ttlem, gassar4usetts 3 , January 7, 1994 Frank Grealish Chairman Board of Appeal One Salem Green Salem, MA 01970 RE: 7 CLARK STREET Dear Mr . Grealish: On January 6 , 1994 , in accordance with Massachusetts General Law Chapter 40A, Section 16, the Salem Planning Board met to discuss the application of Paul Ferragamo for a "Determination of Specific and Material Change" to his plans for 7 Clark Street which was denied by the Board of Appeal on June 17, 1992 . Mr . Ferragamo' s amended plan increases the size the lot located at 7 Clark Street from 5 ,000 square feet to 11, 400 square feet. As required by State law for this petition to be resubmitted to the Board of Appeal within two ( 2) years of unfavorable action by the Board of Appeal, the Planning Board voted unanimously that "Specific and Material Changes" have been made to the petition which was denied by the Board of Appeal. Sincerely, Wa wtc /3 -AVILIL%, Walter B. Power , III Chairman EX\DH\SMC7CLRK ��t,cowira'iQ _ (11T##? IIIenT, rR�tt�sttchuse##s q yam. (19r f£ice of t1je CHC Touncif 9�i '•.. ? .'f '� hlitn?�Issll G�» Januar 1 January 9 , 1994 Mr. Francis X. Grealish Board of Appeal City of Salem Salem, Mass . Dear Mr. Grealish: I cannot be in attendance this evening due to a prior commitment. I would however like to inform the members of the Board that I have received several telephone calls from neighbors of the proposed 7 Clark Street lot reconfiguration who are opposed to the plan. It is my hope that the Board of Appeals will pay serious attention to the concerns of the neighborhood with this matter. Thank you for your attention. SVere JUE COUNCILLOR WARD THREE V of �$Mfem, fflassar4usdts eye _ _ b gyp} M�y ♦y� y yNy 2 a A'J�0.414114µ� �YN4� Mm Salem (f)Trrtt January 7 , 1994 Frank Grealish Chairman Board of Appeal One Salem Green Salem, MA 01970 RE: 7 CLARK STREET Dear Mr . Grealish: On January 6, 1994 , in accordance with Massachusetts General Law Chapter 40A, Section 16, the Salem Planning Board met to discuss the application of Paul Ferragamo for a "Determination of Specific and Material Change" to his plans for 7 Clark Street which was denied by the Board of Appeal on June 17 , 1992 . Mr . Ferragamo' s amended plan increases the size the lot located at 7 Clark Street from 5 , 000 square feet to 11 , 400 square feet . As required by State law for this petition to be resubmitted to the Board of Appeal within two ( 2) years of unfavorable action by the Board of Appeal, the Planning Board voted unanimously that "Specific and Material Changes" have been made to the petition which was denied by the Board of Appeal . Sincerely, W /3 - Walter B. Power , III Chairman EX\DH\SMC7CLRK APPEAL CASE NO. . . . . . . . . .. .. .. .. . . . . . .. E fc IIf Uirm. assarfnzsEffs TO THE BOARD OF APPEALS: `he undersigned reoresent that ::e _ are ^.e owners of a certain earcei of land locatec c f10. . .7. .C1arh .St.., .22. A .20. aarnes. .Circle. . . . . . . . . . . . . .=treet: C;,mna DistrictR-L . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . : and said earcei ' s affectea by Sec n ontsj . . . . . . . . . . . . . . . . of the Massacnusetts State Building Code. Plans cescribing the work proposed, have peen submitt__ea to the Inspector of Buildings in accoroance with Section IX A. 1 of the Zoning Ordinance. m -v G Ln The Application for Permit was denied by the Inspector of Buildings for the following reasons: Direct Appeal The Undersigned hereby petitions the Board of Appeals to vary the terms of the Salem Zoning Ordinance and/or the Building Code and order the Inspector of Buildings to approve the application fee permit to build as filed, as the enforcement of said Zoning By-Laws and Building Code would involve practical difficulty or unnecessary hardship to the Undersigned and relief may be granted without substantially dero- gating from the intent and purpose of the Zoning Ordinance and Building Code for the following reasons: See attached Statement In Support of Petition For Variances cn ri I-: a' Paul Ferragamo, Trustee of Owner. . . .T11A F(pXxagamo .Family, cs Address. � 11ighland Ay ,., MA Telephone. ( 5,08), 7,45-09869 ;J PetiticnerPaul Ferragamo . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Address . , 41,9 .Highland Ave. : Salem: MA Date. .September . 29.,. .1993 ( 508 ) 745-0869 Telephone. . . . . . . . . . . . . . . . . . . . . . . . . . . . . By William� H. �eellan IYi Attorney for Paul Ferragamo Three copies of the application must be filed with the Secretary of the Board of Appeals with a check, for advertising in the amount of. . . . . . . . . . . . .. . . . . . . . ... . . four weeks prior to the meeting of the Board of Appeals. Check payable to The Evening News. STATEMENT IN SUPPORT OF PETITION FOR VARIANCES PROPERTY ADDRESSES: 7 Clark Street Barnes Circle and Barnes Circle, Salem, Massachusetts OWNER/PETITIONER: Paul Ferragamo, Trustee of the Ferragamo Family Trust ASSESSOR'S MAP: 3 LOT NOS . : 79 , 88 , 89 DEED REFERENCES: Commonwealth of Massachusetts Land Court , Essex South Registry of Deeds, Southern District, Salem, Massachusetts , Certificate No. 49669 , Registration Book 226 , Page 49669 ( lot 79 ) , Commonwealth of Massachusetts Land Court, Essex South Registry of Deeds , Southern District, Salem, Massachusetts , Certificate No. 49670 , Registration Book 226 , page 49670 ( lot 88 ) , Commonwealth of Massachusetts , Essex Registry of Deeds , Southern District, Salem, Massachusetts , Book 6671 , Page 481 ( lot 89 ) . The Petitioner respectfully requests the variances necessary in order to sell the property known as 7 Clark Street, 22 Barnes Circle and 20 Barnes Circle as three single family lots . The present configuration of the property is depicted on the Citv of Salem Assessor' s Map 3 as lots 79 , 88 and 89 . A copy of said plan is attached hereto as Exhibit "A" . At present the property known as 7 Clark Street which is depicted as lot 79 on Exhibit A has an area of 5 , 000 square feet and a width of 50 feet . The property known as 22 Barnes Circle which is depicted as lot 88 on Exhibit A has an area of 21, 926 square feet and width of 59 feet . The property known as 20 Barnes Circle which is depicted as lot 89 on Exhibit A has an area of 14 , 669 square feet and width of 66 feet . The proposed reconfiguration of the property is depicted .on a plan of land attached hereto as Exhibit "B" . The reconfiguration increases lot area of 7 Clark Street from 5 , 000 square feet to 11,400 square feet decreases the area of 22 Barnes Circle from 21, 926 square feet to 15 , 000 square feet and increases the area of 20 Barnes Circle from 14 , 669 square feet to 15 ,000 square feet . In order to create the reconfigured lots the petitioner requires the following variances from the requirements of Section VI , Table 1 of the City of Salem Zoning Ordinance as follows : 1 . 7 Clark Street, Salem, MA. (City of Salem Assessor' s Map 3 , lot 79 ) Lot area: 11 , 400 square feet from 15 , 000 square feet Lot width: 50 feet from 100 feet 2 . 22 Barnes Circle, Salem, MA. (City of Salem Assessor' s Map 3 , lot 88 ) Lot width: 59 feet from 100 feet 3 . 20 Barnes Circle, Salem, MA. (City of Salem Assessor ' s Map 3 , lot 89 ) Lot width: 66 feet from 100 feet . 2 - Petitioner requests that the variances requested be granted upon a finding by the board that special conditions and circumstances exist which especially effect the parcel of land depicted by the plan of land marked as Exhibit B in that the topography of the land is irregular and such irregularity does not exist generally in this zoning district . Furthermore, that enforcement of the provisions of the ordinance would involve substantial hardship to petitioner because the land will not be developed for a use that is reasonable and consistent with the character of the neighborhood and that the desired variances may be granted without detriment to the public good and without nullifying or derogating from the intent of the zoning-by-law because the proposed use, single family house lots, is consistent with the existing zoning scheme . The neighborhood in which the subject property lies consists mainly of single-family homes , a substantial number of which are on lots significantly smaller in size than those depicted by Exhibit B. The public good will be served by the construction of additional single family homes in this neighborhood as it will make productive use of what is presently vacant land and will serve to further stabilize the character of the area . The present ordinance permits the - 3 - proposed use; granting this petition will neither derogate from the existing ordinance nor be harmful to the public good. Therefore, Petitioner requests that the variances be granted so he may usefully develop this property. Respectfully submitted, Paul Ferragamo, Trustee of the Ferragamo Family Trust, By his Attorney, William H. Sfie6Wn III BBO#: 457060 PEARL, McNIFF, CREAN, COOK & SHEEHAN 30 Main Street Peabody, Massachusetts 01960 Telephone: ( 508 ) 531-1710 Fax No: ( 508 ) 531-4895 Dated: September 29 , 1993 4 - z _OT 75 LOT 89 (Tl AREA = �-n 15 , 000 S . F . i LOT 88 AREA = 15 , 000 S . F . LOT 76 LOT 87 LOT 79 AREA = 117400 S . F . LOT 77 b C� LOT 78 LOT 80 OWNER OF RECORD: PAUI ASS LOT CLARK STREET ZONING DISTRICT R-1 RESIDENTIAL REOUIRED LOT 79 I LOT AREA 15,000 S.F. 11,+00 S.F. 15 LUT WIDTH 100 FT. 50 FT. FRONT ARD 5 FT, 15 FT. SIDE YARD 10 F T 10 FT. REAR ARD 30 FT. 30 FT. of + PLAN OF LAND LaMONIter. `u No.UM SALEM , MASSACH t� PREPARED FOR PAUL FERRAGAMC MINUTES - NNE 3, 1992 page ten 7 CLARK ST. - PAUL FERRAGAMO This request for Variances from frontage, and lot size to allow construction of a single family dwelling was denied originally in 1987, it was denied again in 1989, this denial was appealed in court and has subsequently been remanded back to this Board. The property is located in an R-1 district. Mr. Grealish read the original application. Mr. Bencal: we will be treating this as a new case. Attorney Matthew Kavanaugh, Peabody represented Mr. Ferragamo. When this petition was first present we were not representing Mr. Ferragamo. I took the opportunity to prepare a statement in support of the petition which will give the Board a little more information as far as Mr. Bencal interrupted Mr. Ferragamo at that point and explained that except for two members there was a brand new Board. It is a new petition and you have gentlemen here who are not familiar with this so we are treating it as a new case, I think, if you could present it as a new case. Mr. Kavanaugh submitted copies of his statement to the Board, attached to this statement is a plan "Exhibit A" showing the lot and the proposed dwelling, "Exhibit B" a list of the variances requested. The land is registered land, established back in 1921 and attached as "Exhibit C" is the original plan that shows it as lot 104, that lot still exists , same size also have as "Exhibit B" a copy of today's Assessor's Map. The neighborhood is mainly single family homes and the lots at least on the northerly side are all the same size. As far as hardship, if variance is not granted this land could not be used as single family in an R-1 zone. Mr. Ferragamo lives in the neighborhood. This will be in harmony with the neighborhood. We have a lot that is in an R-1 zone and without variances it cannot be used for single family, cannot be used for anything that would be consistent with the neighborhood. Mr. Bencal: Did Mr. Ferragamo, the owner of the property, which is Hammond Family Trust, did they at anytime own lot 78? Mr. Kavanaugh: yes: Mr. Ferragamo did own lot 78. Mr. Bencal: is that owned by Mr. Ferragamo as trustee for this trust? Mr. Kavanaugh: I believe that was owned by Mr. Ferragamo as trustee of Ferragamo family trust, I could check the deed. Mr. Bencal: is Hammond Family Trust a successor to the Ferragamo trust? Mr. Kavanaugh: a successor in interest? I believe the title of lot 79 was Hammond Family Trust and 78 was Ferragamo Family Trust and I believe the lots were purchased by Mr. Ferragamo as Trustee at approximately the same time. Some were taken as by the Ferragamo Family Trust and some were taken as the Hammond Family Trust. Mr. Bencal: did Mr. Ferragamo come into the Board and ask the Board to get variance for lot 78 to allow it to be built. Mr. Kavanaugh: yes, I believe he did, I did not represent him in that action, I believe he did receive variance to construct a single family on lot 78. Mr. Bencal: so, what he did was take, what, under merger would be a 10,000 sq.ft. lot and created two 5,000 sq.ft. lots and now has created his own hardship. Mir. Kavanaugh: I have had many discussions with Attorney Femino, we have written back and forth, have many cases to support our position that we are entitled to grand- father protection for lot 79, we have agreed to disagree on that point. <o one appeared in favor or in opposition. Hearing closed. MINUTES - JUNE 3, 1992 page eleven 7 CLARK STREET - CONTINUED Mr. Grealish: would you refresh my memory on the grandfathering. Mr. Kavanaugh: the grandfather, the argument basically is, these lots were created prior to 1965, they were not held in common ownership at the time the zoning ordinance was adopted, 1965, they always had separate deeds, never part of the same deed. They did subsequently come into common ownership under the name of Hammond, but it was by separate deed. We say that because they were separate at the time of zoning, we contend they are grandfathered. I do want to make it clear that Mr. Femino disagrees with our position. Mr. Febonio: the letter of the law is one thing but in good faith it some how becomes a scheme. You chopped it up, that's the sticky point, respectfully, and I can' t say it any simpler, he was playing the edge. Mr. Grealish made a motion to grant the petition on condition petitioner comply with all city and state code, regulations, ordinances and statutes, all construction be as per plans and dimensions submitted and with legal building permit, all requirements of the Salem Fire Dept. relative to smoke and fire safety be strictly adhered to, a certificate of occupancy be obtained and property number be obtained from the City of Salem Assessor. Mr. Luzinski seconded. Voting in favor of the motion to grant was Mr. Febonio, Mr. Grealish and Mr. Touchette. Voting in opposition to the motion was Mr.Bencal and Mr. Luzinski. The motion to grant, having failed to garner the required four affirmative votes fails and the petitioners request for Variances is denied by a 3-2 vote. DENIED Minutes of the Board of Appeal meeting of May 20, 1992 unanimously approved. Meeting adjourned at 9 :30 p.m. , next scheduled hearing to be held June 24, 1992, the meeting in July will be held July 22, 1992, on the second floor of One Salem Green. Respectfully submitted, Brenda M. Sumrall Clerk of the Board (gitu of -'-5ttlem, '� Httssttcllusetts 3aQ`�" 9 �nard of ,c�u}�eal MINUTES OF THE BOARD OF APPEAL MEETING - MAY 20 1992 A meeting of the Salem Board of Appeal was held Wednesday, May 20, 1992 at 7:00 p.m. , second floor of One Salem Green. Notices of the hearing were duly advertised in the Salem Evening News on May 6 and May 13, 1992. Abutters and other interested persons were notified by mail. Present at the hearing were Board Members Bencal, Febonio, Grealish, Luzinski, Touchette and Associate Member Plante. Also present at the meeting was the Assistant Building Inspector, D. Harris. The Clerk of the Board was not present due to an injury. The meeting was called to order at 7 :00 p.m. by the Chairman, Richard A. Bencal. Mr. Bencal: before we go to item one there are two pieces of business I would like to get out of the way. I would like to ask the Members of the Board and the audience to stand for a moment of silence, number one for deceased Building Inspector Bill Munroe and secondly, it was just brought to my attention that one of our Board Members, Arthur Labrecque 's wife passed away recently, unbeknownst to most of us. Please stand, we would appreciate it. Thank you. The first item of business is the election of officers. Nominations for Chairman? Mr. Luzinski nominated Mr. Bencal, Mr. Febonio seconded. Mr. Febonio moved to close nominations. Nominations unanimously closed. Mr. Bencal was unanimously elected Chairman. Mr. Luzinski nominated Richard Febonio for Vice Chairman, Mr. Grealish seconded. Mr. Luzinski moved to close nominations, seconded by Mr. Grealish, unanimous. Mr. Febonio elected Vice Chairman unanimously Mr. Luzinski nominated Mr. Grealish for Board Secretary. Mr. Touchette seconded. Mr. Luzinski moved to close nominations, seconded by Mr. Febonio, unanimously closed. Mr. Grealish unanimously elected secretary. Mr. Bencal: at this point in time I would appoint Mr. Plante a voting member. 7 CLARK ST. - ?AUL FERRAGAMO This is a remanded petition regarding Variances from frontage and lot size to allow construction of a single family dwelling in this R-1 district. Mr. Bencai: this petition will not be heard this evening due to the petitioners noncompliance with conditions set forth by the Board of Appeal relative to advertising. The petition will be heard June 3, 1992 . 1 will except a motion at this time for a continuance. '?r. Grealish made a motion MINUTES - MAY 20, 1992 page two 7 CLARK ST. - CONTINUED to continue this petition until June 3, 1992. Mr. Febonio seconded. Mr. Bencai : under discussion I will only make note that under the agreement this Board made with Mr. Ferragamo and his attorney that they bear all advertising costs. They chose not to and chose to cite a law that they felt would relieve them of that act. In fact, the agreement was made legally & binding. On the motion to continue I will call the roll. UNANIMOUSLY CONTINUED UNTIL JUNE 3, 1992 8 MADELINE AVE. - RITA AND ANN MANOOGIAN Petitioners are requesting Variance to convert a single family dwelling into a two family dwelling in this R-1 district. Mr. Grealish read the application, there was no correspondence. Ms. Rita Manoogian represented herself. We own a single family home and want to raise the roof of the house, Ann and I do. I live alone and she wants to move back in and have her own apartment. It's really an inlaw apartment, one of the egress is going to come right into my apartment. I have a problem sleeping at night being all by myself and Ann has a problem worrying about me when she moved out. '.:e are trying to help each other. She submitted a petition in favor signed by 20 persons in the area. Mr. Bencal explained the criteria for proving hardship. Ms. Manoogian did not understand. Mr. Bencal read from the Ordinance the section pertaining to hardship. Mr. Bencal: you must meet all three criteria. Have you consulted with anyone on this? Ms. Manoogian: No. When we decided to do this we did not realize all this was going to happen. Mr. Bencal: unfortunately there are a lot of people who do that and the onus has been put on this Board to attempt to extract exactly what they are looking for and that is not what we are supposed to be doing. Ms. Manoogian: I don' t understand about the land. Mr. Febonio: would it be advisable to have her withdraw and give her a better chance to present her petition at a later date, get her facts and figures together, I don' t think she understood what she had to do or what was necessary and may with this it would give her a better understanding and come in better prepared. Mr. Bencal: Mr. Febonio has suggested that perhaps you would like to withdraw this. _f the Board were to deny this you would not be able to come back for two vears. '?s. Manoogian: I see, so it would be better to withdraw without prejudice. Mr. Bencal: that would give you the opportunity to seek counsel to try to address these items. Councillor O'Leary: would it be possible to continue this . Mr. Bencal: we have nine items on the next meeting Mr. O'Leary. '?r. O'Leary: these people did not confide in an attorney, Wavbe they didn' t need one, I 'm not sure if they need a variance. '^.r. Bencal: they do need a variance. Mr. O'Leary: For an inlaw apartment? Mr. Bencal: there is no such thing as an inlaw apartment. Mr. O'Leary: Okay, this Board in it's wisdom granted one on Barceiona Ave. just a few years ago, they granted it with condition that if the mother moved or married and left the child there they would turn it back to a single family home and they did that. :t worked out fine. Maybe you can give them the same opportunity. 7:r. 2encai asked Mr. Harris how many petitions were pending for the last meeting in June. Mr. Harris: there ' s about four. '^.r. Bencal: if we continued it would probably not be until .;uly. Would that be all right? vr. O'Leary: think that would be f1GItu of �calcilI, c IIS42IC�j1ISrttS JUN -Baura of Au eal 3 e? P/f c , P CjrYofSq 91 CfRK,SCFF/fcSs REMANDED DECISION ON THE PETITION OF PAUL FERRAGAMO FOR A VARIANCE AT 7 CLARK STREET (R-1) A hearing on this petition was held June 3, 1992 with the following Board Members present: Richard Bencai, Chairman; Richard Febonio, Francis Grealish, Edward Luzinski and Stephen Toucette. Notice of the hearing was sent to abutters and others and notices of the hearing were properly published in the Salem Evening News in accordance with Massachusetts General Laws Chapter 40A. Petitioner is requesting Variances to allow the construction of a single family home in this R-1 district. This petition was denied by the Board of Appeal on March 18, 1987 and again on July 5 , 1989 . The latter denial was appealed and subsequently remanded back to the Board by the Court. The Variance which has been requested may be granted upon a finding of the Board that: a. Special conditions and circumstances exist which especially affect the land, building or structure involved and which are not generally affecting other lands, buildings or structures in the same district. b. Literal enforcement of the provisions of the Zoning Ordinance would involve substantial hardship, financial or otherwise, to the petitioner. c. Desirable relief may be granted without substantial detriment to the public good and without nullifying or substantially derogating from the intent of the district or the purpose of the Ordinance. The Board of Appeal, after careful consideration of the evidence presented at the hearing and after viewing the plans, makes the following findings of fact: 1 . The petitioner failed demonstrate or to meet the burden of proof relative to legal hardship. it p /l PTTION OF PAUL ERRAG FORIAIVARIIANCEEATE 7ICLARK STREET,FSALEM�10 Circ O3 02 F S page two 1 C��RKS OFF/�E ss On the basis of the above findings of fact, and on the evidence presented at the hearing, the Board of Appeal concludes as follows : I. Special conditions do not exist which especially affect the subject property and not the district in general. 2. Literal enforcement of the provisions of the Zoning Ordinance would not involve substantial hardship to the petitioner. 3 . The relief requested cannot be granted without substantial detriment to the public good or without nullifying and substantially derogating from the intent of the district or the purpose of the Ordinance. Therefore, the Zoning Board of Appeal voted three (3) in favor two ( 2) opposed to the motion to grant, having failed to garner the required four affirmative votes to pass, the motion is defeated and the petition is denied. VARIANCE DENIED June 3 1992 -�� �)6Z,4t Francis X. Grealish, Jr. , Secretary Board of Appeal 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 MCL CHAPTER 40A AND SHALL BE FILED WITHIN 20 DAYS AFTER THE DATE OF FILING OF THIS DECISION IN THE OFFICE OF THE CITY CLERK. PURSUANT TO MGL CHAPTER 40A, SECTION 11, THE VARIANCE OR SPECIAL PERMIT GRANTED HEREIN SHALL NOT TAKE EFFECT UNTIL A COPY OF THE DECISION BEARING THE CERTIFICATION OF THE CITY CLERK THAT 20 DAYS }LAVE PASSED AND NO APPEAL HAS BEEN FILED, OR THAT, IF SUCH APPEAL HAS BEEN FILED, THAT ITK HAS BEEN DISMISSED OR DENIED IS RECORDED IN THE SOUTH ESSEX REGISTRY OF DEEDS AND INDEXED UNDER THE NAME OF THE OWNER OF RECORD OR IS RECORDED AND NOTED ON THE OWNER'S CERTIFICATE OF TITLE. BOARD OF APPEAL A TAE COPY�U �nx SALEM, MASS. M AUC �'� � l 121 �lJ.[ttJ llf ��IILItI� �.�IiISSiIClillfiCftS `1 y;l ILC �3aurb of AupFul f DECISION ON THE PETITION CF :'AUL =1 VARLAIICEZ AT 7 CLARK CTREET ( R-1 ) hearing on this petition ',:as field July 1189 sjith .he 1C11o:juir_ P.oard Ilember� present; James Fleminc, _.:airman: Iessrc. , 3encai . :ebonto. Lucinski and Ilutttt Notia2 of the hearinf; was c"nt Lo ❑uUCter•; r.':rnd ottler'C allU I'.he heat'inC were 'properly published in L!ie lalem Evening fleas in ;rc-- Jancc arith hlassachusect General Laws Chapter 40A. Petitioner is requesting ':'ariances from Crontnce and tut .;ice to allow construct: of a single family dweilinc to this R-1 district. The Variances which have been requested may be [;ranted upon n finding of the Board that: a. special conditions and circumstances exist which especially affect the land, building or structure involved and which are riot generally affecting other Ends, buildings or structures in the came district; b. literal enforcement of the provisions of the Toning Ordinance would in volve substantial hardship, financial or otherwise, to the petitioner; c. desirable relief may be granted without substantial detriment to the public good and without nullifying, or substantially derogating from th intent of the district or the purpose of the Ordinance. The Board of Appeal , after careful consideration of the evidence presented at t hearing, and after viewing tho plans, ::iakes the Iellow>nr, t'indint;s of fact: 1 . Opposition was voiced by the abutters; 2. A concern regarding blasting on the site was noted; 3 . The traffic problems would be increased b_; the building; 4 . Further development; of the neighborhood would be detrimental. On the basis of the above findings of fact . and on rile evidence presented at tt hearing the Board of Appe_i concludes is follows: 1 . Special cenditicn..s and circumstances do not exist which especially affect the subject property and not the district generally; 2. Literal enforcement of the provisions of the Ordinance would not invol substantial hardship to the petitioner; 3. The relief requested cannot be granted without substantial detriment t the public good or .:ithout nullifyinr or substantially derogating fro the intent of the district or the purpose of the Ordinance. // /7 i/ DECISION ON THE PETITION OF PAUL FaRRAGACIO FOR A VARIANCE AT 7 CLARK ST. , SALEM Therefore, the Zoning Ecarc e[ Aooeai voted unanimousi',, S against grantimr_ the Variances requested. Tile 'Variances are, therefore, denied . Jue to the faiiu of the petitioner to obtain the required four ( 4 ) affirmative Notes. VARIANCES DENIED �,Talnes 11. e ieming, Ssq . , -ila,y'man A COPY OF THIS DECISION IIAS CEEH FiLLD UIT11 'CITE PLAHHIWI 12UAIiD i111D 'CITE (:ItY CLLR Se�Gon 17 of ) ill be r"j, Pursum,l to days relon, II ❑nV• 5 ,, Ilap be Idad wdlnn ZO nPPCJ1 Isom this dcc r 3Ud. ynl 5 file Clt'7 Clrrk. ,nl tolls. 1'.h-ul^ tile ulllc'- at the Mas;. OCnc �y-gin u' t t the pan;mcc I lainr ul 1h15 .i"C 1 9 r,,,•.. . oiler Il of tial'. u �. •. ,. l.r.t cord a r..l•y of d10 fll1:: ('y:arl a', 1.1 ..1 nC! t C,c rl,Vt havC PUI`-u`nl .n. ClC11, JI'M 2U roof Il lh^ I•''-1 :Ills hC"n of jl%ec,u the c.•ruDr JIIGI n' h 'IUP,•.II n1"1. or 111"1. I sue In t", 3nulh C'." •� decrswP, be.v v eel 1,.,5 uean i1em"o Is recorded end no aPP or . u.vner of record or CIJpSCd Len d15n u55ed Inc li,r• n.IluC or II I bled. that It has U un'- IWC. ReB of Us'�-Is ,`nd onetnc ow ucrs C^-r hllcule of sit note) is recorded and OUAIZU OF APPEAL' A TRUE COPY_ ATTEST, CITY CLERK SALEM, MASS. l f•"�Y lCbT1�1 of c caf erll' c7ass22c4uePffs ` s C DttrII a2 ���P221 '87 MV 31 P3 :10 DECISION ON THE PETITION OF DAVID FERRAGAMO ( PETITIONER) , FERRAGAMO FAMILY TRUST (OWNERS) FOR VARIANCE AT 7 CLARK STREET CITY '_ = _ 55 r:MCE �t A hearing on this petition was held March 12, 1987 with the fOinbiring Board Members present: Edward Luzinski, Vice Chairman; Messrs. , Bencal, Fleming, Stro and Associate Member Dore. Notice of the hearing was sent to abutters and other and notices of the hearing were properly published in the Salem Evening News in accordance with Massachusetts General Laws Chapter 40A. Petitioner is requesting variances from frontage, lot size and area per dwelling unit to allow construction of a single family dwelling in this R-1 district. Sa property is owned by the Ferragamo Family Trust. The Variances which have been requested may be granted upon a finding of the Board that: a. special conditions and circumstances exist which especially affect the land, building or structure involved and which are not generally affecting other lands, buildings or structures in the same district; b. literal enforcement of the provisions of the Zoning Ordinance would in- volve substantial hardship, financial or otherwise, to the petitioner; c. desirable relief may be granted without substantial detriment to the public good and without nullifying or substantially derogating from the intent of the district or the purpose of the Ordinance. The Board of Appeal, after careful consideration of the evidence presented at thi hearing, and after viewing the plans, makes the following findings of fact: 1 . Opposition was voiced by the abutters; 2. A concern regarding blasting on the site was noted; 3. The traffic problems would be increased by the building; 4 . Further development of the neighborhood would be detrimental. On the basis of the above findings of fact, and on the evidence presented at the hearing the Board of Appeal concludes as follows: 1 . Special conditions and circumstances do not exist which especially affect the subject property and not the district generally; 2. Literal enforcement of the provisions of the Ordinance would not involvc substantial hardship to the petitioner; 3. The relief requested cannot be granted without substantial detriment Eo the public good or without nullifying or substantially derogating from the intent of the district or the purpose of the Ordinance. DECISION ON THE PETITION OF DAVID FERRAGAMO ( PETITIONER) , FERRAGAMO FAMILY TRUST (OWNER) FOR VARIANCE FOR 7 CLARK ST. , SALEM page two Therefore, the Zoning Board of Appeal voted unanimously, 1-0, against granting the Variances requested. VARIANCES DENIED. Peter Strout, Member, Board of Appeal A COPY OF THIS DECISION HAS BEEN FILED WITH THE PLANNING BOARD AND THE CITY CLER) APPEAL FROM THIS DECISION. IF ANY. SHALL BE MADE PURSUANT TO SEMJN 17 OF THE KISS. GENERAL LAWS. CHAPTER 808. AND SHALL Sc FEED WITHIN 20 DAYS AFTER THE DATE OF FILING OF THIS DECISION IN THE OFFICE OF THE CITY CLERK. PURSA:iT TO "tS. GENERh;. LA'..5. CHP.PTTR 898. SECTION 11. THE VARIANCE OR SPECIAL PER'.:IT GRANTED HEREIN. SHALL NOT T.UIE EFFECT UNTIL A COPY OF +HEN,CAF7EAL HAS BEENHFILEDT FICATION OF THE CITY CLERK THAT 20 DAYS HAVE ELAPSED OR THAT. IF SUCH AN APPEAL HAS BEEN FILE. THAT IT HAS BEEN DIS':ISSED OR GrNIED IS RECORDED IN THE SOUTH ESSEX REGISTRY OF DEEDS AND INDEXED UNDER THE NAME OF THE OF RECORD OR IS RECORDED AND NOTED ON THE OWNER'S CERTIFICATE OF TITLE. BOARD OF APPEAL r PEARL. McNIFF, CREAN. COOK & SHEEHAN ATTORNEYS AT LAW 30 MAIN STREET JOHN M.CREAN PEABODY.MASSACHUSETTS 019605552 MATTHEW J.KAVANAGH OLIVER T.COOK MICHAEL 5. HOULDEN WILLIAM HSHEEHAN 111 PEABODY 15081 531 17 10 LAWRENCE J.O'K EEFE . THOMAS C. REGAN.PC BOSTON 18171289-3456 .MICHAEL L$MERG ZYN SKI,PC FAX 15081 531-4895 SAMUEL PEARL,OF COUNSEL JOHN A.MCNIFF Ov COUNSEL ARTHUR J.FRAWLEY.JR..OF COUNSEL July 2 , 1992 Richard A. Bencal Stephen Touchette 19 Goodell Street 452 Loring Avenue Salem, MA 01970 Salem, MA 01970 CM# P 828 820 001 CM# P 828 820 004 Richard T. Febonio Francis Grealish 4 Arnold Drive 8A Cleveland Road Extension Salem, MA 01970 Salem, MA 01970 CM# P 828 820 002 CM# P 828 820 005 Edward Luzinski 24 Hardy Street Salem, MA 01970 CM# P 828 820 003 Gentlemen: Please take notice that Paul Ferragamo, trustee of the Ferragamo Family Trust has filed in Essex Superior Court an appeal from the June 3 , 1992 decision of the Poard of Appeal of Salem denying his application for a variance . A copy of the complaint filed in Superior Court and a copy of notice filed with the City Clerk is enclosed. Very tr ly yours William H. Sheehan III WHS:ms Enclosures Certified Mail/RRR PEA12L, 1IcNIFF, Cl2EAN, COOK & SlIEEIIAN ATTORNEYS AT LAW 30 MAIN STREET JOHN M.CREAN PEABODY.MASSACHUSETTS 019605552 MATTHEW J. KAVANAGH OLIVER T.COOK MICHAEL S. HOULOEN WILLIAM H.SHEEHAN III PEABOOY(5081531 1710 LAWRENCE J.0 KEEFE THOMAS C.REGA N.PC BOSTON r61 T 2893456 . MICHAEL T.SMERC ZYNSKI,PC FAX r5O815314895 SAMUEL PEARL OF COUNSEL JOHN A.MCNIFF.OF COUNSEL ARTHUR J.FRAWLEY.JR..OF COUNSEL July 2 , 1992 Ms . Josephine Fusco Salem City Hall City Clerk' s Office 93 Washington St . Salem, MA 01970 Re: Paul Ferragamo, Trustee of the Ferragamo Family Trust Vs : Richard Bencal , et als Dear Ms . Fusco: You are hereby notified, pursuant to M.G. L. c . 40A, 517 , that an action has been filed in the Essex Superior Court appealing from the denial of a variance by the Board of Appeal of the City of Salem sought by the plaintiff Paul Ferragamo, Trustee of the Ferragamo Family Trust , for their property at 7 Clark Street, Salem, Massachusetts . A copy of the complaint is attached to this notice . Very truly yours , Ix William H. Sheeha III Enclosure WHS :aml COMMONWEALTH OF I.ASSACHUSETTS Essex, ss . Superior Court Department Civil Action No . 40—;P--# 2 PAUL FERRAGAMO, TRUSTEE ) OF THE FERRAGAMO FAMILY ) TRUST, ) PLAINTIFF ) VS. ) RICHARD BENCAL, ET ALS ) AS THEY ARE MEMBERS OF ) THE SALEM BOARD OF ) APPEAL, ) DEFENDANTS ) COMPLAINT AND JURY DEMAND Now comes the plaintiff Paul Ferragamo , Trustee of the Ferragamo Family Trust, and complains and says as follows : COUNT I (APPEAL FROM DENIAL OF VARIANCE, G.L. , c . 40A, SECTION 17) 1 . The plaintiff Paul Ferragamo resides at 419 Highland Avenue, Salem, Massachusetts . 2 . The defendant Salem Board of Appeal ( hereafter "Board" ) was . at all times material hereto , comprised of the following individuals : Richard Bencal , 19 Goodell Street, Salem, MA Richard Febonio, 4 Arnold Drive, Salem, MA Francis Grealish, 9A Cleveland Road Extension, Salem, MA Edward Luzinski , 24 Hardv Street , Salem, MA Stephen Touchette , 452 Loring Avenue , Salem, f•1A 3 . The plaintiff is the owner of real estate located at 7 Clark Street , Salem, Massachusetts ( hereafter "the premises " ) , and is a party aggrieved within the meaning of G.L. , c . 40A, Section 17 , by the decision of the Board dated June 3 , 1992 , and filed with the Salem City Clerk on June 17 , 1992 , a certified copy of which decision is attached hereto and marked "A" , denying the plaintiff ' s application for a variance to construct a single-family home on the premises . 4 . On or about May 22 , 1989 , the plaintiff filed an application for a variance from the lot area and frontage requirements of the Salem Zoning Ordinance so as to permit the plaintiff to construct a single-family home on the premises . The variance sought was necessary because the City of Salem maintained that lot was undersized . 5 . The Board conducted an initial hearing of said application on July 5 , 1989 , and voted to deny the request for variance, which decision was filed with the City Clerk as aforesaid, a copy of which decision is attached hereto and marked "B" . 6 . An appeal from the denia' of plaintiff ' s request for variance was filed with this court on or about September 12 , 1989 . On or about April 15 , 1992 , the parties agreed to annul the decision of the Board of Appeal and to remand the application for variance to the Board for further proceedings without the necessity of bringing a new application. A copy of the Agreement for Judgment is attached hereto , incorporated herein and marked 'C " . 7 . The Board conducted a subsequent hearing of said application on June 3 , 1992 , and voted to deny the request for -2- variance , which decision was filed with the City Clerk as aforesaid. 8 . The Board' s denial on June 3 , 1992 , of the plaintiff ' s application for variance exceeded the Board' s authority and was arbitrary, capricious and without support in law or fact in that the plaintiff established that due to the shape, size and topography of his land, the plaintiff , without the requested variance, would be unable to construct a single-family home or any other improvement on the premises , thus incurring great economic waste and hardship and that said variance application was no different from many identical and similar applications in the same and surrounding neighborhoods which have been granted by the Board and the plaintiff ' s application could have been granted without any detriment to the public good and without in any way nullifying or derogating from the intent and purpose of the zoning by-law. 9 . The Board based its decision on factors which are totally irrelevant and immaterial to the statutory issues involved in a variance application; the decision is unsupported by evidence presented at the hearing; thus , the Board ' s decision is contrary to law, in excess of its authority, arbitrary and capricious . 10 . The Board',s denial , premised as it is on irrelevant: and immaterial matters , is in excess of its authority because the Board failed to exercise in accordance with law the discretion granted to it by G . L. , c . 40A and the -3- Salem Zoning Ordinance . WHEREFORE , the plaintiff demands the following relief : 1 . That the decision of the defendant Board of Appeal be annulled; 2 . That this Court enter an order directing the defendant Board of Appeal to issue the requested variance to the plaintiff; 3 . That the plaintiff be granted the costs of this appeal because the defendant Board of Appeal acted with gross negligence, in bad faith , or with malice in denying the plaintiff ' s request for variance ; and 4 . In the alternative, that this matter be remanded to the Board of Appeal so that it can exercise the discretion granted to the Board by M.G.L.. , c . 40A. 5 . For such other relief as this Court may deem meet and just . COUNT II (DAMAGES AND LAND 'PARING) 11 . The plaintiff repeats and realleges and incorporates herein by reference the allegations of Paragraphs 1 through 10 of the Complaint . 12 . The defendant City of Salem is a municipal corporation with a usual place of business at 93 Washington Street, Salem, Massachusetts . 13 . The premises at 7 Clark Road , Salem, Massachusetts are legally described as follows : -4- That certain parcel of land situate in Salem, in the County of Essex and said Commonwealth of Massachusetts , bounded and described as follows : SOUTHERLY by Clark Street , Eifty ( 50 ) feet ; EASTERLY by lot 105 , as shown on plan hereinafter mentioned one hundred ( 100 ) feet; NORTHERLY by lots 229 and 230 , as shown on said plan, fifty ( 50 ) feet; and WESTERLY by lot 103 , as shown on said plan, one hundred ( 100 ) feet . All of said boundaries are determined by the Court to be located as shown upon plan numbered 7159-8, drawn by Eastman & Bradford, Civil Engineers , dated May 1 , 1918 , as modified and approved by the Court , filed in the Land Registration Office, a copy of a portion of which is filed with Certificate of Title #3862 in said registry, and the above described land is shown as lot #104 , sheet 2 , on last mentioned plan. So much of the above described land as is included within the! limits of said Clark Street, is subject to its use by all persons lawfully entitled thereto, as described in Certificate of Title #3862 , and there is appurtenant thereto the right to use all the streets and ways shown on said plan, in common with others entitled thereto . 14 . The action of the Board in denying the plaintiff 's application for variance leaves the plaintiff without any possible use to be made of the premises by }rim. 15 . The action of the Board in denying the plaintiff ' s application for variance de facto applies the premises to public use in that the non-development of the plaintiff 's premises , which abuts city-owned land, will result in benefits to the surrounding neighborhood and the general public . 16 . The action of the Board constitutes a taking of the plaintiff ' s premises for public use by the Board and defendant City of Salem, but such taking was riot effected by -5- or in accordance with a formal vote or order of the Board of Officers of a body politic duly authorized by law. 17 . The defendants Board and City of Salem paid no money or lawful consideration to the plaintiff for the premises . 18 . As a result of the actions and taking of said defendants , the plaintiff has suffered great monetary damage. WHEREFORE , the plaintiff prays and demands as follows : 1 . That this Honorable Court declare that the actions of the defendants culminating on June 3 , 1992 , constitute a taking of plaintiff ' s land within the meaning of Mass . Gen. Laws , c . 79 and the applicable provisions of the United States Constitution and the Massachusetts Declaration of Rights . 2 . Judgment that the loss , injury and damage sustained by the plaintiff on account of the abovesaid acts of the defendants be inquired into, determined and ascertained, and that damages be assessed therefor and that the *Tial of this complaint for the assessment of its damage may be by jury. 3 . For such other relief as this Honorable Court deems meet and just . COUNT III (DECLARATION RELIEF AS TO PLAINTIFF'S RIGHT TO BUILDING PERMIT PURSUANT TO M.G.L. C . 40A, 56 AND THE CITY OF SALEM ZONING ORDINANCE) 19 . The plaintiff repeats and realleges and incorporates herein by reference the allegations of paragraphs -6- 1 through 18 of the Complaint . 20 . The City of Salem' s Zoning Ordinance ( hereinafter "Ordinance " ) was enacted on or about August 27 , 1965 . 21 . The premises constitute a non-conforming lot, within the meaning of G.L . , c . 40A, §6 and the Salem Zoning Ordinance, which lot is for a single-family use, has fifty feet of frontage, and contains five thousand square feet. 22 . Pursuant to said G . L. , c . 40A, 56 , the plaintiff is entitled, as a matterof law, to a building permit for a single-family home on the premises . Wherefore , the plaintiff demands the following relief : 1 . That this Court enter an order directing the City of Salem, through its Building Inspector or other appropriate authority, to issue a building permit for the subject property forthwith. 2 . For such other and further relief as this Court may deem meet and just . PLAINTIFF DEMANDS A TRIAL BY JURY. -7- Respectfully submitted, Paul Ferragamo , Trustee of the Ferragamo Family Trust , By his Attorney, William H . Sheehan III Matthew J . Kavanagh PEARL, McNIFF , CREAN, COOK & SHEEHAN 30 Main Street Peabody, Massachusetts 01960 Telephone : ( 508 ) 531-1710 Dated: -8- } � �U COMMONWEALTH OF MASSACHUSETTS \ y Essex, s1s . Superior Court partment Civil Action N 2 F UL FERRAGAMO,,-TRUSTEE ) - , TH�RR$GAM0 FAMILY ) UST ) PLAINTIFF ) VS. ) �\ RICHARD BENGAL, ET ALS ) AS THEY ARE MEMBERS OF ) THE SALEM BOARD OF ) y APPEAL, ) 1 DEFENDANTS ) \ V V AGREEMENT FOR JUDGMENT Now come the parties and stipulate and agree that the following entry be made upon the docket : The decision of t, Board of Appeal is annulled and the matter is remanded to th( Board of Appeal for further proceedings without the necessit i Iof bringing a new application . The Superior Court shall retain jurisdiction of this matter . Each party to bear its own costs . All rights of appeal are waived. " ii Respectfully submitted, Paul Ferragamo , Trustee as aforesaid, By his Attorney, William H . Sheehan II #457060 PEARL , :IcNIFF , CREAN, COOK & SHEEHAN 30 Clain Street Peabody, Massachusetts 01960 Telephone : ( 508 ) 531-1710 i 11101 I,VM, \ v• .,.uvu.n..• - CIVIL ACTION COVER SHEET SUPERIOR COURT DEPARTMENT Essex Division i °LOIN TIF F(S) DEFENDANT(SI Paul Ferragamo, Trustee of the Ferraqamo Richard Bencal , et aLs, as they are the Family Trust '' Salem Board of Appeals ATTORNEY(S) FIRM NAME. ADDRESS AND TEL.) ( 508) 531-1710 ATTORNEY(S) (if known) Lliam H. Sheehan III, Esquire pearl, McNiff, Crean, Cook & Sheehan ;O Main Street; Peabody, MA 01960 Board of Bar Overseers # (Required) 457060 ORIGIN CODE AND TRACK DESIGNATION Place an u in one box only: I :cxx1. F01 Original Complaint !, U 4, F04 District Cf. Appeal c231, s. 97 (X) 1 2. F02 Removal to Sup. Cf. c231, s. 104 (F) I 5. F05 Reactivated after Rescript: Relief from — 'J 3. F03 Retransfer to Sup. Ct. c231, s. 102C (X) ijudgment/order (Mass. R Civ. P. 60 (X) 6. E10 Summary process appeal (X) TYPE OF ACTION AND TRACK DESIGNATION (See Reverse Side) CODE NO. TYPE OF ACTION (specify) TRACK IS THIS A JURY CASE? —raz— v or,i nq_Appea_L,_G_L_c_40A__ ______ (F ) km Yes 11 No 1. PLEASE GIVE A CONCISE STATEMENT OF THE FACTS: (Required in ALL Types of Actions) The Salem IIoard.oE Appeal denied the plaintiff's application for variance, which denial was arbitrary, capricious and in excess of its authority and constituted a de facto taking of plaintiff's property. Furthermore, the plaintiff is entitled to a building permit as a matter of right. i 2. IN A CONTRACT ACTION (CODE A) OR A TORT ACTION (CODE B) STATE, WITH PARTICULARITY, MONEY DAMAGES WHICH WOULD WARRANT A REASONABLE LIKELIHOOD THAT RECOVERY WOULD EXCEED S25,000: N/A I 3. PLEASE IDENTIFY, BY CASE NUMBER. NAME AND DIVISION. ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT. None. i SIGNATURE OF ATTORNEY OF RECORD OR PLAINTIFF DATE DISPOSITION RECEIVED A. Judgment Entered u. No Judgment Entered BY: 1. Before jury trial or non-jury hearing Ll 6. Transferred to District DATE ❑ 2. During jury trial or non-jury hearing Court under G.L. c.231, O)SFD910ON EN)cnED 3. After jury verdict s.102C. L 4. After court finding Disposition Date BY 5. After D,st trial motion DATE. I h \QhO� m m m m NO M p m m m DO p N Q W W W W roh W W W - � a� . 753,5 a o �^09A c �0 / rp 00 e< 9 ca % N Cto) Q (O o � 6 r, oa. ryti � 9: / CJ so 00 / 00 �S 0 0 o `Q. O CP 2r B `y3 co i A ��b W>o O/ //� n O 06 � 0b v~j 60,6 M o oPr b a M d71 \v r OD 60 m X76b0r gg ti CD a�C O w 6 o Al 110 �o J� a �m z e4b ^o,/ /o M Pro b 1 N &ID N / Os `O Ike, Clo Y �D fVR • BOARD OF ASSESSORS PAGE, CITY HALL 77,—Z fl-.MIA" TY970 eSeSBaa, ftPPa'3n 71 2 0 W�A& ',,4 -f T�5/,90S' ,;' i vi 3 IT' I W4,"m 4 0s SUBJECT PROPERTY: MAP" 03 LOT: 0079 SUFF. �;2 OXWX44 6 PROPERTY ADDRESS. 0007 CLARK STREET /11¢ ;2 .1 0 N Ef R I=IA*Pl PIT)Pill-F-AP I'M7Y-T-R M;T-r 7 -,"r;9,.j*RAGAM(,;0 PAWL� ,WR 8 �...... .... 2"; 10 lFifir PRVPE-RT-Y-'AUDRE-SS- T NG LAD&R&SS�� 2 0 11L4 0 — 03 0079 0007 CLARK STREET HAMMOND FAMILY TRUST 419 HIGHLAND AVENUE 15 12 ZE:RRAGAkA,,--2AUL-TR SALEWjjA n 16 13 b,f6,Ui, DRIVE- 14 e A` 15 Nd. Ho 77: - QVX J-UNLLC2F-, 16 Ll 0 — 0 17 03 (10761 O76 049 HIGHLAND AVENUE HAMMOND FAMILY TRUST THE 419 HIGHLAND AVENUE RZE.RRAGAM0,2it,� 11 Lt 22-T 41 7 9 2,7� 1"�pr 4 *W vu �,4 CLARKL2,3 0077" 0003 ST ,RE JABER,SAM: a M-V, �,V X" 0, . 8 -90 -GL-AR*�-SXR& 2 PATRICIA A SALEM MA 01970 3 03 0079 0007 CLARK STREET HAPIMOND FAMILY TRUST 419 HIGHLAND AVENUE 4 Pr'PPArAPA0-P-AUL �SALE4,410,9-,.1 977-Q $ @ 3` 0080-- qp09 CLARK SA L.)F�.M, ITY,,�6F��',,I 3 z X 0 0 0-.1H 1610.15 Ql,ARh�-S-TBEEn NOR a LYNN MA 01905 9 0 F ! o 9 03 0082 00226 BARNES CIRCLE R J S REALTY TRUST' 60 CHILDS ST 0 0 ;L.IAN-RS:t@�E L-1��4 #,T 4 LIAN-JIM Ct 41 992 -,C MASEL.L.A-Sl IRCLL, m7- .,�,,,,BARNES . 2 1'KA, 33 ME '.CI' OLE-- "S,0648=BARUE p 0 3 MARIE R SALEM PIA 01970 3j 03 0091 0016 BARNES CIRCLE DAMATO PANFILO 16 BARNES CIRCLE rl� -,7,, ,-, �, , , " ,,Q p�q'OsE,p, SALEM 0,A -1 37 —7-- , -CIRCL, 001%9 aARN'E S. MIL, ...... ALEPI,gPIA-04,9,7&�, v K -T s""fid f, �&r.,Kj 1=0�" 4;,T-,RF,,RTAA 9: cl�,"I nlnn,;Q 0 SALEM PIA 0-1970 0 41 03 0138 0011 CLARK STREET MASELLA STEPHEN J 24 BARNES CIRCLE 2 PE GGY E - P L-AD 61-1.) R SALEM PI 0197D 00 3 4 4, "a v "i 4 5za AHIZ 46 0 T7 • 48 9 X t K 4 0 K,V .... 2 3 4 ETE Rll,, C ARM% C • V DATE OF P.EAR:NG �d` / C ETIT_IONER �f��4��J / � % .O'CATION 7OTION: TO GRANT r/ SECOND J i TO DENY / SECOND TO RE-HEAR SECOND LEAVE TO WITHDRAW SECOND 70 CONTINUE SECOND POLL CALL PRESENT GRANT DENY WITHDRAW RE-HEAR CONTINUE STEPHEN T GRADY GEORGE A. AHMED FRANCIS GREALISH STEPHEN T?UCHETTE ASSOCIATE :MEMBERS R ARTHUR LABRECOUE CONDITION0,Qlan _ APPEAL CASE NO. . . . . . . . . . . . . .. . . . . . . . . . (9if>s of 15ttlrm, C�Httssar4useffs TO THE BOARD OF APPEALS: The Undersigned represent that he is are the owners of a certain parcel of land located at No. .7. .c,�axk .st:,,.zz ,&20,Barnes Circle„ Street; Coning DistrictR-1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ; and said parcei is affected by Sectionjs ) . . . . . . . . . . . . . . . . of the Massachusetts State Building Code. Plans describing the work proposed, have been submitted to the Inspector of Buildings in accordance with Section IX A. 1 of the Zoning Ordinance. • � m -o r m o ca t^ b, un r U1 CD N W The Application for Permit was denied by the Inspector of Buildings for the following reasons: Direct Appeal The Undersigned hereby petitions the Board of Appeals to vary the terms of the Salem Zoning Ordinance and/or the Building Code and order the Inspector of Buildings to approve the application fee permit to build as filed, as the enforcement of said Zoning By-Laws and Building Code would involve practical difficulty or unnecessary hardship to the Undersigned and relief may be granted without substantially dero- gating from the intent and purpose of the Zoning Ordinance and Building Code for the following reasons: See attached Statement In Support of Petition For Variances Ck- LLJ Uj Ln '—_j Ca W o Paul Ferragamo, Trustee of a 'n The Ferragamo Family Trust co N Owner. . Address.419. Highland Ave. , Salem, MA Telephone. . .(•508.) 745-0869 Paul Fe Petitioner. . . . . . . . . . . . . .rragamo. . . . . . . . . . . . . . . . . . . . Address.419 Highland Ave. , Salem; MA Date. . ,September . . . 1. ( 508 ) 745-0869 Telephone. . . . . . . . . . . . ByGfilliam 'ee "ri, TI'.. . . . . . . . . . . Attorney for Paul Ferragamo Three copies of the application must be filed with the Secretary of the Board of Appeals with a check, for advertising in the amount of. . . . . . . . . . . . . . . . . . . . . .. . . . four weeks prior to the meeting of the Board of Appeals. Check payable to The Evening News. NO... ...... ....................... PETIT ION 10 HOARD OE APPI;A LS LOCA I ION ...........I................... ....................... Pul 111 ON ER.................. ....................... ADDRESS......... ......... .. ... ................................................ CONDI I IONS ............... .......... ...... .......--....... ................. .. ............... .......................................................... .................................... ................-- ..............I.............. ..........I........................ ................................. ...................... PETITION APPROVED.................... ❑ DENIED... . ......... ......... ........................................ 19......... f STATEMENT IN SUPPORT OF PETITION FOR VARIANCES PROPERTY ADDRESSES: 7 Clark Street Barnes Circle and Barnes Circle, Salem, Massachusetts OWNER/PETITIONER: Paul Ferragamo, Trustee of the Ferragamo Family Trust ASSESSOR'S MAP: 3 LOT NOS. : 79 , 88, 89 DEED REFERENCES: Commonwealth of Massachusetts Land Court, Essex South Registry of Deeds, Southern District, Salem, Massachusetts, Certificate No. 49669, Registration Book 226, Page 49669 (lot 79) , Commonwealth of Massachusetts Land Court, Essex South Registry of Deeds, Southern District, Salem, Massachusetts, Certificate No. 49670, Registration Book 226, page 49670 ( lot 88) , Commonwealth of Massachusetts, Essex Registry of Deeds , Southern District, Salem, Massachusetts, Book 6671, Page 481 ( lot 89) . The Petitioner respectfully requests the variances necessary in order to sell the property known as 7 Clark Street, 22 Barnes Circle and 20 Barnes Circle as three single family lots . The present configuration of the property is depicted on the City of Salem Assessor's Map 3 as lots 79, 88 and 89 . A copy of said plan is attached hereto as Exhibit "A" . At present the property known as 7 Clark Street which is depicted as lot 79 on Exhibit A has an area of 5, 000 square feet and a width of 50 feet. The property known as 22 Barnes Circle which is depicted as lot 88 on Exhibit A has an area of 21,926 square feet and width of 59 feet. The property known as 20 Barnes Circle which is depicted as lot 89 on Exhibit A has an area of 14, 669 square feet and width of 66 feet. The proposed reconfiguration of the property is depicted on a plan of land attached hereto as Exhibit "B" . The reconfiguration increases lot area of 7 Clark Street from 5, 000 square feet to 11,400 square feet decreases the area of 22 Barnes Circle from 21,926 square feet to 15, 000 square feet and increases the area of 20 Barnes Circle from 14 ,669 square feet to 15, 000 square feet. In order to create the reconfigured lots the petitioner requires the following variances from the requirements of Section VI, Table 1 of the City of Salem Zoning Ordinance as follows: 1 . 7 Clark Street, Salem, MA. (City of Salem Assessor's Map 3, lot 79) Lot area: 11,400 square feet from 15, 000 square feet Lot width: 50 feet from 100 feet 2 . 22 Barnes Circle, Salem, MA. (City of Salem Assessor's Map 3, lot 88) Lot width: 59 feet from 100 feet 3 . 20 Barnes Circle, Salem, MA. (City of Salem Assessor's Map 3, lot 89 ) Lot width: 66 feet from 100 feet. 2 - Petitioner requests that the variances requested be granted upon a finding by the board that special conditions and circumstances exist which especially effect the parcel of land depicted by the plan of land marked as Exhibit B in that the topography of the land is irregular and such irregularity does not exist generally in this zoning district. Furthermore, that enforcement of the provisions of the ordinance would involve substantial hardship to petitioner because the land will not be developed for a use that is reasonable and consistent with the character of the neighborhood and that the desired variances may be granted without detriment to the public good and without nullifying or derogating from the intent of the zoning-by-law because the proposed use, single family house lots, is consistent with the existing zoning scheme . The neighborhood in which the subject property lies consists mainly of single-family homes, a substantial number of which are on lots significantly smaller in size than those depicted by Exhibit B. The public good will be served by the construction of additional single family homes in this neighborhood as it will make productive use of what is presently vacant land and will serve to further stabilize the character of the area. The present ordinance permits the - 3 - l proposed use; granting this petition will neither derogate from the existing ordinance nor be harmful to the public good. Therefore, Petitioner requests that the variances be granted so he may usefully develop this property. Respectfully submitted, Paul Ferragamo, Trustee of the Ferragamo Family Trust, By his Attorney, //AQ vf� William H. a an III BBO#: 457060 PEARL, McNIFF, CREAN, COOK & SHEEHAN 30 Main Street Peabody, Massachusetts 01960 Telephone: (508) 531-1710 Fax No: (508) 531-4895 Dated: September 29 , 1993 - 4 - .a STATEMENT IN SUPPORT OF PETITION FOR VARIANCES PROPERTY ADDRESSES: 7 Clark Street Barnes Circle and Barnes Circle, Salem, Massachusetts OWNER/PETITIONER: Paul Ferragamo, Trustee of the Ferragamo Family Trust ASSESSOR'S MAP: 3 LOT NOS . : 79 , 88, 89 DEED REFERENCES: Commonwealth of Massachusetts Land Court, Essex South Registry of Deeds, Southern District, Salem, Massachusetts, Certificate No. 49669, Registration Book 226 , Page 49669 ( lot 79 ) , Commonwealth of Massachusetts Land Court, Essex South Registry of Deeds, Southern District, Salem, Massachusetts , Certificate No. 49670, Registration Book 226 , page 49670 ( lot 88 ) , Commonwealth of Massachusetts, Essex Registry of Deeds , Southern District, Salem, Massachusetts, Book 6671, Page 481 ( lot 89 ) . The Petitioner respectfully requests the variances necessary in order to sell the property known as 7 Clark Street, 22 Barnes Circle and 20 Barnes Circle as three single family lots . The present configuration, of the property is depicted on the City of Salem Assessor' s Map 3 as lots 79 , 88 and 89 . A copy of said plan is attached hereto as Exhibit "A" . At present the property known as .7 Clark Street which is depicted as lot 79 on Exhibit A has an area of 5,000 square feet and a width of 50 feet . The property known as 22 Barnes Circle which is depicted as lot 88 on Exhibit A has an area of 21, 926 square feet and width of 59 feet. The property known as 20 Barnes Circle which is depicted as lot 89 on Exhibit A has an area of 14 , 669 square feet and width of 66 feet. The proposed reconfiguration of the property is depicted on a plan of land attached hereto as Exhibit "B" . The reconfiguration increases lot area of 7 Clark Street from 5, 000 square feet to 11,400 square feet decreases the area of 22 Barnes Circle from 21,926 square feet to 15, 000 square feet and increases the area of 20 Barnes Circle from 14 ,669 square feet to 15 , 000 square feet. In order to create the reconfigured lots the petitioner requires the following variances from the requirements of Section VI, Table 1 of the City of Salem Zoning Ordinance as follows : 1 . 7 Clark Street, Salem, MA. (City of Salem Assessor's Map 3, lot 79 ) Lot area: 11,400 square feet from 15, 000 square feet Lot width: 50 feet from 100 feet 2 . 22 Barnes Circle, Salem, MA. (City of Salem Assessor' s Map 3, lot 88) Lot width: 59 feet from 100 feet 3 . 20 Barnes Circle, Salem, MA. (City of Salem Assessor's Map 3, lot 89 ) Lot width: 66 feet from 100 feet. - 2 - Petitioner requests that the variances requested be granted upon a finding by the board that special conditions and circumstances exist which especially effect the parcel of land depicted by the plan of land marked as Exhibit B in that the topography of the land is irregular and such irregularity does not exist generally in this zoning district. Furthermore, that enforcement of the provisions of the ordinance would involve substantial hardship to petitioner because the land will not be developed for a use that is reasonable and consistent with the character of the neighborhood and that the desired variances may be granted without detriment to the public good and without nullifying or derogating from the intent of the zoning-by-law because the proposed use, single family house lots, is consistent with the existing zoning scheme. The neighborhood in which the subject property lies consists mainly of single-family homes , a substantial number of which are on lots significantly smaller in size than those depicted by Exhibit B. The public good will be served by the construction of additional single family homes in this neighborhood as it will make productive use of what is presently vacant land and will serve to further stabilize the character of the area. The present ordinance permits the - 3 - proposed use; granting this petition will neither derogate from the existing ordinance nor be harmful to the public good. Therefore, Petitioner requests that the variances be granted so he may usefully develop this property. Respectfully submitted, Paul Ferragamo, Trustee of the Ferragamo Family Trust, By his Attorney, William H. e n III BBO#: 457060 PEARL, McNIFF, CREAN, COOK & SHEEHAN 30 Main Street Peabody, Massachusetts 01960 Telephone: (508) 531-1710 Fax No: (508 ) 531-4895 Dated: September 29, 1993 - 4 - Ctu of 'Salem' 'Mttssadjusetts Poara of 'Appeal MINUTES OF THE BOARD OF APPEAL MEETING - MAY 20 1992 A meeting of the Salem Board of Appeal was held Wednesday, May 20, 1992 at 7:00 p.m. , second floor of One Salem Green. Notices of the hearing were duly advertised in the Salem Evening News on May 6 and May 13, 1992. Abutters and other interested persons were notified by mail. Present at the hearing were Board Members Bencal, Febonio, Grealish, Luzinski, Touchette and Associate Member Plante. Also present at the meeting was the Assistant Building Inspector, D. Harris. The Clerk of the Board was not present due to an injury. The meeting was called to order at 7:00 p.m. by the Chairman, Richard A. Bencal. Mr. Bencal: before we go to item one there are two pieces of business I would like to get out of the way. I would like to ask the Members of the Board and the audience to stand for a moment of silence, number one for deceased Building Inspector Bill Munroe and secondly, it was just brought to my attention that one of our Board Members, Arthur Labrecque's wife passed away recently, unbeknownst to most of us. Please stand, we would appreciate it. Thank you. The first item of business is the election of officers. Nominations for Chairman? Mr. Luzinski nominated Mr. Bencal, Mr. Febonio seconded. Mr. Febonio moved to close nominations. Nominations unanimously closed. Mr. Bencal was unanimously elected Chairman. Mr. Luzinski nominated Richard Febonio for Vice Chairman, Mr. Grealish seconded. Mr. Luzinski moved to close nominations, seconded by Mr. Grealish, unanimous. Mr. Febonio elected Vice Chairman unanimously Mr. Luzinski nominated Mr. Grealish for Board Secretary. Mr. Touchette seconded. Mr. Luzinski moved to close nominations, seconded by Mr. Febonio, unanimously closed. Mr. Grealish unanimously elected secretary. Mr. Bencal: at this point in time I would appoint Mr. Plante a voting member. 7 CLARK ST. - PAUL FERRAGAMO This is a remanded petition regarding Variances from frontage and lot size to allow construction of a single family dwelling in this R-1 district. Mr. Bencal: this petition will not be heard this evening due to the petitioners noncompliance with conditions set forth by the Board of Appeal relative to advertising. The petition will be heard June 3, 1992. I will except a motion at this time for a continuance. Mr. Grealish made a motion MINUTES - MAY 20, 1992 page two 7 CLARK ST. - CONTINUED to continue this petition until June 3, 1992. Mr. Febonio seconded. Mr. Bencal: under discussion I will only make note that under the agreement this Board made with Mr. Ferragamo and his attorney that they bear all advertising costs. They chose not to and chose to cite a law that they felt would relieve them of that act. In fact, the agreement was made legally & binding. On the motion to continue I will call the roll. UNANIMOUSLY CONTINUED UNTIL JUNE 3, 1992 8 MADELINE AVE. - RITA AND ANN MANOOGIAN Petitioners are requesting Variance to convert a single family dwelling into a two family dwelling in this R-1 district. Mr. Grealish read the application, there was no correspondence. Ms. Rita Manoogian represented herself. We own a single family home and want to raise the roof of the house, Ann and I do. I live alone and she wants to move back in and have her own apartment. It's really an inlaw apartment, one of the egress is going to come right into my apartment. I have a problem sleeping at night being all by myself and Ann has a problem worrying about me when she moved out. We are trying to help each other. She submitted a petition in favor i n s g ed by 20 persons in the area. Por. Bencal explained the criteria for proving hardship. Ms. Manoogian did not understand. Mr. Bencal read from the Ordinance the section pertaining to hardship. Mr. Bencal: you must meet all three criteria. Have you consulted with anyone on this? Ms. Manoogian: No. When we decided to do this we did not realize all this was going to happen. Mr. Bencal: unfortunately there are a lot of people who do that and the onus has been put on this Board to attempt to extract exactly what they are looking for and that is not what we are supposed to be doing. Ms. Manoogian: I don't understand about the land. Mr. Febonio: would it be advisable to have her withdraw and give her a better chance to present her petition at a later date, get her facts and figures together, I don't think she understood what she had to do or what was necessary and may with this it would give her a better understanding and come in better prepared. Mr. Bencal: Mr. Febonio has suggested that perhaps you would like to withdraw this. If the Board were to deny this you would not be able to come back for two years. Ms. Manoogian: I see, so it would be better to withdraw without prejudice. Mr. Bencal: that would give you the opportunity to seek counsel to try to address these items. Councillor O'Leary: would it be possible to continue this. Mr. Bencal: we have nine items on the next meeting Mr. O'Leary. Mr. O'Leary: these people did not confide in an attorney, maybe they didn't need one, I'm not sure if they need a variance. Mr. Bencal: they do need a variance. Mr. O'Leary: For an inlaw apartment? Mr. Bencal: there is no such thing as an inlaw apartment. Mr. O'Leary: Okay, this Board in it's wisdom granted one on Barcelona Ave. just a few years ago, they granted it with condition that if the mother moved or married and left the child there they would turn it back to a single family home and they did that. It worked out fine. Maybe you can give them the same opportunity. Mr. Bencal asked Mr. Harris how many petitions were pending for the last meeting in June. Mr. Harris: there's about four. Mr. Bencal: if we continued it would probably not be until July. Would that be all right? Mr. O'Leary: I think that would be MINUTES - JUNE 3, 1992 page ten 7 CLARK ST. - PAUL FERRAGAMO This request for Variances from frontage, and lot size to allow construction of a single family dwelling was denied originally in 1987, it was denied again in 1989, this denial was appealed in court and has subsequently been remanded back to this Board. The property is located in an R-1 district. Mr. Grealish read the original application. Mr. Bencal: we will be treating this as a new case. Attorney Matthew Kavanaugh, Peabody represented Mr. Ferragamo. When this petition was first present we were not representing Mr. Ferragamo. I took the opportunity to prepare a statement in support of the petition which will give the Board a little more information as far as Mr. Bencal interrupted Mr. Ferragamo at that point and explained that except for two members there was a brand new Board. It is a new petition and you have gentlemen here who are not familiar with this so we are treating it as a new case, I think, if you could present it as a new case. Mr. Kavanaugh submitted copies of his statement to the Board, attached to this statement is a plan "Exhibit All showing the lot and the proposed dwelling, "Exhibit B" a list of the variances requested. The land is registered land, established back in 1921 and attached as "Exhibit C" is the original plan that shows it as lot 104, that lot still exists, same size also have as "Exhibit B" a copy of today's Assessor's Map. The neighborhood is mainly single family homes and the lots at least on the northerly side are all the same size. As far as hardship, if variance is not granted this land could not be used as single family in an R-1 zone. Mr. Ferragamo lives in the neighborhood. This will be in harmony with the neighborhood. We have a lot that is in an R-1 zone and without variances it cannot be used for single family, cannot be used for anything that would be consistent with the neighborhood. Mr. Bencal: Did Mr. Ferragamo, the owner of the property, which is Hammond Family Trust, did they at anytime own lot 78? Mr. Kavanaugh: yes, Mr. Ferragamo did own lot 78. Mr. Bencal: is that owned by Mr. Ferragamo as trustee for this trust? Mr. Kavanaugh: I believe that was owned by Mr. Ferragamo as trustee of Ferragamo family trust, I could check the deed. Mr. Bencal: is Hammond Family Trust a successor to the Ferragamo trust? Mr. Kavanaugh: a successor in interest? I believe the title of lot 79 was Hammond Family Trust and 78 was Ferragamo Family Trust and I believe the lots were purchased by Mr. Ferragamo as Trustee at approximately the same time. Some were taken as by the Ferragamo Family Trust and some were taken as the Hammond Family Trust. Mr. Bencal: did Mr. Ferragamo come into the Board and ask the Board to get variance for lot 78 to allow it to be built. Mr. Kavanaugh: yes, I believe he did, I did not represent him in that action, I believe he did receive variance to construct a single family on lot 78. Mr. Bencal: so, what he did was take, what, under merger would be a 10,000 sq.ft. lot and created two 5,000 sq.ft. lots and now has created his own hardship. Mr. Kavanaugh: I have had many discussions with Attorney Femino, we have written back and forth, I have many cases to support our position that we are entitled to grand- father protection for lot 79, we have agreed to disagree on that point. No one appeared in favor or in opposition. Hearing closed. MINUTES - JUNE 3, 1992 page eleven 7 CLARK STREET - CONTINUED Mr. Grealish: would you refresh my memory on the grandfathering. Mr. Kavanaugh: the grandfather, the argument basically is, these lots were created prior to 1965, they were not held in common ownership at the time the zoning ordinance was adopted, 1965, they always had separate deeds, never part of the same deed. They did subsequently come into common ownership under the name of Hammond, but it was by separate deed. We say that because they were separate at the time of zoning, we contend they are grandfathered. I do want to make it clear that Mr. Femino disagrees with our position. Mr. Febonio: the letter of the law is one thing but in good faith it some how becomes a scheme. You chopped it up, that's the sticky point, respectfully, and I can't say it any simpler, he was playing the edge. Mr. Grealish made a motion to grant the petition on condition petitioner comply with all city and state code, regulations, ordinances and statutes, all construction be as per plans and dimensions submitted and with legal building permit, all requirements of the Salem Fire Dept. relative to smoke and fire safety be strictly adhered to, a certificate of occupancy be obtained and property number be obtained from the City of Salem Assessor. Mr. Luzinski seconded. Voting in favor of the motion to grant was Mr. Febonio, Mr. Grealish and Mr. Touchette. Voting in opposition to the motion was Mr.Bencal and Mr. Luzinski. The motion to grant, having failed to garner the required four affirmative votes fails and the petitioners request for Variances is denied by a 3-2 vote. DENIED Minutes of the Board of Appeal meeting of May 20, 1992 unanimously approved. Meeting adjourned at 9:30 p.m. , next scheduled hearing to be held June 24, 1992, the meeting in July will be held July 22, 1992, on the second floor of One Salem Green. Respectfully submitted, Brenda M. Sumrall Clerk of the Board IMF PEARL, MoNIFF, CREAN, COOK & SHEEHAN ATTORNEYS AT LAW 30 MAIN STREET JOHN M.CREAN PEABODY,MASSACHUSETTS 01960-5552 MATTHEW J.KAVANAGH OLIVER T.COOK MICHAEL S. HOULDEN PEABODY 15081531-1710 WILLIAM H.SHEEHAN III LAWRENCE J.O'KEEFE THOMAS C.REGAN,PC BOSTON 16171289-3456 MICHAEL T.SMERCZYNSKI,PC FAX 15081531-0895 SAMUEL PEARL.OF COUNSEL JOHN A.MCNIFF OF COUNSEL ARTHUR J.FRAWLEY.JR.,OF COUNSEL July 2 , 1992 Richard A. Bencal Stephen Touchette 19 Goodell Street 452 Loring Avenue Salem, MA 01970 Salem, MA 01970 CM# P 828 820 001 CM# P 828 820 004 Richard T. Febonio Francis Grealish 4 Arnold Drive 8A Cleveland Road Extension Salem, MA 01970 Salem, MA 01970 CM# P 828 820 002 CM# P 828 820 005 Edward Luzinski 24 Hardy Street Salem, MA 01970 CM# P 828 820 003 Gentlemen: Please take notice that Paul Ferragamo, trustee of the Ferragamo Family Trust has filed in Essex Superior Court an appeal from the June 3, 1992 decision of the Poard of Appeal of Salem denying his application for a variance. A copy of the complaint filed in Superior Court and a copy of notice filed with the City Clerk is enclosed. Very trgly yours William H. eehan III WHS:ms Enclosures Certified Mail/RRR PEARL, MCNIFF, CREAN, COOK & SHEEHAN ATTORNEYS AT LAW 30 MAIN STREET JOHN M.CREAN PEABODY.MASSACHUSETTS 01960-5552 MATTHEW J. KAVANAGH OLIVER T.COOK MICHAEL S. HOULDEN WILLIAM H.SHEEHAN III PEABODY 15081 531 1710 BOSTON i61>1269-3A56 LAWRENCE J.O-KEEFE THOMAS C.REGAN,PC MICHAEL T.SMERCZYNSKI,PC FAX 15081531 4695 SAMUEL PEARL,OF COUNSEL JOHN A.Mc NIFF,OF COUNSEL ARTHUR J.1FRAWLEY,JR..OF COUNSEL July 2 , 1992 Ms . Josephine Fusco Salem City Hall City Clerk' s Office 93 Washington St . Salem, MA 01970 Re: Paul Ferragamo, Trustee of the Ferragamo Family Trust Vs : Richard Bencal , et als Dear Ms . Fusco: You are hereby notified, pursuant to M.G.L. c . 40A, §17 , that an action has been filed in the Essex Superior Court appealing from the denial of a variance by the Board of Appeal of the City of Salem sought by the plaintiff Paul Ferragamo, Trustee of the Ferragamo Family Trust, for their property at 7 Clark Street, Salem, Massachusetts . A copy of the complaint is attached to this notice . Very truly yours , William H. Slieeha In II Enclosure WHS:aml COMMONWEALTH OF MASSACHUSETTS i Essex, ss . Superior Court Department Civil Action No. -2 PAUL FERRAGAMO, TRUSTEE ) OF THE FERRAGAMO FAMILY ) TRUST, ) PLAINTIFF ) VS. ) RICHARD BENCAL, ET ALS ) AS THEY ARE MEMBERS OF ) THE SALEM BOARD OF ) APPEAL, ) DEFENDANTS ) COMPLAINT AND JURY DEMAND Now comes the plaintiff Paul Ferragamo, Trustee of the Ferragamo Family Trust, and complains and says as follows : COUNT I (APPEAL FROM DENIAL OF VARIANCE G.L. c . 40A, SECTION 17) 1 . The plaintiff Paul Ferragamo resides at 419 Highland Avenue, Salem, Massachusetts . 2 . The defendant Salem Board of Appeal ( hereafter "Board" ) was ;, at all times material hereto, comprised of the following individuals : Richard Bencal , 19 Goodell Street, Salem, MA Richard Febonio, 4 Arnold Drive, Salem, MA Francis Grealish, BA Cleveland Road Extension, Salem, MA Edward Luzinski, 24 Hardy Street, Salem, MA Stephen Touchette, 452 Loring Avenue, Salem, MA I 3 . The plaintiff is the owner of real estate located at 7 Clark Street, Salem, Massachusetts (hereafter "the premises " ) , and is a party aggrieved within the meaning of - i MW G.L. , c . 40A, Section 17 , by the decision of the Board dated June 3 , 1992 , and filed with the Salem City Clerk on June 17 , 1992 , a certified copy of which decision is attached hereto and marked "A" , denying the plaintiff ' s application for a variance to construct a single-family home on the premises . 4 . On or about May 22 , 1989 , the plaintiff filed an application for a variance from the lot area and frontage requirements of the Salem Zoning Ordinance so as to permit the plaintiff to construct a single-family home on the premises . The variance sought was necessary because the City of Salem maintained that lot was undersized . 5 . The Board conducted an initial hearing of said application on July 5, 1989 , and voted to deny the request for variance, which decision was filed with the City Clerk as aforesaid, a copy of which decision is attached hereto and marked "B" . 6 . An appeal from the denia' of plaintiff ' s request for variance was filed with this court on or about September 12 , 1989 . On or about April 15 , 1992 , the parties agreed to annul the decision of the Board of Appeal and to remand the application for variance to the Board for further proceedings without the necessity of bringing a new application. A copy of the Agreement for Judgment is attached hereto, incorporated herein and marked "C" . 7 . The Board conducted a subsequent hearing of said application on June 3 , 1992 , and voted to deny the request for -2- J variance, which decision was filed with the City Clerk as aforesaid. 8 . The Board' s denial on June 3 , 1992 , of the plaintiff ' s application for variance exceeded the Board' s authority and was arbitrary, capricious and without support in law or fact in that the plaintiff established that due to the shape, size and topography of his land, the plaintiff , without the requested variance, would be unable to construct a single-family home or any other improvement on the premises , thus incurring great economic waste and hardship and that said variance application was no different from many identical and similar applications in the same and surrounding neighborhoods which have been granted by the Board and the plaintiff ' s application could have been granted without any detriment to the public good and without in any way nullifying or derogating from the intent and purpose of the zoning by-law. 9 . The Board based its decision on factors which are totally irrelevant and immaterial to the statutory issues involved in a variance application; the decision is unsupported by evidence presented at the hearing; thus, the Board' s decision is contrary to law, in excess of its authority, arbitrary and capricious . 10 . The Board's denial , premised as it is on irrelevant: and immaterial matters, is in excess of its authority because the Board failed to exercise in accordance with law the discretion granted to it by G.L. , c . 40A and the -3- Salem Zoning Ordinance. WHEREFORE, the plaintiff demands the following relief : 1 . That the decision of the defendant Board of Appeal be annulled; 2 . That this Court enter an order directing the defendant Board of Appeal to issue the requested variance to the plaintiff; 3 . That the plaintiff be granted the costs of this appeal because the defendant Board of Appeal acted with gross negligence, in bad faith, or with malice in denying the plaintiff ' s request for variance; and 4 . In the alternative, that this matter be remanded to the Board of Appeal so that it can exercise the discretion granted to the Board by M.G.L. , c . 40A. 5 . For such other relief as this Court may deem meet and just . COUNT II (DAMAGES AND LAND TAILING) 11 . The plaintiff repeats and realleges and incorporates herein by reference the allegations of Paragraphs 1 through 10 of the Complaint . 12 . The defendant City of Salem is a municipal corporation with a usual place of business at 93 Washington Street, Salem, Massachusetts . 13 . The premises at 7 Clark Road, Salem, Massachusetts are legally described as follows : -4- That certain parcel of land situate in Salem, in the County of Essex and said Commonwealth of Massachusetts , bounded and described as follows : SOUTHERLY by Clark Street, fifty ( 50 ) feet; EASTERLY by lot 105 , as shown on plan hereinafter mentioned one hundred ( 100 ) feet; NORTHERLY by lots 229 and 230 , as shown on said plan, fifty ( 50 ) feet; and WESTERLY by lot 103 , as shown on said plan, one hundred ( 100 ) feet . All of said boundaries are determined ,by the Court to be located as shown upon plan numbered 7159-B, drawn by Eastman & Bradford, Civil Engineers , dated May 1 , 1918 , as modified and approved by the Court, filed in the Land Registration Office, a copy of a portion of which is filed with Certificate of Title #3862 in said registry, and the above described land is shown as lot #104 , sheet 2 , on last mentioned plan. So much of the above described land as is included within thE! limits of said Clark Street, is subject to its use by all persons lawfully entitled thereto, as described in Certificate of Title #3862 , and there is appurtenant thereto the right to use all the streets and ways shown on said plan, in common with others entitled thereto. 14 . The action of the Board in denying the plaintiff 's application for variance leaves the plaintiff without any possible use to be made of the premises by him. 15 . The action of the Board in denying the plaintiff ' s application for variance de facto applies the premises to public use 'in that the non-development of the plaintiff 's premises, which abuts city-owned land, will result in benefits to the surrounding neighborhood and the general public . 16 . The action of the Board constitutes a taking of the plaintiff ' s premises for public use by the Board and defendant City of Salem, but such taking was not effected by -5- or in accordance with a formal vote or order of the Board of Officers of a body politic duly authorized by law. 17 . The defendants Board and City of Salem paid no money or lawful consideration to the plaintiff for the premises . 18 . As a result of the actions and taking of said defendants, the plaintiff has suffered great monetary damage . WHEREFORE, the plaintiff prays and demands as follows : 1 . That this Honorable Court declare that the actions of the defendants culminating on June 3 , 1992 , constitute a taking of plaintiff ' s land within the meaning of Mass . Gen. Laws, c . 79 and the applicable provisions of the United States Constitution and the Massachusetts Declaration of Rights . 2 . Judgment that the loss , injury and damage sustained by the plaintiff on account of the abovesaid acts of the defendants be inquired into, determined and ascertained, and that damages be assessed therefor and that the trial of this complaint for the assessment of its damage may be by jury. 3 . For such other relief as this Honorable Court deems meet and just . COUNT III (DECLARATION RELIEF AS TO PLAINTIFF'S RIGHT TO BUILDING PERMIT PURSUAMT TO M.G.L. C.40A, §6 AND THE CITY OF SALEM ZONING ORDINANCE) 19 . The plaintiff repeats and realleges and incorporates herein by reference the allegations of paragraphs -6- 1 through 18 of the Complaint . 20 . The City of Salem' s Zoning Ordinance (hereinafter "Ordinance" ) was enacted on or about August 27 , 1965 . 21 . The premises constitute a non-conforming lot, within the meaning of G.L. , c . 40A, §6 and the Salem Zoning Ordinance, which lot is for a single-family use, has fifty . feet of frontage, and contains five thousand square feet. 22 . Pursuant to said G.L. , c . 40A, §6 , the plaintiff is entitled, as a matterof law, to a building permit for a single-family home on the premises . Wherefore, the plaintiff demands the following relief : 1 . That this Court enter an order directing the City . of Salem, through its Building Inspector or other appropriate authority, to issue a building permit for the subject property forthwith. 2 . For such other and further relief as this Court may deem meet and just . PLAINTIFF DEMANDS A TRIAL BY JURY. -7- Respectfully submitted, Paul Ferragamo, Trustee of the Ferragamo Family Trust, By his Attorney, William H. Sheehan III Matthew J. Kavanagh PEARL, McNIFF, CREAN, COOK & SHEEHAN 30 Main Street Peabody, Massachusetts 01960 Telephone: ( 508 ) 531-1710 Dated: -8- � COMMONWEALTH OF MASSACHUSETTS Essex, s1s . Superior Court tment Civil Action N .l P UL FERRAGAMO, TRUSTEE ) FT E E O FAMILY U ) vill - PLAINTIFF ) vs. ) \ RICHARD BENCAL, ET ALS ) AS THEY ARE MEMBERS OF ) `h THE SALEM BOARD OF ) APPEAL, ) c\ " DEFENDANTS ) v AGREEMENT FOR JUDGMENT I Now come the parties and stipulate and agree that the following entry be made upon the docket : "The decision of the Board of Appeal is annulled and the matter is remanded to the Board of Appeal for further proceedings without the necessity of bringing a new application. The Superior Court shall retain jurisdiction of this matter. Each party to bear its own costs . All rights of appeal are waived. " Respectfully submitted, Paul Ferragamo, Trustee as aforesaid, By his Attorney, I 7 (� William H. Sheehan II #457060 PEARL, McNIFF, CREAN, COOK & SHEEHAN 30 Main Street Peabody, Massachusetts 01960 Telephone: ( 508 ) 531-1710 11101 VV CIVIL ACTION COVER SHEET SUPERIOR COURT DEPARTMENT Essexs Division " PLAINTIFF(S) DEFENDANT(S) Paul Ferragamo, Trustee of the Ferragamo Richard Bencal, et als, .as they are the Family Trust Salem Board of Appeals ATTORNEYS)FIRM NAME,ADDRESS AND TEL.) (508) 531-1710 ATTORNEY(S)(if known) William H. Sheehan III, Esquire Pearl, McNiff, Crean, Cook & Sheehan 30 Main Street; Peabody, MA 01960 Board of Bar Overseers # (Required) 457060 ORIGIN CODE AND TRACK DESIGNATION Place an OO in one box only: fixl. F01 Original Complaint ❑ 4. F04 District Ct. Appeal c231, s. 97 (X) ❑ 2. F02 Removal to Sup. Ct. c231, s. 104 (F) ❑ 5. F05 Reactivated after Rescript; Relief from ❑ 3. F03 Retransfer to Sup. Ct. c231, s. 102C (X) judgment/order (Mass. R Civ. P. 60 (X) ❑ 6. E10 Summary process appeal (X) TYPE OF ACTION AND TRACK DESIGNATION (See Reverse Side) CODE NO. TYPE OF ACTION (specify) TRACK IS THIS A JURY CASE? —CO2— 7nni ng_lppeal,—G__1__c 10A_ _- (F ) ±)dx Yes No I 1. PLEASE GIVE A CONCISE STATEMENT OF THE FACTS: (Required in ALL Types of Actions) The Salem Board of Appeal denied the plaintiff's application for variance, which denial was arbitrary, capricious and in excess of its authority and constituted a de facto taking of plaintiff's property. Furthermore, the plaintiff is entitled to a building permit as a matter of right. 2. IN A CONTRACT ACTION (CODE A) OR A TORT ACTION (CODE B) STATE, WITH PARI ICULARITY, MONEY DAMAGES WHICH WOULD WARRANT A REASONABLE LIKELIHOOD THAT RECOVERY WOULD EXCEED $25,000: N/A i 3. PLEASE IDENTIFY, BY CASE NUMBER, NAME AND DIVISION, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT. None. i I SIGNATURE OF ATTORNEY OF RECORD OR PLAINTIFF DATE { � 1 • 111 DISPOSITION - I RECEIVED A. Judgment Entered B. No Judgment Entered BY. ❑ 1. Before jury trial or non-jury hearing ❑ 6. Transferred to District DATE ❑ 2. During jury trial or non-jury hearing Court under G.L. c.231, ❑ DISPOSITION ENIEneD 3. After jury verdict s.102C. ❑ 4. After court finding Disposition Date BY: ❑ 5. After post trial motion DATE: STATEMENT IN SUPPORT OF PETITION FOR VARIANCES PROPERTY ADDRESSES: 7 Clark Street Barnes Circle and Barnes Circle, Salem, Massachusetts OWNER/PETITIONER: Paul Ferragamo, Trustee of the Ferragamo Family Trust ASSESSOR'S MAP: 3 LOT NOS. : 79 , 88 , 89 DEED REFERENCES: Commonwealth of Massachusetts Land Court, Essex South Registry of Deeds, Southern District, Salem, Massachusetts, Certificate No. 49669, Registration Book 226 , Page 49669 ( lot 79 ) , Commonwealth of Massachusetts Land Court, Essex South Registry of Deeds, Southern District, Salem, Massachusetts, Certificate No. 49670, Registration Book 226 , page 49670 ( lot 88 ) , Commonwealth of Massachusetts , Essex Registry of Deeds , Southern District, Salem, Massachusetts, Book 6671, Page 481 ( lot 89 ) . The Petitioner respectfully requests the variances necessaryin order to sell the property known as 7 Clark P P Y Street, 22 Barnes Circle and 20 Barnes Circle as three single family lots . The present configuration of the property is depicted on the City of Salem Assessor' s Map 3 as lots 79 , 88 and 89 . A copy of said plan is attached hereto as Exhibit "A" . At present the property known as 7 Clark Street which is depicted as lot 79 on Exhibit A has an area of 5,000 square feet and a width of 50 feet . The property known as 22 Barnes Circle which is depicted as lot 88 on Exhibit A has an area of 21, 926 square feet and width of 59 feet . The property known as 20 Barnes Circle which is depicted as lot 89 on Exhibit A has an area of 14 , 669 square feet and width of 66 feet. The proposed reconfiguration of the property is depicted on a plan of land attached hereto as Exhibit `'B" . The reconfiguration increases lot area of 7 Clark Street from 5, 000 square feet to 11,400 square feet decreases the area of 22 Barnes Circle from 21, 926 square feet to 15, 000 square feet and increases the area of 20 Barnes Circle from 14,669 square feet to 15,000 square feet. In order to create the reconfigured lots the petitioner requires the following variances from the requirements of Section VI , Table 1 of the City of Salem Zoning Ordinance as follows : 1 . 7 Clark Street, Salem, MA. (City of Salem Assessor's Map 3 , lot 79 ) Lot area: 11,400 square feet from 15, 000 square feet Lot width: 50 feet from 100 feet 2 . 22 Barnes Circle, Salem, MA. (City of Salem Assessor' s Map 3, lot 88) Lot width: 59 feet from 100 feet 3 . 20 Barnes Circle, Salem, MA. (City of Salem Assessor's Map 3, lot 89 ) Lot width: 66 feet from 100 feet . 2 - Petitioner requests that the variances requested be granted upon a finding by the board that special conditions and circumstances exist which especially effect the parcel of land depicted by the plan of land marked as Exhibit B in that the topography of the land is irregular and such irregularity does not exist generally in this zoning district. Furthermore, that enforcement of the provisions of the ordinance would involve substantial hardship to petitioner because the land will not be developed for a use that is reasonable and consistent with the character of the neighborhood and that the desired variances may be granted without detriment to the public good and without nullifying or derogating from the intent of the zoning-by-law because the proposed use, single family house lots, is consistent with the existing zoning scheme. The neighborhood in which the subject property lies consists mainly of single-family homes , a substantial number of which are on lots significantly smaller in size than those depicted by Exhibit B. The public good will be served by the construction of additional single family homes in this neighborhood as it will make productive use of what is presently vacant land and will serve to further stabilize the character of the area. The present ordinance permits the - 3 - proposed use; granting this petition will neither derogate from the existing ordinance nor be harmful to the public good. Therefore, Petitioner requests that the variances be granted so he may usefully develop this property. Respectfully submitted, Paul Ferragamo, Trustee of the Ferragamo Family Trust, By his Attorney, William H. e n III BBO#: 457060 PEARL, McNIFF, CREAN, COOK & SHEEHAN 30 Main Street Peabody, Massachusetts 01960 Telephone: (508) 531-1710 Fax No: ( 508) 531-4895 Dated: September 29 , 1993 - 4 - /e o- q PIP ?p 6� \ 00 e + optv 6 \ d 4bN eee X02 05�5° bry ery w / /OF / - ? op Ery • °1 s .4e� ` .ppp O,� ery QGV c 0 O 50 q\ .• 9d) P as 4 C& bti 5 / 'yap .mss F bg FF��5° ery e ^ OA- O .� sq of e" O 0P e 6• e - e / 89 /4,669 6• +, ry o 0 p S/ � ?s?6 88 �+ !/ ai h 6,0 2/ 926 '+B a REV. BY �\` V to REV. BY 19 \\ oo >� �28ea 8e ' ��� REV. BY I 1 O �o carr s ` 60 so s fM 9B 6 6: REV. BY CLARK ' 6o 00 0 9 e )''o 6 S000 /38 ) a sgo 83 e� 40 84 e? _ 00 �os so r Sr fT eo A O ., so 9 ,e to ',' -904C so le T % io zz /60000 131 /6/61 122all V — b /0? \p2 „i, _ 132 ' /.05 Ac d 006 AC 1W It d y`p a REV. BY < \\10 q,� y���' REV. BY 6 2q9 Z\oP°o �yc�, j5�6 REV. BY 1 U APPEAL CASE NO. . . . . . . . . .. . . .. .. . . . . . . . i 01Yttl of '�$ttlPm, � tt8 gFiL lISP S n e TO THE BOARD OF APPEALS: The Undersigned represent that he is are the owners of a certain parcel of land located at NO. . .7. .Clark .St...,. .22. & .20. Barnes. .Cirr-le. . . . . . . . . . . . . .Street; 7onina DistrictE.-.1 . . . . . . . . . . . . . . • • • . . . . . . . . . . . . . . . . . : and said parcel is affected by Section(s ) . . . . . . . . . . . . . . . . of the Massachusetts State Building Code. Plans describing the work proposed, have been submitted to the Inspector of Buildings in accordance with Section IX A. 1 of the Zoning Ordinance. n N m n � w EYt n x m a cn w The Application for Permit was denied by the Inspector of Buildings for the following reasons: Direct Appeal The Undersigned hereby petitions the Board of Appeals to vary the terms of the Salem Zoning Ordinance and/or the Building Code and order the Inspector of Buildings to approve the application fee permit to build as filed, as the enforcement of said Zoning By-Laws and Building Code would involve practical difficulty or unnecessary hardship to the Undersigned and relief may be granted without substantially dero- gating from the intent and purpose of the Zoning Ordinance and Building Code for the following reasons: See attached Statement In Support of Petition For Variances C7' Paul Ferragamo, Trustee of UJ w Owner. . . .The, F�rragamo ,Family, T m e9 U' wa Address. . 41.% jjighland, Ave,..,. . U! Telephone. .( QU. 745-0869 _ od , PetitionerPaul. m . . . . . . . . . . . . . . . . . Address. . 419 .145.4land .Aye.. c . Sa1emr MA Date. .SeRtember . 29.,. .1gP3 Telephone. .( 508 ) 745-0869. . . . . . . . . . . . . . . . . By William H. 9ee1h5i'III Att rney for Paul Ferragamo Three copies of the application must be filed with tie Secretary of the Board of Appeals with a check, for advertising in the amount of. . . . . . . . . . . . .. . . . . . . . .. . . . four weeks prior to the meeting of the Board of Appeals. Check payable to The Evening News. 0 � o o z c n y as . C N O c/ W t o Q Qo CD n u m0 Ln ti CCi W O O O O O uj Oma' Li W z s N m m m m m C!) Cn CN Q I C C'J \�y0� m m m m 0o m m m � hQ oo oB W W W w — M b Wcli — 753,500E �C O(1to !G: °, .S' N /, ,.• •° a OM b (b 01 O S c C) 6 O' CO eo N b b pp0 �O 0 �6 s SJR d N 02 B z2 CZ) 13 MJF `90 31 6� V� 91 °r \ Cb mda a v~ f6j 60l N o0 00 Cb o O 0// O °r P b I-o 'FO O s o// w 6O O j 1 �6` udo p 0s 9° V m ° e h$ o a C) O o Q) °r is ° CV 0 ' . ry, cq Y, O 64 h O N CP C V m g�sP (-- � \ryC E�l — O en n CV ci ° N tm °`Fb LOT 74 LOT 90 3, 641 z LOT 75 LOT 89 '2vt A EA - 15 , 0 Oc S . N c) 6, 1 r7b p / M LOT 88 So, AREA = , 15 , 000 S . F .b� ;x LOT 76 (ryr) LOT 87 LOT 79 AREA = 113400 S . F . LOT 77 G G p p LOT 78 LOT 80 s . N 2a OWNER OF RECORD PAUL FERRAGAMO +� ASSESSORS MAP 3 so.00' LOTS 79, 88 AND 89 CLARK STREET ZONING DISTRICT R-1 RESIDENTIAL REQUIRED LOT 79 LOT 88 LOT 89 LOT AREA 15,000 S.F. 11,400 S.r. 15,000 S.F . 15,000 S.F. LOT WIDTH 100 FT. 50 FT. 59 FT. 66 FT. FRONT YARD 15 FT. 15 FT. 15 FT. 15 FT. SIDE YARD 10 FT. 10 FT. 10 FT. 10 FT. REAR YARD 30 FT. 30 FT. 30 FT. 30 FT. ! �4 `� , z �Tf j �Lb 1 •e �a. a PLAN OF LAND IN SALEM , MASSACHUSETTS PREPARED FOR In rVl PAUL FERRAGAMO PREPARED BY ABBA CONSULTING GROUP, INC. - STEPHEN T. LaMONICA PLS 100 CORPORATE PLACE, PEABODY, MA (617) 334-3072 SCALE: 1'' - 40' DATE: JANUARY 22, 1993 IZEVIsE� : >JEc. T, 1993 133 -,69 24394 pp�p C �0 6` e t O / 'y0 •/�/O C� y� sJ V 00 0 bti� 00 IQ 0 O °° / O 1�P \600 soo °" /.yy c/T / Oh b b y1 \ Cp b" O A� ��CP /0 bb ° / 89 \�pp s P 14, 669 S. E.D. 1989 B.O.A. 1988 / 1 ?688 ' N ?9 B.O.A. 1987 J % 4c 2/, 926 ze ,�\\ 9� ^ ill' REV. BY B.O.A. 1986 °Om REV. BY B.O.A. 1985 \ \ 87 a ��� � '— v Soo /2983 e ° REV. BY B.O.A. 1984 pr of es r �` REV. BY S.E.D. 1982 � � 0 P 9169 ��; _ es so / ! 79 34tEm Jc CLARK a So soo 80 8g n ° 60 o soo 138 10,900 0 6 so 55p0 /381 83 b" 5 e °O Soo 84 b \ 0 6 °o \/ 5p ,E s r��E r SO \a4 q 5p �9 'a 33 2a `yE 12j / 5° 6 EI /,yO4 a„�69 . . 123 a 0 50 .e 130 106 100 PO zz /6000 IM45 _ 131 �0 16/63 122 /2733 0 �, IL \\\^\\J $ so 51 101121 1 12d4p J /9,000 9lIf- ?� ;oAZ332 — 1,03 ac S.E.D. 1981 a \\006 II,,, _ S.E.D. 1980 1.13 A s — iW. AVI S 1979 0 0 AVIS 1978 0 — �� �g2 REV. BY AVIS 1971; 15pi REV. BY /// /974 'u� \\'l 00 �ZG� 1�p56 REV, BY AVIS /973 Z00 y 1L� AUZ, V 0 0 3565 480 0 ._ 544,500 N LAST NQ USEC139 .o LOTS 126,136 `CT U1EC 4 8 3 7 � � 11 N LOT 74 / LOT 90 \ 706 � z LOT 75 LOT 89 FT� AREA = un 15 , 000 S . F . E LOT 88 AREA = 15 , 000 S . F . LOT 76 LOT 87 LOT 79 AREA = 117400 S . F . 5 .00, LOT 77 b r� v o LOT 78 LOT 80 OWNER OF RECORD: PAUL FERRAGAMO ASSESSORS MAP 3 n 0o LOTS 79, 88 AND 89 CLARK STREET ZONING DISTRICT R-1 RESIDENTIAL REQUIRED LOT 79 LOT 88 LOT 89 LOT AREA 15,000 S.F. 11,400 S.F. 15,000 S.F. 15,000 S.F. LOT WIDTH 100 FT. 50 FT, 59 FT. 66 FT. FRONT YARD 15 FT. 15 FT. 15 FT. 15 FT. SIDE YARD 10 FT. 10 FT. 10 FT. 10 FT. REAR YARD 30 FT. 30 FT. 30 FT. 30 FT. �tit OF��, STEPHEN V PLAN OF LAND IN Na32� a SALEM , MASSACHUSETTS PREPARED FOR PAUL FERRAGAMO PREPARED BY ABBA CONSULTING GROUP, INC. - STEPHEN T. LaMONICA PLS ZZ-93 100 CORPORATE PLACE, PEABODY, MA (617) 334-3072 SCALE: V = 40' DATE: JANUARY 22, 1993 ilIil!� If1 I' N LOT 74 / LOT 90 E4 z LOT 75 LOT 89 r Fl� AREA - 0 - 15 , 000 S . F . LOT 88 AREA = 15 , 000 S . F . LOT 76 LOT 87 LOT 79 AREA = 11 , 400 S . F . LOT 77 O ('j O O LOT 78o g LOT 80 OWNER OF RECORD: PAUL FERRAGAMO ASSESSORS MAP 3 sn.no LOTS 79, 88 AND 89 CLARK STREET ZONING DISTRICT R-1 RESIDENTIAL REQUIRED LOT 79 LOT 88 LOT 89 LOT AREA 15,000 S.F. 11,400 S.F. 15,000 S.F. 15,000 S.F. LOT WIDTH 100 FT. 50 FT. 59 FT. 66 FT. FRONT YARD 15 FT. 15 FT. 15 FT. 15 FT. SIDE YARD 10 FT. 10 FT. 10 FT, 10 FT, REAR YARD 30 FT. 30 FT, 30 FT. 30 FT. OF T PLAN OF LAND IN NICA No. SALEM , MASSACHUSETTS PREPARED FOR PAUL FERRAGAMO PREPARED BY ABBA CONSULTING GROUP, INC. - STEPHEN T. LaMONICA PLS zz-93 100 CORPORATE PLACE, PEABODY, MA (617) 334-3072 SCALE: 1" = 40' DATE: JANUARY 22, 1993 133 / /„ � � 69 9) �� .. 0 6 P� �/ 0 6• e s / X0000 �tij bry G b° tee' eb 0��00 0 a h1 P OP S �O bry 5 b �h Rro�i3 / e 6 Ip ° o / 89 i 14, 669 a S.E.D. 1989 a a s� o6y 6 B.O.A. 1988 % / 1 '6 88 - N z, B.O.A. 1987 J Ob <76 21, 926 '4C ee ,\\\ REV. BY B.O.A. 1986 1 — °O m REV. BY B.O.A. 1985 \\\ 87 Jo /298 @2 REV. BY B.O.A. 1984 ? 500 0 8g C0 °� e6 REV. BY S.E.D. 1982 O P i26 S.4CEM cLqR 'so 50 -,%000 9 80 / 8S n K 6° Soo0 5138 °9p0 3 ° 6 3pp /S0 °8� 83 ea Ti a 400 84 e rQ 0 4 8, /9 I tioe i 00, 6p0 ry ST� 60 \dd V q 50 EET9 rp JJ ,fid `fie O 50 OAC 6 2r /9 4C 5p re O 130 106 23 a loo 2'� 16000 15145 131 16/65 122 12753 O 4 — 1o? — 1llL 640 16,2000 9�f '�, \\A23 \/ — All, — _ 132 S.E.D. 19fJ1 o � ,0 _— 1,05 AC \\N06 II _ S.E.D. 1980 IZ�AC P g0 — AVIS 1979 o _ li AVIS 1978 �ls DC) REV. BY AVIS 1916 REV. BY 1111974 AtucA — \2 960 \\,� QO FyG� ;5p56 REV. BY AVIS 1973 — Zoo OLA -LLLL, m � W ul \ 0 ° 35T 2 1a60 m 544,500 N LAST NQ USEC132 • so LOTS 126, 156 ICT U'kL' 4 8 1 3 7 ( 1 ^ 11