2 PLANTERS STREET - BUILDING INSPECTION 2 PLANTERS STREET
" Commonwealth of Massachusetts
MIDDLESEX, as. Superior Court
C.A. No.: ESCV2000-018248
JOAO A.SALOMAO and MARGARET
C.HALLETT-SALOMAO,
Plaintiffs
V.
THOMAS A.BUBIER and ANDREW
B.PERKINS,in their individual _
capacities and as trustees of the Subpoena Pursuant to
PHOENIX REAL ESTATE TRUST,KILBORN M.R.C.P. Rule 30Ia1
PROPERTY CONSULTANTS,INC.and & Rule 45
HUNNEMAN-COLDWELL BANKER,
Defendants
To: Keeper of Records,City of Salem
Attn:Debra Burkinshaw,City Clerk of Salem
93 Washington Street
Salem,MA 01970
Greetings:
YOU ARE HEREBY COMMANDED in the name of the CommonweAlth of Massachusetts in accordance
with the provisions of Rule 45 of the Massachusetts Rules of Civil Procedure to appear and testify on behalf of
plaintiffs, Joao A. Salomao and Margaret C. Hallett-Salomao before a Notary Public of the Commonwealth, at
the office of Lawson & Weitzen, LLP, Robert J. Roughsedge, 88 Black Falcon Avenue, in the City of Boston,
Massachusetts on the 25th day of July, 2002 at 10:00 a.m., and to testify as to your knowledge, at the
taking of the deposition in the above-entitled action.
" And you are further required to bring with you all documents listed in the attached Schedule A:
Please note that you are invited to produce the documents in lieu of testimony
Hereof fail not as you will answer your default under the pains and penalties in the law in that behalf made and
provided.
Robert J. Roughsedge Dated: June 24, 2002
Lawson & Weitzen, LLP AUDREY L ANDREWS
Attorney/a Joao A. Salomao and Margaret C. Hallett-Salomao A NOTARY PUBLIC OF BOSTON
MY COMMISSION EXPIRES MARCH 20,2009
88 Black Falcon Avenue v
AOd Notary Public
Boston, Massachusetts 02210 My Commission expires: Q. 'I' 20 0
City a Town 7
16171 439-4990
TeMpb a Number
Any questions, please call Robert J. Roughsedge at 617-439-4990 U AT EST COPY
1.
DEPUTY SHERIFF
Schedule A
1. Any documents, including, but not limited to: complaints, building permits, inspections,
lawsuits, notices, or other documents, concerning any of the following individuals and%or entities
and the properties they owned or were involved with:
a. Andrew Perkins
b. Thomas Bubier
c. Phoenix Real Estate Trust
d. Andrew B. Perkins Trust
e. T&A Realty Trust
f. Franklin Street Realty Trust
g. A& B Realty Trust
2. Any documents referencing any complaints about Rebecca Kilbom or Kilbom Property
Consultants, Inc. or properties in which either were involved.
3. Documents concerning any of the individuals and/or entities listed in paragraph one and
any of the following properties:
a. 58 Derby Street, Salem, MA.
b. 25 North Street, Salem, MA.
c. 16 Churchill Street, Salem, MA.
d. 3 Watson Street, Salem, MA.
e. 2 Planters Street, Salem, MA.
Titg of #a1Em, massac4usetts
tie Public Prnpertq Bepnrtment
� Nuilbing ]Department
(One dalem (green
500-745-9595 Ext. 300
Leo E. Tremblay
Director of Public Property
Inspector of Building
Zoning Enforcement Officer
December 11 , 1996
Mary Griffin
2 Planters Street
Salem, Mass . 01970
RE : 2 Planters Street
Dear Mrs. Griffin:
This department conducted an inspection at the above
mentioned location and the siding on the structure was
loose and blowing in the breeze making an unsafe condition
for pedestrians and street traffic.
Please see that this situation is repaired
immediately. Upon doing so contact my department to
inform us that it has been taken care of. Failure to do
so within five (5 ) days will result in legal action being
taken against you.
Thank you in advance for your anticipated cooperation
in this matter.
Sincerely,
Leo E . Tremblay
Inspector of Builings
LET: scm
cc: Councillor Flynn, Ward 2
CITY OF SALEM
BUILDING DEPARTMENT
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ONE SALEM GREEN °NoSuchtl ° A°'"a I ;
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SALEM, MASSACHUSETTS 01970 ' °o oe"Q06ed Address UNITEOSTdTES l
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Mary Griffin
2 Planters Street
Salem, Mass. 01970
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3� �Q Tito of 19ttlem, mastiac4usetts
tlublic Propertg Department
Nuilbing Department
(Ne t3ntem (6rern
508-735-9595 Ext. 300 -
Leo E. Tremblay
Director of Public Property
Inspector of Building
Zoning Enforcement Officer
December 11 , 1996
Mary Griffin
2 Planters Street
Salem, Mass . 01970
RE : 2 Planters Street
Dear Mrs . Griffin:
This department conducted an inspection at the above
mentioned location and the siding on the structure was
loose and blowing in the breeze making an unsafe condition
for pedestrians and street traffic .
Please see that this situation is repaired
immediately. Upon doing so contact my department to
inform us that it has been taken care of. Failure to do
so within five ( 5 ) days will result in legal action being
taken against you .
Thank you in advance for your anticipated cooperation
in this matter.
Sincerely,
Leo E . Tremblay
Inspector of Buil ings
LET: scm
cc : Councillor Flynn, Ward 2