Untitled (002) I
John H. Carr, Jr., Esq.
9 North Street
Salem, MA 01970
Phone: 978-807-3264
Fax: 978-825-0068
Email: johnhenrycarr@gmail.com
October 17, 2018
By Hand& By Email: tstpierre@salem.com
Salem Building Inspector and Zoning Enforcement Officer
Salem Building Department
98 Washington Street, 2nd floor
Salem, MA 01970
Re: Former Alpha Used Car Lot, 311 Bridge Street, Salem, MA 01970
Dear Mr. St. Pierre:
I am formally writing you in your capacity as Salem's Zoning Enforcement Officer.
As you are well aware, I represent approximately 130 plaintiffs in three separate lawsuits filed in
the Essex Superior Court involving the rezoning of the present F. W. Webb parcel at 295-297
Bridge Street and the rezoning of the adjacent so-called Universal lot owned by the City (Civil
Action No. 16V-1792-D), and in appealing separate ZBA and Planning Board Decisions granting
F. W. Webb or its subsidiaries (hereinafter collectively referred to as "Webb") various zoning
relief(Civil Action No. 17-889-B and 17-1191-A).
As you are also aware, Webb also owns the former Alpha Used Car Lot now renumbered as 311
Bridge Street in Salem(hereinafter"Alpha lot"), which is zoned two-family residential.
I would be happy to prove to you why the Alpha lot has as a matter of law lost its former
arandfathered status even before NVebb acquired title on Tune 22, 2015, but it reed not come to
that.
The escalating, unsightly, and illegal conditions that Webb has caused at that location since it
acquired title, including storage of a large yacht, two long tractor trailer truck bodies, two large
dump trucks, one or more box trucks, large metal shipment or storage containers, snow plow
blades, and a motor boat and trailer,was never part of the former grandfathered use of the lot,
even assuming that the grandfathered status had not been lost. I have written to Counsel for Webb
requesting that his client clean up the lit, but to no avail.
Given the high visibility of these conditions on a major entrance corridor into the City, we would
have thought that you or your subordinates would have taken the initiative long before now without
our having to complain and seek redress. but you haven't.
E
Accordingly, I am herewith formally requesting in behalf of my clients that you immediately
contact Webb and order it to remove the above conditions, clean up the property, and bring it into
compliance with the zoning, all effective forthwith.
I am also requesting that you(as well as other relevant City authorities)examine the former Alpha
sales office structure to determine if it is unsafe and/or represents a fire, structural or other safety
threat to the neighborhood,in which event we further request that you order Webb to demolish
it forthwith.
Until recently, when one or more of my clients complained to your office, Webb had permitted its
adjacent Pegasus grandfathered, auto repair tenant to install an interior lift without a building
permit in the former Alpha sales office structure and illegally use it as an interior auto repair bay.
If you have any questions, please do not hesitate to contact me.
Thank you in advance for your hoped for and anticipated prompt enforcement of this matter.
V tr yo s,
John . Carr,
Cc Salem City Solicitor Elizabeth Rennard—By Email
Salem Mayor Kimberley Driscoll — mail
Salem City Councilors—By Email
James E. Gallagher, Esq. —By Email
Plaintiffs—By Email