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Town of Winthrop · from StateReference · 2 pages · 21 KB
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COMMONWEALTH OF MASSACHUSETTS

DEPARTMENT OF LABOR RELATIONS

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Case Number: MUP-14-4210 and MUP-15-4652
FERRUCCIO ROMEO

Vv.

TOWN OF WINTHROP

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ANSWER

COUNT ONE
1. The Town admits Paragraphs 1, 2, 3, 4, 5 of the Complaint.
2. The Town denies Paragraph 6 of the Complaint.
3. The Town admits Paragraphs 7 and 8 of the Compiaint.
4, The Town denies Paragraph 9, 10, 11, 12 and 13 of the Complaint.
FIRST AFFIRMATIVE DEFENSE
The charging party’s claims are barred to the extent that they fail to establish a violation

of Chapter 150E.

SECOND AFFIRMATIVE DEFENSE

The charge is untimely and barred by the applicable statute of limitations.

THIRD AFFIRMATIVE DEFENSE

The Complaint fails to state a claim upon relief may be granted.

FOURTH AFFIRMATIVE DEFENSE

The Respondent has complied with all laws and regulations and otherwise satisfied its

statutory obligations under G.L. Chapter 150E.

Dated:

4-S-20a0

Respectfully submitte
The Town of Winthfo
by its counsel,

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Howard'L. Cccenspan
roadway, Suite 304

Lynnfield, MA 01940
(718) 598-4545
Hgreenspan@greenspanlawyers.com