Superior Court Motion to Dismiss Fair Test Appeal from Civil Service and Town of Winthrop.pdf

Town of Winthrop · from the Town's request portal · released Dec 13, 2023 · 5 pages · 605 KB
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He HOWARD L. GREENSPAN
{ ATTORNEY AT LAW
January 22, 2020

Feruccio Romeo
9 Hitching Hill Road
Saugus, MA 01906

Re: Ferruccio Romeo v. Civil Service Commission and Town of Winthrop
Superior Court No.: 1984CV01806
Dear Attorney Romeo:

In accordance with Rule 9A of the Superior Court please find:

1. Defendant’s Joint Motion To Dismiss; and
2. Defendant’s Request For Hearing.

Sincerely,

cc: Robert L. Quinan, Jr., Assistant Attorney General
Austin Faison, Town Manager
Chief Terence Delehanty

200 Broadway, Suite 304 © Lynnfield, Massachusetts 01940
TeL: (781) 598-4545 © Fax: (781) 598-4579
HGreenspan@GreenspanLawyers.com

CIVIL SERVICE COMMISSION:
arid: TOWN OF WINTHR¢

Now cone the Deferidants; Town 6

the above entitled action and move

I4.and Superior Court Standing Order:

96 i> dismiss the Complaint of te Plaintifé.
Ferruccio: Romeo, forsfailureito: prosecute the appeal of the decision of the Civil Service

Lat

Commissiow-under-the statute.

As pounds for this motion the Defendant states:

arid the Defendant, Ci

Complaint on August21,2

setved its bn Septem

2019.

3. Pursuant to Mass. Super Ct. Standing: Order 1-96, whieh governsthe judieial

review 6
esolved through a neon th placings &

accordance with Superior Court Rule 9A. . ..{and the] platitiff's Rule 12(¢) motionand

supporting memorandum shall.be served within dhirty

vrecotd......*Asisuch, the Plaintiff's Motion for Judgment on'the Pleadings wasto:be:

‘greenspan@greenspanlawyersicom,

COMMONWEALTH OF MASACHUSETTS

DEPARTMENT OF LABOR RELATIONS

SUFFOLK, SS

FERRUCCIO ROMEO
Plaintiff
Vv.

CIVIL SERVICE COMMISSION
and TOWN OF WINTHROP

SUPERIOR COURT

NO. 1984CV01806

PLAINTIFF’S REQUEST FOR HEARING

Now, comes the Defendant and moves this Honorable Court for a Motion To Dismiss.

The Motion is filed pursuant to Rule 9A of the Superior Court Rules and Procedure.

Dated: yj i/o

Respectfully submitted,
The Town of Winthrop
by its counse},

Howard L. Greenspan

200 Broadway, Suite 304

Lynnfield, MA 01940

(718) 598-4545
Hgreenspan@greenspanlawyers.com

CERTIFICATE OF SERVICE

A copy of the foregoing Defendant’s Joint Motion To Dismiss and Defendant’s Request
For Hearing has been sent via First Class Mail this gon day of January, 2020 to Ferruccio
Romeo, 9 Hitching Hill Road, Saugus, MA 01906.

oward L. Greenspan