Pothier Law Offices 86 Summer Street Haverhill, MA 01830 Respondents Representatives: Marianne Dill Department of Public Health 365 East Street Tewksbury, MA 01876 Kerry Bonner, Esq. Human Resources Division One Ashburton Place Boston, MA 02108 Commissioner: John J. Guerin, Jr.

Napoli received, via first class mail, a written notice informing him of the date, time and location for him to appear to take the examination (April 24, 2008 in Haverhill MA). He received the notice and took the examination as scheduled. (HRD Motion, Exhibit C; Appellants Response; Undisputed Representation of Counsel) 7. On June 18, 2008, HRD e-mailed a notice to Mr.

Chief of Police Haverhill Police Department 40 Bailey Boulevard Haverhill, MA 01830 Dear Chief Pistone: I have received the petition of Jeff Raymond, of the Bramanville Tribune, appealing the response of the Haverhill Police Department (Department) to his request for public records. See G. L. c. 66, 10A; see also 950 C.M.R. 32.08(1). On May 22, 2023, Mr. Raymond requested the following records: [1.]

DLR FORM-005 (page 2) Revised 11/07 UNFAIR LABOR PRACTICE Request for Legal Services Date: _October 15, 2012 LOCAL: LOCAL PRESIDENT: Joe LeBlanc MCCC Email: Mailing Address: president@mccc-union.org Telephone (978)241-9373 Cell Phone: (978) 376-6741 18 Hawthorne St Haverhill, MA 01835 COLLEGE PRES./SUPERINTENDENT Department of Higher Ed/STCC Phone:_(617)994-6950 ATTY REPRESENTING COMMITTEE/BOARD: Jim Brown, Esq.

Haverhill, MA 01830 . 978-556-3742 From: Corbett, Thomasine Sent: Thursday, March 24, 2016 11:05 AM To: Brody, Joyce ; Fabbrucci, Stephen Ce: Rivera, Ricardo ; Kevin Hanley ; Byrnes, Diane Subject: RE: Your Request to Take Tomorrow Off importance: High Just tried to call Steve and no answer on his cell phone. lam sitting on an Arbitration

Civil Service Commission & City of Haverhill, 72 Mass. App. Ct. 535, 538 (2008). This is one of five appeals filed with the Commission in calendar year 2010 in which an individual claims that HRD has misinterpreted Section 59 and the Weinburgh decision and erroneously denied them the opportunity to sit for a public safety promotional examination or, in the alternative, allowed them to sit for the examination, but refused to score it.

City of Boston, 26 MLC 177, 181 (2000); Town of Andover, 1 MLC 1103, 1106 (1974); City of Haverhill, 16 MLC 1077, 1079 (1989). 1. This Charge Should Be Dismissed Because It Is Untimely.

City of Boston, 26 MLC 177, 181 (2000); Town of Andover, (1974); City of Haverhill, 16 MLC 1077, 1079 (1989). 1 MLC 1103, 1106 For the reasons set forth below, the charges should be dismissed. 1. There Was No Duty to Bargain the decision to Close the Northgate Program as It is Not a Mandatory Subject of Bargaining.

City of Haverhill, 42 MLC 273, 275 (2016) (citing Swansea Water District, 28 MLC 244, 245 (2002)). Even if a single event could 12 create a past practice, the CERBs clear pronouncements on this point should prevent the Employers defense from precluding probable cause that a change occurred. Given the Employers heavy burden of proof, the CERB can and should direct a complaint based on this fact alone.

Gleason Law Offices, P.C. 163 Merrimack Street Haverhill, MA 01830 Appearance for Respondent: Caroline Thibeault, Esq. 100 Westminster St., Suite 710 Providence, RI 02903 Nicholas Dominello, Esq. Valerio, Dominello and Hillman One University Ave., Suite 300B Westwood, MA 020901 Commissioner: Cynthia Ittleman, Esq.