City of New Bedford, 471 Mass. 446 (2015). In DaRosa, the SJC concluded that opinion work product that was prepared in anticipation of litigation or for trial by or for a party or its representative falls within the scope of Exemption (d). Id. at 448. It also concluded that fact work product under Mass. R. Civ.

City of New Bedford, 471 Mass. 446, 458 (2015). You were previously provided under the Public Record Law the final and completed transcripts of the statement delivered by the District Attorney on August 25, 2023. Disclosure of the requested drafts of that statement could reveal the thought processes and deliberations employed by the District Attorney.

Telephone Number William Straus, Esq. 508-992-1260 Address (street and No., city/town, state, and ZIP code) 15 Hamilton Street, New Bedford, MA 22. 18. Representative to contact 21.

Fax Number 115 Orchard Street, New Bedford, MA 02740 23, The Charging Party is an; 508-993-3696 [vy . Individual C} Employee Organization [| Employer DECLARATION | have read the above charge of prohibited practice and swear under the pains and penalties of perjury that the information contained In itis true and complete to the bast of my knowledge and belief. Name (prin Signature Nancy Ghossein , h Unpyruce 4 Title (any) I .

City of Somerville, 23 MLC at 259; City of New Bedford, 15 MLC 1732, 1737 (1989); City of Boston, 6 MLC 1117, 1126 (1979).

Commonwealth of Massachusetts, 27 MLC 52, 56, SUP- 4091 (November 21, 2000); City of New Bedford, 15 MLC 1732, 1737, MUP-6488 (May 31, 1989). Upon review, the record reveals that the radio dispatchers performed the majority of the lighting truck duties prior to July 2012. However, after the City assigned those in September 2012, the any of the lighting truck duties.

Commonwealth of Massachusetts, 27 MLC 52, 56, SUP- 4091 (November 21, 2000); City of New Bedford, 15 MLC 1732, 1737, MUP-6488 (May 31, 1989). Upon review, the record reveals that the radio dispatchers performed the majority of the lighting truck duties prior to July 2012. However, after the City assigned those in September 2012, the any of the lighting truck duties.

Respondent, By its attorney, /s/ Jane Medeiros Friedman Jane Medeiros Friedman Mead, Talerman & Costa, LLC Attorneys at Law 227 Union Street, Suite 606 New Bedford, MA 02740 Office: (774) 202-6812 Cell: (508) 717-5964 Jane@mtclawyers.com CERTIFICATE OF SERVICE I certify that the foregoing ANSWER TO COMPLAINT OF PROHIBITED PRACTICE AND PARTIAL DISMISSAL was sent to the following persons, in the manner specified, on the date below: Via email: Via email

Respondent, By its attorney, /s/ Jane Medeiros Friedman Jane Medeiros Friedman Mead, Talerman & Costa, LLC Attorneys at Law 227 Union Street, Suite 606 New Bedford, MA 02740 Office: (774) 202-6812 Cell: (508) 717-5964 Jane@mtclawyers.com CERTIFICATE OF SERVICE I certify that the foregoing ANSWER TO COMPLAINT OF PROHIBITED PRACTICE AND PARTIAL DISMISSAL was sent to the following persons, in the manner specified, on the date below: Via email: Via email

Address (street and No., city/town, state, and ZIP code) 227 Union Street New Bedford MA 02740 14. FAX Number 15. E-mail address jane@mtclawyers.com 16. Firm/Organization Name Mead, Talerman & Costa, LLC EMPLOYEE ORGANIZATION (if any) 17. Name Marblehead Municipal Employees' Union, Local 81776, IUE-CWA 1 18. Telephone Number 781-771-3327 19,20,21,22. Address (street and No., city/town, state, and ZIP code) PO Box 1289 Marblehead MA 01945 23.

City of New Bedford, 471 Mass 446, (2015), the Massachusetts Supreme Judicial Court was explicit that the deliberative process exemption applies to consultants working with the government exactly as CTD is working with the Department.

City of New Bedford, 471 Mass. 446 (2015). In DaRosa, the SJC concluded that opinion work product that was prepared in anticipation of litigation or for trial by or for a party or its representative falls within the scope of Exemption (d). Id. at 448. It also concluded that fact work product under Mass. R. Civ.

City of New Bedford, 471 Mass. 446, 458, 30 N.E.3d 790, 801 (2015) (discussing the federal deliberative process exemption). See also Sears, Roebuck & Co., 421 U.S. at 150, (federal Exemption 5 covers documents reflecting advisory opinions, recommendations, and deliberations comprising part of a process by which governmental decisions at1d policies are formulated)."

City of New Bedford, 471 Mass. 446 (2015) (attorney work product falls within the scope of exemption (d)). Segregation and redaction are essential to ensure compliance with legal and ethical obligations. Exemption (f) - Investigatory Materials. Many emails will likely include correspondence between prosecutors and police investigators regarding active and ongoing investigations.