City/town, State, ZIP Code New Bedford MA 02740 16. FAX Number 508-991-4266 15. E-mail Address staveira@afscme93.org 16. Firm/Organization Name Afscme Council 93 1 EMPLOYER 18. Name North Attleboro Public Schools 19. Telephone Number 508-643-2100 20. Address 6 Morse St. 24. FAX Number 508-643-2110 21,22,23. City/town, State, ZIP Code North Attleboro MA 02760 LABOR RELATIONS REPRESENTATIVE 25. Name Daniel C. Brown, Esquire 26.

City/town, State, ZIP Code New Bedford MA 02740 LABOR RELATIONS REPRESENTATIVE 8. Name Brian Senior 9. Title Attorney 10. Address 177 Milk Street 14. Telephone Number 617-338-1976 11,12,13. City/town, State, ZIP Code Boston MA 02109 16. FAX Number 617-338-7070 15. E-mail Address bps@fdb-law.com 16. Firm/Organization Name Feinberg, Dumont & Brennan 1 EMPLOYER 18. Name Town of Fairhaven - Sewer Department 19. Telephone Number 508-979-4030 20.

City of New Bedford, 471 Mass. 446 (2015), the Office states that [t]he work product doctrine protects from public disclosure all materials and mental impressions prepared by an attorney, or another representative of a client retained or consulted at the direction of counsel, in anticipation of actual or reasonably foreseeable litigation.

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, 448 (2015). Reasonable description of records Items (h) (j) Regarding the above Items, the Office stated that [i]t is unclear from your request what is meant by departmental records. To the extent that this request seeks investigatory records retained by a department(s) of this Office, we understand this to be duplicative of your broader request for all files related to the investigation.

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, 23 MCSR 134 (2010). See also ONeill v. City of Lowell, 21 MCSR 683 (2008), affd sub nom ONeill v. Civil Service Commn, MICV2009-00391 (Sup.Ct. 2009) (Chernoff, J.) (The statute gives the Commission the power to initiate an investigation upon request . . . but does not require it to do so.) affd, 78 Mass.App.Ct. 1127 (2011); Memorandum and Decision in Boston Patrolmens Association v.

Lizotte v City of New Bedford Police Department 12 MCSR 40 (1999). An Appellant's "expectation of selection based on his position on a civil service list does not rise to the level of a property list entitled to constitutional protection." Stuart v. Roache, 951 IF. 2d 446 (1st Cir. 1991). It is a limited preference to be considered for appointment rather than a right to be hired.

November 21, 2000; City of New Bedford, 15 MLC 1732, 1737, MUP-6488, May 31, 1989. The Commonwealth Employment Relations Board (CERB) analysis focuses on the pre-existing pattern of shared work and the impact that any change in that pattern may have on the allegedly aggrieved party. See City of Boston, 26 MLC 144, 147, MUP-1085, March 10, 2000; Town of Natick, 11 MLC 1434, 1438, MUP-5319, February 19, 1985.

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.