23A-079 (27) December 7, 1979
Rogers, Alden, & Pacella, P.A.
Attorneys at Law
73 State Street
Springfield, Massachusetts 01103
Re: 41 Main Street, Florence, Massachusetts
Dear Mr. Pacella:
In reference to your letter of November 16, 1979, please be
advised of the following:
I have been expecting your call, requesting an appointment to
come to this office to view our plans on the above.
We do not have the facilities necessary to reproduce copies of
plans, as in most instances the original mylars are needed for
a clear print.
However, our files are open for public viewing with the proper
notification. Please call this office at 586-6950, Ext. 240
to make an appointment, and we will be pleased to assist you in
any manner we can.
Sincerely,
Cecil I. Clark
INSPECTOR OF BUILDINGS
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ROGERS, ALDEN & PACELLA, P.A.
Attorney. at Law
Arthur M. Rogers 73 State Street
Doris F. Alden Springfield, Masaaehu.ette 01103
Jo.ePh A. Patella (413) 781-2470
David H. Rome November 16, 1979
Mayor Harry S. Chapman IV_.
City of Northampton
City Hall 1 7
Northampton, Massachusetts 01060 DEPT.OF BUILDING INSPECTIONS
NORTHAMPTON, MA.01060
Dear Mayor Chapman:
This office represents two residents of the City of Northampton,
Mr. and Mrs. Erwin L. Brady of 12 Wilder Place. Our representa-
tion concerns the building (prior to your administration) of a
professional medical dental building at 41 Main Street , Florence,
Massachusetts. It is our clients contention that this building
was allowed to be built by the Building Inspector of Northamtpon,
Mr. Cecil Clark, although it did not conform to several regula-
tions of the Northampton Zoning By-laws in effect at that time.
In furtherance of our representation of our cliextts, we made a
demand on the Building Inspector of the City of Northampton to
enforce the Zoning By-laws as they pertained to the subject prop-
erty. Our demand was refused, and we took an appeal to the North-
ampton Board of Appeals, which is now pending. In conjunction
with that appeal Attorney Eric Gervais of the Board of Appeals
requested that our office furnish eight (8) copies of a sketch
plan of the subject property to the board to help them in their
determination of our appeal . Although both Attorney Gervais and
I agreed that this was not a requirement for my clients, nor
should they be forced to incur additional expense in this regard,
I did offer to obtain copies of any plans on record in the Build-
ing Inspector ' s office, and at our expense duplicate them and fur-
nish them to the Board of Appeals.
On Thursday November 15th, 1979, I made a special trip to North-
ampton to visit the Building Inspector ' s office and view the pub-
lic documents on record with him with regard to this property.
Thereafter if a plan was on record, we would have requested that
the Building Inspector supply us with a copy. When my associate
and I arrived at the Building Inspector ' s office, we were told by
Ms . Linda Patryn that Mr. Clark was in court, and that his assist-
ant Mr. Tewhill was out on several inspections, but would be re-
turning shortly. We then asked her to please view the records
concerning 41 Main Street, so that we could determine whether or
r eE MC
NOV 9 1979
NW ACPImniuc iuurerin,
Mayor Harry S. Chapman -2- November 16, 1979
not an adequate plan had been filed.
At that point Ms . Patryn asked my name, and when she heard that
I was the attorney in regards to the appeal, she stated that she
would not be able to show us anything without her boss ' s permis-
sion. She stated that these were his orders, and despite the
fact that I appraised her that these records were public, and
that she was violating the law (M.G.L. C. 66 $10) , she refused
to furnish the records to us.
We then asked her if she could at least tell us whether or not
a plan was on record in regards to 41 Main Street, and she even
refused to furnish this information. I then came up to your of-
fice at which time you were engaged in a meeting with Mayor-elect
Musante, and your secretary who I might indicate was most helpful
called Attorney Gervais to verify our purpose in being there. It
is my understanding that your secretary was assured by Attorney
Gervais that there was no harm in furnishing the plan allowing us
to view the plan by the Building Department, since it was at his
request that we were there. At that time your secretary called
Ms. Patryn and advised her of this fact, and she was told that
Ms. Patryn still refused to allow us to examine the public records.
While I can appreciate that you are not responsible for the ig-
norance of an employee, I certainly think the type of insubordin-
ation shown by Ms. Patryn should be dealt with severely. Although
I am aware, that her actions, could be reported to the District
Attorney, or the Attorney General for Massachusetts for prosecution,
I am not interested in doing so over such a small matter, however
I am concerned that a city employee, on the city payroll, being
paid by my clients taxes, and the taxes of several other clients
and friends that I have in Northampton would refuse to allow a
public record to be examined, and would do so in complete viola-
tion of law, and as a complete act of insubordination to the
Mayor ' s office that had assured her that this was alright .
It is also especially upsetting, that she indicated that sha was
doing this at her "boss ' s instruction" . This amounts to what ap-
pears to me conspiracy not only to violate Massachusetts laws, but
to violate several Federal Statutes including the Civil Rights Act
and the Freedom of Information Act . It is especially amusing, when
I have documented proof that this policy has never been carried
out previously with regards to any other public citizen, but only
came about when we requested to view documents in regards to this
appeal of the Building Inspectors decision.
Mayor Harry S. Chapman -3- November 16, 1979
I would expect that: your office would now undertake to repri-
mand this employee for her ignorance and violation of law, and
would see to it that either her or her superiors forward to our
office a written apology for the inconvenience that they caused
us. Upon receipt of the apology, we will consider the matter
closed.
It might also be noted, that we have this day forwarded a writ-
ten request to Mr. Clark for the documents that we wanted to
look at yesterday, and I would expect that he would be expedi-
tious in his handling of our request based on yesterdays occur-
rences.
Thank you for your courtesy and cooperation in this matter.
Yours very truly,
ep A. Pacella
JAP/mec
cc: Cecil Clark, Building Inspector ✓
David Musante, Mayor-elect
f-
ROGERS, ALDEN& PACELLA, P.A.
Attorneys at Law
Arthur M. Rogers 73 State Street
Doris F. Alden Springfield, Massachusetts 01103
Joseph A. Pacella (413) 781-2470
David H. Rome
November 16, 1979
Mr. Cecil Clark, Building Inspector
Building Department, City Hall
Northampton, Massachusetts 01060
Re: 41 Main Street, Florence, Massachusetts
Dear Mr. Clark:
Please be advised that you are hereby requested to furnish this
office with one (1) copy of any plans, plot plans, site plans,
or sketch plans, contained in your records in regards to the
aforementioned property. These plans should have been submitted
to you at the time that you approved both the original building
permit, and the second building permit whereby mixed residen-
tial business use was authorized.
Please furnish these to us at your earliest convenience, as
these are needed by the Board of Appeals in order to reach their
decision, and I have been requested to obtain them by Attorney
Eric Gervais. Any charges incurred for copies of these plans,
should be billed to this office and they will be promptly re-
mitted. If you have any questions, or if there is any problem
in your office furnishing us with these documents, please advise
us immediately.
Yours very truly,
6
Jo` e h A. Pacella
JAP/mec
LULDIEV r 79
NOV 191979 613/al
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DEFT.OF BUILDING INSPECTIONS Piirj
NORTHAMPTON, MA.01060 I ���
ROGERS, AEDEN, & PACEL LA, P.A. ,�F 4 I
P N FILL? GOODW D►Attorheys at LW (r OLIVEReu 73 State Street 01 « NOV q I HELP THE 1`r o
Sprunngricid, Massachusetts 01103 Wm.
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Mr . Cecil Clark, Building Inspector
I Building Department, City Hall
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