23D-107 COMPLAINT (2) Law Offices of
JAMES E. BARNETT, JR. SEAN E. O'LEARY
Attorneys at Law
184 Northampton Street
Easthampton, MA 01027 April 25 , 1985
(413) 527-5710 R,g ZO VE
Mr. Edward Tewhill1111
APR 2 9
Building Inspector1985
City of Northampton 6. 1
City Hall OWT IN�
Northampton, MA 01060
RE: Pioneer Valley Nursing Home
Dear Mr. Tewhill
On behalf of Frederick and Nancy Hayden of 542 Elm Street , Northampton,
abuttors of Pioneer Valley Nursing Home , I hereby make the following
requests of you in your official capacity as building inspector for
the City of Northampton in accordance with Massachusetts General Laws ,
Chapter 40A, Sec . 7 .
1) We believe that the intensity of use of the Nursing Home has
increased dramatically without the Nursing Home home having first
obtained a zoning permit in accordance with sec . 10 . 2 of the City of
Northampton Zoning ordinance in that the number of employees has
recently increased almost two-fold and a new head trauma unit has been
recently established at the Nursing Home.
2) Said extension has also taken place without the benefit of a Special
Permit as required in sec . 9.3 of the City' s Zoning ordinance.
We call upon your office to immediately issue a cease and desist order
and further require that the Nursing Home immediately apply for a
Special and Zoning Permit .
3) The Pioneer Valley Nursing Home obtained. a Special Permit to
construct another story on a portion of the existing building on
April 20 , 1983 . No construction has commenced to date nor to our
knowledge has as,building permit been issued .
We call upon your office to notify the Pioneer Valley Nursing Home
that this permit has lapsed in accordance with sec . 1046 of the Zoning
ordinance .
We further call upon your office to enforce the provisions of sec .
Pale 2 April 25 , 1985
10 . 7 and sec . 10 . 8 of the Zoning ordinance in the event that
the Pioneer Valley Nursing Home takes no action on your requests.
We would expect to have your reply by May 14, 1985 in accordance
with said. Section 7 .
Very truly yours ,
ktiv
•
scan E . O'Leary AN 2 9 J11
Attorney for the Haydens .
m$ t�C�P15PEC7 oNs
0��'33GJv, mA:.011160
SO/me
CERTIFIED MAIL NO. •p620350581
wllimr",l
Law Offices of
SEAN E. O'LEARY _Z�":�.._._�-_;• t
JAMES E. BARNETT JR. ASSOC. `f�"CNAMAV*1.4,--�` .s.P -'K
184 Northampton Street It7 APR26'85 z L.S.N�SiAGt
'�:.� E_i .6 7
Easthampton, MA 01027 s p, �,�
CLAIM CHECK
NO.
Mr . Edward Tewhill
❑HoLo Building Inspector
DATE City of Northampton
CERTIFIED City Hall Annex
1ST Northampton, MA 01060
P 620 350 581
2ND NOTIC MAIL
RETURN 2
Detached from
PS Form 3849-A
Oct.1980