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20120422 Johnson Settlement Demand 22 April 2012

20120422 Johnson Settlement Demand 22 April 2012

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Published by William F. Zachmann
Letter from Follansbee to Kesten with Johnson Golf settlement demand of 22 April 2012
Letter from Follansbee to Kesten with Johnson Golf settlement demand of 22 April 2012

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Published by: William F. Zachmann on Jun 21, 2012
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06/21/2012

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F
OLLANSBEE AND
M
C
L
EOD
,
 
LLP
 
ATTORNEYS AT LAW
 
536
 
G
RANITE
S
TREET
,
 
3
RD
 
F
LOOR
E
AST
 B
RAINTREE
,
 
M
ASSACHUSETTS
02184
 TELEPHONE
 
(781)
 
848-1500 FACSIMILE
 
(781)
 
848-2220
April 22, 2012Leonard Kesten, Esq.Brody, Hardoon, Perkins & Kesten, PC1 Exeter Plaza, 12
th
FloorBoston, MA 02116Re: Johnson Golf Management v. Town of Duxbury et alMiddlesex Superior Court, Docket No. 08-04641-B
FOR SETTLEMENT PURPOSES ONLY
Dear Lenny:As you requested, we are prepared to submit the following as an alternative to the demand forsettlement of the above referenced action. Please see correspondence of March 13, 2012, re-submitted herewith, for underlying details.As you know, we have made multiple overtures to resolve this litigation without any responsefrom the Town of Duxbury.Astonishingly, the recent deposition testimony of Ms. Elizabeth Sullivan indicates that she neverread the settlement materials from my office or the settlement materials submitted directly fromMr. Johnson. Assuming for present purposes that she is to be believed, her testimony raisesserious issues concerning the neglect of her duties as a Selectwoman. I do not have a copy of hertranscript yet, but my notes indicate that she failed to follow the Town By-Laws regarding theengagement of counsel to defend the Town in the present litigation, costing the Town of Duxburyhundreds of thousands of dollars in needless legal fees.Had Ms. Sullivan and/or the other Selectmen fulfilled their responsibilities in January 2009, thiscase would have settled with no negative impact on the taxpayers of Duxbury. As you know,Johnson proposed a settlement one day after the Award Letter was executed by RichardMacDonald. The ensuing three and one half years of lies and misrepresentations by Duxburyofficials have created the situation we find ourselves in today.In the event that the Town of Duxbury elects to forego an award of a contract to Johnson Golf asper my letter of March 13, 2012, my client has authorized me to submit the following alternatedemand for settlement purposes:

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