From: 

Elias Fillas 

Sent: Tuesday, October 26, 2021 6:20 PM

To: 'amarshall@kdvlaw.com' <amarshall@kdvlaw.com>
Cc: Zachary Kaplan <ZKaplan@saccofillas.com>

Subject: For Settlement and Negotiation Purposes

Only
 
Adam, it was a pleasure speaking with you earlier today.
 
As I stated in our conversation, in an effort to resolve the dispute
between our respective clients and to bring an end to the litigation
between the parties, the
residents that are represented by my firm would be amenable to
dismissing the action filed against the DMA if the following terms are
agreeable to your clients.
 
1. A security committee shall be created to solicit bids for security services,
North Shore Security shall be precluded from submitting a bid. North
Shore’s contract shall be immediately terminated upon the retention of
a new security service.
2. Adopt a resolution that any and all waivers of DMA dues for any
member, employee or resident be immediately revoked. All residents
shall be required to pay membership dues.
3. Adopt a resolution whereby the Secretary of the DMA shall be an
elected position.
4. Adopt a resolution whereby the office manager’s position shall be an at-
will employee position for a 20 hour per week work schedule and shall
be subject to the annual review, approval and modification of the DMA
Board. The office manager shall be precluded from serving as Secretary
of the DMA Board. The DMA Board shall create a detailed job
description for the office manager on or before December 31, 2021.
5. The hours of operation of the DMA office and any changes to the office
schedule shall be published to all residents whether by email or regular
mail.
6. Adopt a resolution that any and all checks, contracts and any other
documentation that binds, obligates or exposes the DMA to any
agreement or liability with respect to any third parties must be executed
by an elected DMA board member, not an at-will employee or office
manager.
7. The creation of a clearly defined process by which residents can review
the complete financial records and minutes of the DMA.
8. Holding the annual meeting/elections on or before December 15th,
2021.
 
As you indicated in our conversation, some of the aforementioned items
are not specifically referenced in the initial action that we filed, however,
as you are aware, we do have the right to supplement and/or amend our
pleadings to include these items. If however our respective clients can
agree on these terms, further litigation will not be required.  
 
Please discuss the above proposal with your clients and respond
accordingly.
 
Thank you for your courtesy and attention to this matter.