Professional Documents
Culture Documents
JANE DOE,
Plaintiff
CIVIL ACTION NO. 17-12337-IT
v.
The Defendants, Town of Stoughton (the “Town”), Juliette Miller (“Miller”), and
Marguerite Rizzo (“Rizzo”) (collectively the “Defendants”), hereby move this Honorable Court
pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure to dismiss Plaintiff’s
PRELIMINARY STATEMENT
Plaintiff, Jane Doe (“Doe” or “Plaintiff”), brings claims against the Town of Stoughton,
Juliette Miller, and Marguerite Rizzo resulting from a sexual relationship that she allegedly had
with a male teacher, Timothy Norton (“Norton”), while attending Stoughton High School
(“SHS”). Plaintiff alleges that the Defendants violated M.G.L. c. 119 § 51A, M.G.L. c. 151C,
Title IX, M.G.L. c. 71 § 370, and M.G.L. c. 12 §§ H-I when they failed to recognize and take
action to stop the alleged improper relationship between Plaintiff and Norton. Additionally,
Plaintiff alleges that the Town violated M.G.L. c. 258 and M.G.L. c. 71 § 37L.
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STATEMENT OF FACTS
Plaintiff alleges that during the 2013-2014 academic year she became involved in an
afterschool program called Destination Imagination at SHS. (Pltf. Compl. Dkt. No 1 pg. 2 at ¶
that promotes 21st century skills and teaches students in the areas of science, math, technology
and engineering. (Id. at ¶ 12). Students involved in Destination Imagination would participate in
tournaments whereby groups of students were tasked with developing solutions to open ended
problems. (Id. at ¶ 12). In order to prepare for tournaments, students would spend several hours
after school formulating their solutions. (Id. at ¶ 13). Plaintiff alleges that Norton was the school
advisor for Destination Imagination and the students participating in the program primarily
prepared for their tournaments in Norton’s classroom under his supervision. (Id. at ¶ 11).
Plaintiff alleges that during the 2014-2015 academic year, when she was a junior, she
again participated in Destination Imagination under the supervision of Norton. (Id. at ¶ 14).
Plaintiff also alleges that during her junior year she was in Norton’s project management class.
(Id. at ¶ 14). Plaintiff alleges that there was a separate backroom in Norton’s classroom that was
attached to the main classroom by a door. (Id. at ¶ 15). Plaintiff alleges that the backroom in
Norton’s classroom had limited availability for people to see what was going on inside. (Id. at ¶
15).
Plaintiff alleges that during her junior year, while participating in the Destination
Imagination program, Norton began to “groom” her. (Id. at ¶ 16). Plaintiff alleges that Norton
“groomed” her by: (1) allowing Plaintiff to keep her personal and school belongings in his
classroom, (2) allowing Plaintiff to rest in the backroom of his classroom during class, (3)
engaging in intimate one-on-one conversations with Plaintiff whereby they would discuss
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Plaintiff’s home life and non-educational matters in the presence of other students (4) texting
Plaintiff on a regular basis, (5) spending time with Plaintiff during school hours, and (6)
spending time alone with Plaintiff outside of school hours. (Id. at ¶ 16). Plaintiff also alleges
that from her junior year up until the time she graduated, Norton would provide her with passes
that enabled her to spend a significant amount of time in his classroom and he would provide
written requests to other teachers removing her from other classes in order to spend time with
Plaintiff alleges that she and Norton first became “physical” in November of 2014 and
they subsequently engaged in intercourse in February of 2015. (Id. at ¶ 19). Plaintiff alleges that
in the Fall of 2015 Miller conducted an investigation into Norton and Plaintiff’s relationship
because a classmate of Plaintiff’s reported that Norton was allegedly providing Plaintiff with
special treatment. (Id. at ¶ 20). Additionally, Plaintiff alleges that Miller received reports from a
student and teacher indicating that they saw Plaintiff exit her vehicle and enter Norton’s vehicle
near the school (Id. at ¶ 20). Plaintiff alleges that Miller questioned Plaintiff for about 15-30
minutes regarding the allegations made by the student and teacher. (Id. at ¶ 21). Plaintiff alleges
that Miller subsequently interviewed Norton regarding the allegations made by the student and
teacher. (Id. at ¶ 15). Plaintiff alleges that neither she nor Norton were disciplined as a result of
Plaintiff alleges that her relationship with Norton continued while she began her
undergraduate education and subsequently ended in September 2017. (Id. at ¶¶ 23, 30). Plaintiff
alleges that she told Cathy Boulger (“Boulger”), a teacher at SHS, about her relationship with
Norton after it ended. (Id. at ¶ 30). Plaintiff alleges that Boulger immediately reported Plaintiff’s
relationship with Norton to the SHS principal and other administrative personnel. (Id. at ¶ 31).
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Plaintiff also alleges that SHS served Norton with a termination letter and reported the matter to
Under Fed.R.Civ.P. 12(b)(6), a motion to dismiss for failure to state a claim is evaluated
by “taking it through the well-pleaded facts contained in the Complaint and drawing all
reasonable inferences therefrom in plaintiffs' favor.” Phoung Luc v. Wyndham Mgmt. Corp., 496
F.3d 85, 88 (1st Cir. Mass. 2007). The pleading rules are “not entirely toothless,” Fleming
v. Lind-Waldeck & Co., 922 F.2d 20, 23 (1st Cir. 1990) and the “minimal requirements are not
tantamount to nonexistent requirements.” Gilbert v. Cambridge, 932 F.2d 51, 62 (1st Cir. 1991).
In reviewing a motion to dismiss pursuant to Rule 12(b)(6), a court must “accept well-pleaded
facts as true and draw all reasonable inferences from those facts in favor of the plaintiff.”
Figueroa v. Rivera, 147 F.3d 77, 80 (1 51 Cir. 1998). However, the deference afforded
not logically compelled, or at least supported by the stated facts,” deserve no deference. United
States v. A VX Corp., 962 F .2d 108, 114 n. 8 (1st Cir. 1992). Where it appears from a review of
the complaint that the plaintiff could not legally recover under the facts as plead, dismissal is
appropriate. Hogan v. Eastern Enterprises/Boston Gas, 165 F. Supp2d 55, 57 (D. Mass. 2001).
ARGUMENT
A. Plaintiff’s M.G.L. c. 258 Claims Fail as a Matter of Law Because the Town
cannot be Liable for Conduct outside of the Scope of Employment.
M.G.L. c. 258, § 2, the Massachusetts Tort Claims Act ("MTCA"), provides for liability
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of public employers for injuries caused by the negligent acts or omissions of public employees
while acting within the scope of official employment. “Sexual misconduct by a teacher clearly
falls outside the scope of employment.” Doe v. Dubeck, CA No. 05-11163-RWZ, 2006 U.S. Dist.
LEXIS 40429 at *8 (D. Mass. June 19, 2006). Therefore, Plaintiff cannot maintain a claim under
the MTCA against the Town for Norton’s alleged sexual misconduct.
B. Plaintiff’s MTCA Claims Fail as a Matter of Law Because the Town Cannot
be Liable for Intentional Torts under M.G.L. c. 258 § 10(c).
M.G.L. c. 258 § 10(c) specifically provides that a municipality is not liable for the
intentional torts allegedly committed by its employees. Therefore, Plaintiff cannot maintain a
claim under the MTCA against the Town for any alleged intentional torts committed by Norton
M.G.L. c. 258 § 10(j) protects a municipality from liability “based on an act or failure to
act to prevent or diminish the harmful consequences of a condition or situation, including the
violent or tortious conduct of a third person, which is not originally caused by the public
employer or any other person acting on behalf of the public employer.” Therefore, “in order that
a claim not be barred by § 10(j), the claim must involve something more than the pure failure to
alleviate a private harm and that to be successful a claimant must show some involvement of a
public employee in creating the initial injury-causing scenario, not simply a failure to respond
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adequately after it arises.” Armstrong v. Lamy, 938 F. Supp. 1018, 1043 (D. Mass. 1996). As a
result, claims based upon alleged negligence in failing to protect a student from alleged sexual
abuse are barred by M.G.L. c. 258 § 10(j). Armstrong, 938 F. Supp. at 1044. Similarly, claims
Plaintiff’s MTCA claims, including the alleged failure to train/supervise Norton, fail as a
matter of law because the crux of Plaintiff’s Complaint is based upon the Town’s alleged failure
to prevent and/or stop Plaintiff and Norton from having a sexual relationship. Simply put,
Plaintiff’s claims stem from the Town’s alleged failure to prevent or mitigate harm, which
cannot provide for a cause of action under M.G.L. c. 258. See Armstrong, 938 F. Supp. at 1044;
see also Doe v. D'Agostino, 367 F. Supp. 2d 157, 177 (D. Mass. 2005) (Granting summary
judgment for municipality pursuant to § 10(j) resulting from allegations of municipal employee’s
is devoid of any factual allegations illustrating that the Town originally caused Norton to
sexually harass Plaintiff. See Doe v. Old Rochester Regional Sch. Dist., 56 F. Supp. 2d 114, 121
(D. Mass. 1999) (finding Defendant was not original cause under § 10(j) when it knew teacher
sexually assaulted other students and failed to limit teachers access to other female students).
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Plaintiff alleges that the Town’s employees, including Miller and Rizzi were inadequately
trained and supervised as to their duties as mandated reporters. (Pltf. Compl. Dkt. No 1 pg. 5 at
¶¶ 25-27). Additionally, Plaintiff alleges that Miller was inadequately trained and supervised as
municipalities where the municipality knew or should have known about an underlying,
identifiable tort which was committed by named or unnamed public employees.” Kennedy v.
Town of Billerica, 617 F.3d 520, 533 (1st Cir. 2010). Moreover, “no Massachusetts case has
been cited to us that has ever recognized a supervisory negligence claim against municipalities
for generalized, free-standing, and unspecified wrongs when no individual employee or group of
employees committed an underlying tort.” Id. “Although Chapter 119, section 51A, is generally
intended to protect the children of Massachusetts, it does not create a legal duty owed by
mandated reporters for the purpose of a negligence action.” Roe v. Children's Hosp. Med. Ctr.,
2012 Mass. Super. LEXIS 191, *14, 2012 WL 3637246 (Mass. Super. Ct. July 12, 2012).
Here, Plaintiff’s claims for negligent training and supervision fail as a matter of law
because M.G.L. c. 119 § 51A does not create a private right of action. Additionally, as discussed
above M.G.L. c. 258 § 10(j) precludes Plaintiff from bringing suit based upon the failure to
prevent or mitigate harm. Moreover, neither Miller nor Rizzi committed a tortious act against
Plaintiff. Therefore, Plaintiff’s negligent training and supervision claims are not based upon an
underlying identifiable tort for which the Town can be liable. Consequently, Plaintiff’s claims
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Plaintiff attempts to assert a claim pursuant to M.G.L. c. 119, § 51A against the Town,
Miller and Rizzi. Said statute requires persons that qualify as mandated reporters to report
suspected child abuse to the Department of Social Services. M.G.L. c. 119, § 51A expressly
provides that “whoever violates this section shall be punished by a fine of not more than $1,000.”
Despite creating a statutory fine, M.G.L. c. 119, § 51A does not create a private right of action.
Doe v. Dubeck, CA No. 05-11163-RWZ, 2006 U.S. Dist. LEXIS 40429 at *18-20 (D. Mass. June
19, 2006). Therefore, Plaintiff’s claims under M.G.L. c. 119, § 51A fail as a matter of law.
Accordingly, Count II (Doe v. Town), Count III (Doe v. Miller), and Count IV (Doe v.
Plaintiff attempts to assert a claim pursuant to M.G.L. c. 71, §§ 37L, 37O against the
Town, Miller and Rizzi. M.G.L. c. 71 §§ 37L, 37O are public policy statutes enacted to protect
students in public schools. The provisions of both statutes fail to provide for a private right of
action. See M.G.L. c. c. 71 § 37L and M.G.L. c. 71 § 37O; see also Morgan v. Town of
Lexington, 823 F.3d 737, 741 at n. 2 (1st Cir. 2016) (stating that “the legislature made the choice
not to "create a private right of action" through M.G.L. c. 71 § 37O). Therefore, Plaintiff’s
claims under M.G.L. c. c. 71 § 37L and M.G.L. c. 71 § 37O fail as a matter of law.
Accordingly, Count II (Doe v. Town), Count III (Doe v. Miller), and Count IV (Doe v.
Rizzi) alleging violations of M.G.L. c. c. 71 § 37L and M.G.L. c. 71 § 37O must be dismissed.
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In relevant part, M.G.L. c. 151C § 2(g) makes it unlawful for any educational institution
“[t]o sexually harass students in any program or course of study in any educational institution.”
In order to bring claims under M.G.L. c. 151C, “Plaintiffs must satisfy the administrative
exhaustion requirement of Mass. Gen. L. c. 151B, § 9, 1 made applicable to c. 151C under Mass.
Gen. L. c. 214, § 1C. 2” Harrington v. City of Attleboro, 172 F. Supp. 3d 337, 351 (D. Mass.
2016); see also Bloomer v. Becker College, CA. No. 09-11342-FDS, 2010 U.S. Dist. LEXIS
82997 at *17-20 (D. Mass. Aug. 13, 2010) (discussing requirement of exhausting administrative
remedies prior to filing suit under M.G.L. c. 151C). Simply put, prior to filing suit, Plaintiff must
Discrimination (“MCAD”).
Here, Plaintiff failed to file a charge of discrimination with MCAD prior to filing suit.
Therefore, Plaintiff has failed to exhaust her administrative remedies and as such her claims
1
In relevant part, M.G.L c. 151B, § 9 states “Any person claiming to be aggrieved by a practice made unlawful
under this chapter or under chapter one hundred and fifty–one C, or by any other unlawful practice within the
jurisdiction of the commission, may, at the expiration of ninety days after the filing of a complaint with [MCAD], or
sooner if a commissioner assents in writing, but not later than three years after the alleged unlawful practice
occurred, bring a civil action for damages or injunctive relief or both in the superior or probate court for the county
in which the alleged unlawful practice occurred or in the housing court within whose district the alleged unlawful
practice occurred if the unlawful practice involves residential housing.”
2
M.G.L c. 214, § 1C states “A person shall have the right to be free from sexual harassment, as defined in chapter
one hundred and fifty–one B and one hundred and fifty–one C. The superior court shall have the jurisdiction to
enforce this right and to award the damages and other relief provided in the third paragraph of section 9 of chapter
151B. Any such action shall be commenced in the superior court within the time allowed by said section 9 of said
chapter 151B. No claim under this section that is also actionable under chapter 151B or chapter 151C shall be
brought in superior court unless a complaint was timely filed with the Massachusetts commission against
discrimination under said chapter 151B.”
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Accordingly, Count II (Doe v. Town), Count III (Doe v. Miller), and Count IV (Doe v.
Assuming arguendo, Plaintiff’s claims under M.G.L. c. 151C were viable, these claims
fail as a matter of law against Miller and Rizzi because persons cannot be liable under the statute.
M.G.L. c. 151C § 2(g) makes it unlawful for any educational institution “[t]o sexually
harass students in any program or course of study in any educational institution.” In relevant
part, M.G.L. c. 151C, § 1 defines educational institution as “any institution for instruction or
training.” Here, M.G.L. c. 151C undeniably does not create a private right of action against
persons. See M.G.L. c. 151C; Thomas v. Salem State Univ. Found., Inc., 2011 U.S. Dist. LEXIS
121036, *15-16, 2011 WL 5007973 (D. Mass. Oct. 18, 2011). Therefore, Plaintiff’s claims under
Accordingly, Count III (Doe v. Miller) and Count IV (Doe v. Rizzi) alleging violations of
Title IX provides, in part, that: “no person . . . shall, on the basis of sex, be excluded from
participation in, be denied the benefits of, or be subjected to discrimination under any
Accordingly, the private right of action created under Title IX “extends only to claims against the
educational institution itself.” Frazier v. Fairhaven Sch. Comm., 276 F.3d 52, 65 (1st Cir. 2002).
Therefore, Plaintiff’s Title IX claims against Miller and Rizzi fail as a matter of law because the
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statute does not create a private right of action against individual defendants.
Accordingly, Count III (Doe v. Miller), and Count IV (Doe v. Rizzi) alleging violations
"(1) that [he or she] was a student, who was (2) subjected to harassment (3) based upon sex; (4)
that the harassment was sufficiently severe and pervasive to create an abusive educational
environment; and (5) that a cognizable basis for institutional liability exists." Frazier v.
Fairhaven Sch. Comm., 276 F.3d 52, 66 (1st Cir. 2002). To satisfy the fifth part of that standard,
a plaintiff must show that a school official authorized to take corrective action had "actual
knowledge" of the sexual harassment and either failed to act or exhibited "deliberate
indifference" to it. Id. Plaintiff fails to allege factual allegations in her Complaint supporting the
A. Plaintiff’s Title IX Claims Fail as a Matter of Law Because the Town did not
Have Actual Knowledge of the Alleged Sexual Harassment.
requiring highly reliable and similar reports of inappropriate teacher behavior.” Doe v.
Bradshaw, 203 F. Supp. 3d 168, 185 (D. Mass. 2016). Moreover “inappropriate behavior of a
different nature than the eventual harassment cannot give rise to actual knowledge for Title IX
purposes.” Id. Furthermore, “the case law is clear that only reliable and unambiguous reports
Plaintiff’s Title IX claim against the Town fails as a matter of law because she has failed
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to plead facts illustrating that the Town had actual knowledge of the alleged sexual harassment
while Plaintiff was a student at SHS. Here, the only allegations in Plaintiff’s Complaint that hint
at the Town having knowledge of any alleged sexual harassment are: 1) a student reported to
SHS that Norton was providing Plaintiff with special treatment, and 2) a student and teacher
reported to SHS that they saw Plaintiff get into Norton’s vehicle. (Pltf. Compl., Dkt. No 1, pg. 4
at ¶ 20). However, there is nothing about the above described allegations that rises to the level of
actual knowledge in the Title IX context. See Doe v. Bradshaw, 203 F. Supp. 3d 168, 185-86 (D.
Mass. 2016) (finding no actual knowledge when school received reports that teacher was buying
alcohol for students, there were unsubstantiated rumors that teacher had inappropriate
relationship with student, and another teacher reported overly familiar behavior between student
and teacher); Doe v. D'Agostino, 367 F. Supp. 2d 157, 165-67 (D. Mass. 2005) (finding no actual
knowledge when school received reports that teacher was making comments about girls’
genitals, teacher was incentivizing students with personal trips, teacher was holding students’
hands while walking down hallways, and teacher was tickling students). Indeed, “inappropriate
behavior of a different nature than the eventual harassment cannot give rise to actual knowledge
for Title IX purposes.” Doe v. Bradshaw, 203 F. Supp. 3d at 185. Here, it is undeniable that the
allegations in Plaintiff’s Complaint cannot impute actual knowledge on the Town. Therefore,
B. Plaintiff’s Title IX Claims Fail as a Matter of Law Because the Town was not
Deliberately Indifferent to the Alleged Sexual Harassment.
. . . is clearly unreasonable in light of the known circumstances." Davis v. Monroe, 526 U.S. 629,
644 (1999). Under Title IX “[t]he test is objective -- whether the institution's response, evaluated
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"Title IX does not require educational institutions to take heroic measures, to perform flawless
investigations, [or] to craft perfect solutions." Fitzgerald v. Barnstable Sch. Comm., 504 F.3d
165, 174 (1st Cir. 2007), rev'd on other grounds, 555 U.S. 246, 129 S. Ct. 788, 172 L. Ed. 2d 582
(2009).
Plaintiff’s Title IX claim fails as a matter of law because she has failed to plead any facts
demonstrating that the Town’s response to the alleged harassment was clearly unreasonable. To
this point, the Town received the above described reports from a student and teacher, which did
not suggest sexual harassment, and it acted appropriately by conducting an investigation. During
the investigation Norton and Plaintiff 3 were interviewed and questioned about their relationship.
Subsequently, the investigation concluded and neither Norton nor Plaintiff were disciplined
because the investigation did not expose any sexual harassment. Moreover, Plaintiff’s complaint
is devoid of any allegations demonstrating that Plaintiff or any other person notified the Town
about Plaintiff’s relationship with Norton while Plaintiff was a student at SHS. Here, there are
simply no allegations in Plaintiff’s complaint suggesting that the Town’s response was
unreasonable in light of the known circumstances. This is not a situation where the Town
received notice that Plaintiff was having a sexual relationship with Norton and failed to act or
turned a blind eye. Here, the Town had no articulable evidence that Norton was sexually
harassing Plaintiff. Indeed, the only evidence available to the Town was that Norton was
providing plaintiff with special treatment and that Plaintiff got into Norton’s car. These
In reality, the Town did not become aware of Plaintiff’s relationship with Norton until
3
Here, there are no allegations in Plaintiff’s complaint alleging that during Plaintiff’s interview she complained of
sexual harassment.
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September of 2017, after Plaintiff graduated. Immediately upon learning of the relationship, the
Town terminated Norton’s employment and reported the matter to the Stoughton Police
Department. (Id. at pg. 5, ¶ 23; pg. 6 ¶ 30-32). Here, it is undeniable that the Town’s initial
investigation and subsequent termination of Norton were reasonable in light of the known
The Massachusetts Civil Rights Act (“MCRA”), M.G.L. c. 12 §§H-I, holds persons
accountable for violations of civil rights that stem from threats, intimidation or coercion. M.G.L.
c. 12, § 11H-I. It is well settled law that “a municipality is not a "person" covered by the
Massachusetts Civil Rights Act.” Howcroft v. City of Peabody, 51 Mass. App. Ct. 573, 591-592
(2001). Accordingly, a municipality may not be subject to suit under the MCRA. Id. Therefore,
dismissed.
In order to state a claim under sections 11H and 11I of the MCRA, "the plaintiff must
prove that the defendants used 'threats, intimidation or coercion' to interfere with, or attempt to
interfere with rights secured by the Constitution or laws of the United States or of the
Commonwealth of Massachusetts." Brum v. Town of Dartmouth, 428 Mass. 684, 704 N.E.2d
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1147, 1162 (Mass. 1999). "Threat in this context involves the intentional exertion of pressure to
make another fearful or apprehensive of injury or harm.” Planned Parenthood League v. Blake,
417 Mass. 467, 474 (1994). "Intimidation involves putting in fear for the purpose of compelling
or deterring conduct.” Id. “Coercion [involves] the application to another of such force, either
physical or moral, as to constrain him to do against his will something he would not otherwise
Plaintiff’s MCRA claims against Miller and Rizzi fail as a matter of law because the
complaint is devoid of any factual allegations illustrating that Miller and/or Rizzi threatened,
intimidated, or coerced Plaintiff. Indeed, the allegations against Miller and Rizzi are that they
should have recognized Norton’s alleged “grooming” behavior, that they neglected their duties
as mandated reporters, and that they should have investigated further into Norton and Plaintiff’s
alleged relationship. (See Pltf. Compl., Dkt. No. 1, ¶¶ 24, 26, 27, 29). These allegations simply
do not amount to threats, intimidation, or coercion and as a result Plaintiff’s MCRA claims fail
as a matter of law.
Accordingly, Count III (Doe v. Miller) and Count IV (Doe v. Rizzi) alleging violations of
CONCLUSION
For the above stated reasons, Defendants, Town of Stoughton, Juliette Miller, and
Marguerite Rizzo, respectfully move this Court to dismiss all counts asserted against them in the
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Defendants,
Town of Stoughton, Juliette Miller and
Marguerite Rizzi,
By their attorney,
/s/Douglas I. Louison
_____________________________
Douglas I. Louison, BBO# 545191
dlouison@lccplaw.com
Louison, Costello, Condon & Pfaff, LLP
101 Summer Street
Boston, MA 02110
(617) 439-0305
Date: December 20, 2017
CERTIFICATE OF SERVICE
I, hereby certify that on December 20, 2017, the foregoing document was served via ECF
or first class mail, postage prepaid to the following:
/s/Douglas I. Louison
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