Am Project Norwood Llc Vs. Endicott South Development Corporation Et Al

Affidavit of compliance with Superior Court Rule 9a

MEMORANDUM & ORDER: on Plaintiff's Motion for Reconsideration and Defendant's Motion for Separate and Final Judgment: Both Motions are DENIED Judge: Ricciuti, Hon. Michael D (see P#107 for full decision and order) (dated 7/1/22) notice sent 7/12/22

Endorsement on Motion to Strike the affidavit of John O. Mirick (#89.0): Other action taken The Court will hear argument on this motion when it hears the Summary judgment motion entered 10/6/2021 notice sent 5/3/2022 Judge: Ricciuti, Hon. Michael D

Exhibits/Appendix

Reply/Sur-reply in further support of motion for reconsideration Applies To: AM Project Norwood LLC (Plaintiff)

9A list of documents

Opposition to plaintiff's motion for reconsideration RE: summary judgment filed by Endicott South Development Corporation, Peter True

Notice of filing

Reply/Sur-reply in further support of motion for entry of separate and final judgment Applies To: Endicott South Development Corporation (Defendant)

AM Project Norwood LLC's Memorandum in support of motion for reconsideration RE: summary judgment

Plaintiff AM Project Norwood LLC's Motion for reconsideration RE: summary judgment

Defendant Endicott South Development Corporation's Motion for separate and final judgment

MEMORANDUM & ORDER: on Motions for Summary Judgment Brought By (1) Endicott South Development Corporation and Peter True and (2) Bernkopf Goodman LLP: Endicott South Development Corp and Peter True's Motion for Summary Judgment is ALLOWED. Bernkopf Goodman LLP's Motion is DENIED. Endicott South Development Corp's motion to Strike the Affidavit of John O. Mirick is DENIED as Moot (See P#99.1 for full Decision and Order) (dated 2/26/22) Judge: Ricciuti, Hon. Michael D

Opposition to defendant's motion for separate and final judgment filed by AM Project Norwood LLC

Certificate of service and notice of filing

List of documents

Defendant Endicott South Development Corporation's Notice of filing under Superior Court Rule 9A

Defendant Endicott South Development Corporation's Submission of list of Rule 9A documents

Exhibits/Appendix

Opposition to Endicott's motion to compel payment of membership distributions filed by AM Project Norwood LLC, JS Management LLC, Jan Steenbrugge

Affidavit of Sharon M. Marsh

Defendant Endicott South Development Corporation's Motion to compel payment of it's membership distributions (w/opp. and reply). [CLERK'S NOTE: MOTION WITHDRAWN BY ENDICOTT]

Endorsement on Motion for Leave for Additional Pages on Reply to Opposition to Motion for Summary Judgment (#95.0): ALLOWED (dated 10/25/21) notice sent 10/29/21

Endorsement on Motion for Leave for additional Day to re-Serve Motion for Additional Pages on Reply to Opposition to Motion for Summary Judgment (#94.0): ALLOWED (dated 10/25/21) notice sent 10/29/21

Defendant Bernkopf Goodman LLP's Motion for Leave for additional pages on reply to Endicott South Development Corporation's Opposition to Bernkopf Goodman LLP's Motion for Summary Judgment

Defendant Bernkopf Goodman LLP's Assented to Motion for Leave for an additional day to Re-Serve Motion for additional pages on Reply to Endicott South Development Corporation's Opposition to Bernkopf Goodman LLP's Motion for Summary Judgment

Defendant Bernkopf Goodman LLP's Submission of List of Documents Filed

Opposition to motion for summary judgment filed by AM Project Norwood LLC (corrected)

Affidavit of Compliance with Superior Court Rule 9A Applies To: Kelley, Esq., Kristyn M (Attorney) on behalf of Bernkopf Goodman LLP (Defendant)

Plaintiff AM Project Norwood LLC's Submission of affidavit of Jack I. Siegal accompanying (corrected) opposition to motion for summary judgment

Defendant Bernkopf Goodman LLP's Submission of 9C Certification

Reply/Sur-reply in further support of it's motion to compel payment of it's membership distributions Applies To: Endicott South Development Corporation (Defendant)

Defendant Bernkopf Goodman LLP's Notice of Filing

Reply/Sur-reply Defendant Endicott South Development Corporation's Reply Memorandum in further Support of its Motion to Strike the Affidavit of John O Mirick

Opposition to Defendant Endicott South Development Corporation's Motion to Strike the Affidavit of John O Mirick filed by Bernkopf Goodman LLP

Defendant Endicott South Development Corporation's Motion to Strike the Affidavit of John O Mirick

Opposition to to Bernkopf Goodman LLP motion for leave to file additional pages on reply and Endicott's Request for Fees and expenses filed by

Opposition to Bernkopf Goodman LLP's Motion for Leave to file additional pages on Reply and Endicott's Request for Fees and Expenses filed by Endicott South Development Corporation

Proposed Filings/Orders

Defendant Bernkopf Goodman LLP's Motion for Leave for additional pages on reply to Endicott South Development Corporations Opposition to Bernkopf Goodman LLP motion for Summary Judgment

Endorsement on Motion to Impound or to File Joint Appendix Exhibits Under Seal (#70.0): ALLOWED See Rule 7(e), Trial court Rule VIII (dated 8/12/21) notice sent 8/24/21

Defendant Bernkopf Goodman LLP's Submission of list of documents

Defendant Bernkopf Goodman LLP's Request for hearing

Defendant Bernkopf Goodman LLP's Notice of filing

Defendant Bernkopf Goodman LLP's Certificate of Rule 9C

Affidavit of compliance with Superior Court Rule 9A

Exhibits/Appendix

Certificate of Compliance Superior Court Rule 9A (b)(5)(v)(B) Applies To: Deiulis, Esq., Michael (Attorney) on behalf of Endicott South Development Corporation (Defendant)

Plaintiff AM Project Norwood LLC's Submission of Combined Rule 9A(b)(5) Statement of Facts Applies To: AM Project Norwood LLC (Plaintiff); Endicott South Development Corporation (Defendant); True, Peter (Defendant)

Endicott South Development Corporation, Peter True's Reply Memorandum in Further Support of their Consolidated Motion for Summary Judgment

Opposition to Defendants' Motion for Summary Judgment (P#72) filed by AM Project Norwood LLC

Endicott South Development Corporation, Peter True's Memorandum in support of their Consolidated Motion for Summary Judgment

Defendants Endicott South Development Corporation, Peter True's Motion for summary judgment, MRCP 56 (w/opposition) (Consolidated Motion)

Affidavit Thomas T Reith

Defendant Endicott South Development Corporation, Peter True's Assented to Motion to Impound or File Joint Appendix Exhibits Under Seal

Endorsement on Submission of Conference Memorandum Proposed Agenda for Rule 16 Litigation Control Conference (#69.0): ALLOWED SO ORDERED. (dated 1/11/21) notice sent 1/13/21

Plaintiff AM Project Norwood LLC's Notice of WITHDRAWL OF MICHAEL P BURKE AS COUNSEL FOR PLFF AM PROJECT NORWOOD LLC AND COUNTERCLAIM DEFTS

Received from Defendant Bernkopf Goodman LLP: Answer with a counterclaim; (filed on 1/24/20) Applies To: Bernkopf Goodman LLP (Defendant)

Attorney appearance On this date Jameson J Pasek, Esq. added for Plaintiff AM Project Norwood LLC

Conference Memorandum Proposed Agenda for Rule 16 Litigation Control Conference

Notice of docket entry received from Appeals Court Please take note that, with respect to the Petition pursuant to G.L. c. 231, s. 118 filed for Endicott South Development Corporation by Attorney Susan Stenger. (Paper #1), on February 6, 2020, the following order was entered on the docket of the above-referenced case: RE#1: After careful review of the petition and response, the petition is denied. The petition fails to establish that the trial court judge committed any clear abuse of discretion or error of law. See Aspinall v. Phillip Morris Companies, Inc., 442 Mass. 381, 390 (2004), quoting Jet-Line Servs., Inc. v. Selectmen of Stoughton, 25 Mass. App. Ct. 645, 646 (1988) ("In most cases, based on the deference normally accorded determinations by the judge who heard the matter in the first instance, the single justice will decline to act on an application for relief under G. L. c. 231, s. 118, first par., that does not disclose clear error of law or abuse of discretion."). Recognizing that I have the discretion to order the petitioner to pay attorney's fees, see G. L. c. 231, s. 118, first par., I decline to exercise that discretion in light of the complexity of the issues presented. (Ditkoff, J.) Notice/attest/Sanders, J.

Endorsement on Motion for Reconsideration of Decision and Order (#64.0): DENIED (dated 1/13/20) notice sent 1/15/20 Judge: Sanders, Hon. Janet L

Notice of docket entry received from Appeals Court Please take note that, with respect to the Petition pursuant to G.L. c. 231, s. 118 filed for Endicott South Development Corporattion by Attorney Susan Stenger. (Paper #1), on January 2, 2020, the following order was entered on the docket of the above-referenced case: RE#1: Appellate proceedings stayed to 02/03/2020 pending disposition of petitioner's motion for reconsideration. Status report due on or before that date as to disposition of the motion.. *Notice/Attest/Sanders

Defendant Bernkopf Goodman LLP's Submission of Proposed Agenda for BLS Rule 16 Litigation Control Conference: Proposal on Page 4 is Adopted as to AM Project Expert Depositions of both True and Steenbrugge to take place by 2/25/20; all remaining fact discovery to be complete on/before 3/27/20. Remaining expert discovery by 5/15/20; Rule 16 conference 4/9/20 at 2:00pm (dated 12/12/19) notice sent 12/18/19

Plaintiff AM Project Norwood LLC's Submission for and deft Endicott South Development Corp proposed agenda for BLS Rule 16 Litigation Control Conference

Endorsement on Motion for Leave to File Documents Under Seal (#53.0): ALLOWED (dated 11/6/19) notice sent 11/26/19

MEMORANDUM & ORDER: on Cross Motions to Compel: This court concludes that AM Project's Motion must be ALLOWED and that Endicott's Motion must be DENIED Judge: Sanders, Hon. Janet L (see P#60 for complete decision) (dated 11/25/19) notice sent 11/26/19

Endorsement on Motion to Compel (#56.0): DENIED See Memorandum of Decision (dated 11/25/19) notice sent 11/26/19

ORDER: Order on Plaintiff's Motion to Compel Discovery (see P#59) (dated 11/25/19) notice sent 11/26/19

Endorsement on Motion to Compel (#52.0): ALLOWED See Memorandum of Decision (dated 11/25/19) notice sent 11/26/19

Plaintiff in a Counterclaim AM Project Norwood LLC's Assented to Request for hearing on Motion to amend complaint to add party deft

Endorsement on Motion to Consolidate (#51.0): ALLOWED see endorsement on P#54 (dated 11/7/19) notice sent 11/9/19

Endorsement on Motion to Consolidate (#54.0): ALLOWED as to pretrial purposes only, with questions of consolidation for trial purposes deferred (dated 11/7/19) notice sent 11/9/19

Affidavit of Peter True in Support of Endicott South Development Corporation's Motion to Compel Discovery

Endorsement on Motion to Amend Case Scheduling Order (#55.0): ALLOWED (dated 10/7/19) notice sent 10/8/19

Defendant Endicott South Development Corporation's Motion to compel discovery from AM Project Norwood LLC & other defts in counterclaim (w/opposition)

Plaintiff AM Project Norwood LLC's Motion to amend the case scheduling order

Defendant in a Counterclaim Bernkopf Goodman LLP's Motion to consolidate with 1984-1792 (w/opposition)

Plaintiff in a Counterclaim AM Project Norwood LLC's Assented to Motion for leave to file documents under seal

Plaintiff AM Project Norwood LLC's Motion to compel (w/opposition)

Defendant in a 3rd Party Claim Endicott South Development Corporation's Motion to consolidate (w/opposition)

Letters Rogatory Deposition of Gary Lewis Judge: Salinger, Hon. Kenneth W

AMENDED ORDER: case scheduling order; (dated 4/4/19) notice sent 4/9/19

Commission to take Out of State Deposition: order Deposition of Gary Lewis Notice sent 4/12/19 Judge: Salinger, Hon. Kenneth W

Plaintiff AM Project Norwood LLC's Assented to Motion for letter rogatory for issuance of subpoenas to witness locacted outside of the Commonwealth Allowed Notice Sent 4/12/19

Endorsement on Motion to amend the case scheduling order; (#46.0): ALLOWED See amended scheduling Order. The June 11, 2019 scheduling conference is continued to October 17, 2019, at 2:00P.M. (dated 4/4/19) notice sent 4/9/19

MEMORANDUM & ORDER: Denying Plaintiff's Motion for Injunctive Relief to Allow for EW Development to Enter into Loan Modification Judge: Salinger, Hon. Kenneth W (see P#45 for full decision) (dated 1/17/19) notice sent 1/22/19

Endorsement on Motion for Leave to File Nine-Page Reply Memo (#42.0): ALLOWED (dated 1/14/19) notice sent 1/22/19

Endorsement on Motion for Leave to File Sur-Reply (#41.0): ALLOWED (dated 1/14/19) notice sent 1/22/19

Endorsement on Motion for Injunctive Relief to Allow EW Development to enter into Loan Modification (#35.0): DENIED after hearing. See Memorandum and Order (dated 1/17/19) notice sent 1/22/19

Endorsement on Request for Briefing Schedule and Hearing Date (#34.0): ALLOWED (dated 12/20/18) notice sent 12/21/18

Endorsement on Motion to dismiss (#20.0): DENIED (See Memorandum of Decision ) Notice sent 8/21/18 Judge: Sanders, Hon. Janet L

Defendants Endicott South Development Corporation's EMERGENCY Motion to Compel the plaintiff to serve pursuant to superior court rule 9A or in the alternative to reschedule hearing on the un-served motion for preliminary injunction; ALLOWED in that December 20 date for hearing is CANCELLED. As defendant points out (and this court overlooked), plaintiffs has filed only a motion or short order of notice on a motion for preliminary injunction that has not yet been filed. Plaintiff must file and serve the underlying motion first before this court is in a position to schedule any hearing. Moreover, on further consideration, this court fails to see why any motion once filed must be heard on an expedited basis based on what plaintiff has filed with the court so far. Because of the holiday and because of this court's own schedule, this court suggests that, if and when a motion for injunctive relief is filed, that matter should be scheduled for hearing the week of January 2, 2019. dated 12/14/18 notice sent 12/17/18

ORDER: Case Scheduling Order (see P#30) (dated 9/17/18) notice sent 9/18/18 Judge: Sanders, Hon. Janet L

Endorsement on Motion for (#24.0): DENIED partial Summary Judgment Denied (See Memorandm of Decision) Notice sent 8/24/18 Judge: Sanders, Hon. Janet L

MEMORANDUM & ORDER: on Endicott South Development Corp and Peter True's special Motion to Dismiss & Denied Notice Sent 8/21/18 Judge: Sanders, Hon. Janet L Judge: Sanders, Hon. Janet L Judge: Sanders, Hon. Janet L Judge: Sanders, Hon. Janet L

Received from Defendant Bernkopf Goodman LLP: Answered;

Amended: amended complaint filed by AM Project Norwood LLC & jury demand

Service Returned for Defendant Endicott South Development Corporation: & Peter True Service accepted by counsel;

Endorsement on Motion of Sever and Stay (#19.0): DENIED (dated 5/7/18) notice sent 5/9/18 Judge: Salinger, Hon. Kenneth W

Received from Counterclaim Defendants Answer to the Counterclaim of Endicott South Development Corporation Applies To: AM Project Norwood LLC (Plaintiff); JS Management LLC (Defendant); Ad Meloria Construction LLC (Defendant); AM Building Supply LLC (Defendant); Steenbrugge, Jan (Defendant)

Endorsement on Motion to amend the (#14.0): ALLOWED complaint Allowed without opposition The amended conmplaint shall be docketed Notice Sent 2/1/18 Judge: Salinger, Hon. Kenneth W

Received from Defendant AM Building Supply LLC: Answer with claim for trial by jury; Applies To: JS Management LLC (Defendant); Ad Meloria Construction LLC (Defendant); AM Building Supply LLC (Defendant); Steenbrugge, Jan (Defendant)

Received from Defendant Endicott South Development Corporation: Answer to amended complaint and Counterclaim

Received from Defendant EW Development LLC & :(counterclaims defts ) Answer to the Counterclaim;of South Development Corp Amended counterclaim & jury demand

ORDER: Scheduling Notice Sent : 01/12/2018 Judge: Salinger, Hon. Kenneth W

Plaintiff AM Project Norwood LLC's Joint Motion to Stay Litigation: ALLOWED. Rule 16 conference scheduled for 1/11/18 at 2:00pm (dated 10/26/17) notice sent 10/27/17 Judge: Sanders, Hon. Janet L

Plaintiff AM Project Norwood LLC's Motion to set case schedule and lift stay Notice Sent : 01/12/2018 (01/12/2018) ALLOWED IN PART The stay is lifted. See separate case schedule. Judge: Kaplan, Hon. Mitchell H

Received from Plaintiff AM Project Norwood LLC: Answer to the Counterclaim; & counterclaim & jury demand

Service Returned for Defendant Endicott South Development Corporation: Service made in hand;

Service Returned for Defendant Endicott South Development Corporation: Service accepted by counsel; Affidavit of Acceptance Filed

General correspondence regarding Notice of Acceptance into Business Litigation Session BLS 2 Notice sent 8/31/17

Original civil complaint filed.

Endorsement on Motion to appoint Thomas Maffel, esq. as special master (#10.0): ALLOWED Notice Sent : 12/13/2017 (12/12/17) ALLOWED Judge: Sanders, Hon. Janet L

Plaintiff AM Project Norwood LLC's Motion for short order of notice regarding motion to lift stay of action Notice in hand : 01/03/2018 (01/03/2018) ALLOWED Judge: Sanders, Hon. Janet L

ORDER: Judgment Upon consideration of the Agreement for Judgment (Dkt. 126), pursuant to Mass. R. Civ. P. 58, by and between Plaintiff-in-counterclaim Endicott South Development Corporation ("Endicott") and Defendants-in-counterclaim, Jan Steenbrugge, AM Project Norwood LLC, Ad Meliora Construction LLC, AM Building Supply LLC and JS Management LLC ("Counterclaim Defendants"), this Court hereby enteres judgment in favor of Endicott in the principle amount of $500,000.00, jointly and severally against Counterclaim Defendants. SO ORDERED. Entered on docket pursuant to Mass R Civ P 58(a) And notice sent to parties pursuant to Mass R Civ P 77(d)

Judgment by Agreement. It is ORDERED and ADJUDGED:: Judgment enter in favor of Plaintiff-in-Counterclaim, Endicott South Development Corporation on all counts jointly and severally against Defendants-in-Counterclaim, Jan Steenbrugge, AM Project Norwood LLC, Ad Meliora Construction LLC, AM Building Supply LLC and JS Management LLC in the principle amount of $500,000.00. Entered on docket pursuant to Mass R Civ P 58(a) And notice sent to parties pursuant to Mass R Civ P 77(d)

Opposition to Motion to Withdraw as Counsel filed by Bernkopf Goodman LLP

Proposed Filings/Orders Proposed Order of Judgment

Defendant in a Counterclaim AM Project Norwood LLC, Ad Meloria Construction LLC, AM Building Supply LLC, Jan Steenbrugge's EMERGENCY Motion for leave to allow Fox Rothschild LLP to Withdraw as Counsel and for a Short Order of Notice (Counsel's Motion)

Opposition to Endicott South Development Corporation's Motion for Preliminary Injunction and Prejudgment Attachment filed by AM Project Norwood LLC

Defendant Bernkopf Goodman LLP's Request for Hearing

Affidavit of Thomas T. Reith, Esq.

Notice Of Filing

Endicott South Development Corporation's Memorandum in support of Motion for Preliminary Injunction and Prejudgment Attachment

Agreement for Judgment: Applies To: AM Project Norwood LLC (Plaintiff); JS Management LLC (Defendant); Ad Meloria Construction LLC (Defendant); AM Building Supply LLC (Defendant); Steenbrugge, Jan (Defendant)

Affidavit of Compliance With Superior court Rule 9C

Defendant Endicott South Development Corporation's Motion for Preliminary Injunction and Prejudgment Attachment

Affidavit of Compliance With Superior court Rule 9A

ORDER: Decision And Order On Bernkopf Goodman LLp's Motion To Preclude, Or In The Alternative To Compel Evidence At Trial Regarding Damages see paper #125 dated (3/29/24)

Reply/Sur-reply Opposition To Its Motion to Preclude (Or In The Alternative, To Compel) Evidence At Trial Regarding Damages

AM Project Norwood LLC, JS Management LLC, Ad Meloria Construction LLC, AM Building Supply LLC, Jan Steenbrugge, Endicott South Development Corporation, Peter True, Bernkopf Goodman LLP's Memorandum Joint Pretrial Memorandum

Opposition to Motion to Preclude (Or In The Alternative, To Compel) Evidence At Trial Regarding Damages filed by Endicott South Development Corporation

EW Development LLC's Memorandum in support of Motion to Preclude (Or In The Alternative, To Compel) Evidence At Trial Regarding Damages

Conference Memorandum Rule 16 Litigation Control Conference Agenda Applies To: AM Project Norwood LLC (Plaintiff); Endicott South Development Corporation (Defendant); JS Management LLC (Defendant); Ad Meloria Construction LLC (Defendant); AM Building Supply LLC (Defendant); Steenbrugge, Jan (Defendant); Bernkopf Goodman LLP (Defendant); True, Peter (Defendant)

Reply/Sur-reply Endicott South Development Corporation's Reply in Further Support of Motion for Preliminary Injunction and Prejudgment Attachment

Endorsement on Motion for Status Conference (#108.0): ALLOWED Allowed. A Rule 16 Conf. is scheduled for 3/16/23 via zoom @ 2pm. Zoom credentials to follow. (2/22/23) (Notice sent 2/24/23)

Attorney appearance electronically filed.

Affidavit of Jack I. Siegal

Defendant EW Development LLC's Motion to Preclude (Or In The Alternative, To Compel) Evidence At Trial Regarding Damages

Superior Court Rule 9A Notice of Filing

Plaintiff, Defendant AM Project Norwood LLC, Endicott South Development Corporation, EW Development LLC, JS Management LLC, Ad Meloria Construction LLC, AM Building Supply LLC, Jan Steenbrugge, Bernkopf Goodman LLP, Peter True's Joint Motion for Status Conference

Exhibits/Appendix

Endorsement on Motion for Separate and Final Judgement (#104.0): No Action Taken 08/08/2022 Decided (See Pg #107 for full decision and order) (Ricciuti, J.)

Defendant Bernkopf Goodman LLP's Statement of material facts, and Endicott's responses

Reply/Sur-reply in support of motion for summary judgment Applies To: Bernkopf Goodman LLP (Defendant)

Opposition to Bernkoff's motion for summary judgment filed by Endicott South Development Corporation

Bernkopf Goodman LLP's Memorandum in support of motion for summary judgment

Defendant Bernkopf Goodman LLP's Motion for summary judgment (w/opposition and reply).

Affidavit AFFIDAVIT OF JACK I. SIEGAL CERTIFYING COMPLIANCE WITH SUPERIOR COURT RULE 9A

Affidavit Affidavit of Jack I. Siegal

Response to AND LIMITED OPPOSITION TO AM PROJECT'S MOTION FOR LEAVE TO FILE OPPOSITION WITH CITATION TO STATEMENT OF FACTS OR, ALTERNATIVELY, FOR LEAVE TO FILE A CORRECTED OPPOSITION MEMORANDUM filed by Endicott South Development Corporation, Peter True

Plaintiff AM Project Norwood LLC's Certificate of SERVICE AND NOTICE OF FILING PURSUANT TO SUPERIOR COURT RULE 9A

Plaintiff AM Project Norwood LLC's Submission of LIST OF DOCUMENTS

Plaintiff AM Project Norwood LLC's Motion for LEAVE TO FILE OPPOSITION WITH CITATION TO STATEMENT OF FACTS OR, ALTERNATIVELY, FOR LEAVE TO FILE A CORRECTED OPPOSITION MEMORANDUM

Exhibits/Appendix Index to Joint Appendix; with Joint Appendix Exhibits 1-A-Z; AA-EE

Endorsement on Motion to Allow Counterclaim Defendants to File a (Corrected) Answer to Endicott South Development Corps.' Amended Complaint (#23.0): ALLOWED (dated 5/9/18) notice sent 5/10/18 Judge: Salinger, Hon. Kenneth W

Received from Defendant True, Peter: Answer to amended complaint; (entered 9/17/18)

MEMORANDUM & ORDER: on AM Project Norwood LLC's motion for partial Summary Judgment & Denied Notice Sent 8/24/18 Judge: Sanders, Hon. Janet L Judge: Sanders, Hon. Janet L Judge: Sanders, Hon. Janet L

Plaintiff AM Project Norwood LLC's Notice of WITHDRAWL AS COUNSEL FOR PLFF AM PROJECT NORWOOD LLC AND COUNTERCLAIM DEFTS