Settlement Agreement and Release

This is the settlement agreement for the Superior Court case, where the Feoffees agree to sell Little Neck to the tenants for $29.1 million if they can get approval from the Probate Court to break William Paine’s will.  The Feoffees also get immunity from the claims of the tenants.  The Feoffees signed the agreement without consulting the School Committee, and it requires them to pursue the litigation in Probate Court even if the School Committee opposes it.  It also meant that the tenants no longer had any skin in the game; all the legal fees to achieve the goals of the tenants and the Feoffees would be paid by the schoolchildren of Ipswich.

Superior – Feoffees – 091223 – Settlement Agreement Part 1

Superior – Feoffees – 091223 – Settlement Agreement Part 2

Superior – Feoffees – 091223 – Settlement Agreement Part 3

Part of this filing shows the prices each tenant will pay for their unit  (lot + common area privileges).  You can find an analysis of these prices compared to appraised values here.

Superior – Feoffees – 091223 – Ex. G Price List by Unit

Tenant’s Opposition to Foley Motion for Protective Order and Foley Deposition

Here the Tenants argue that they should be allowed to pursue discovery on James Foley’s file at the Wenham Police Department.  Also included is the full text of the deposition of James Foley.  This motion ends up being denied, meaning they are not allowed to pursue discovery.

Superior – LNLAC – 080527 – Opposition to Foley Motion for Protective Order

Superior – LNLAC – 080527 – Foley Deposition

Feoffees Opposition to Motion for Reconsideration

When the Court allowed the AG’s motion to dismiss counterclaim, it went further into a discussion of whether the Feoffees are a public entity or not.  The AG did not think this was appropriate, and so filed this motion for reconsideration.  The Feoffees, on the other hand, loved it because it supported their argument that they are a private entity.  So they filed this opposition to the AG’s motion.

Superior – Feoffees – 080115 – Opposition to Motion for Reconsideration


Decision on Motion to Dismiss Counterclaims

This is the decision the Feoffees rely on to support their claim that they are a private trust not subject to the Open Meeting Law.  The Attorney General felt that this decision went too far, and filed a motion for reconsideration, but never followed through on it.

Superior – Court – 071218 – Decision on Motion to Dismiss Counterclaims