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23D-107 COMPLAINT (2) Law Offices of JAMES E. BARNETT, JR. SEAN E. O'LEARY Attorneys at Law 184 Northampton Street Easthampton, MA 01027 April 25 , 1985 (413) 527-5710 R,g ZO VE Mr. Edward Tewhill1111 APR 2 9 Building Inspector1985 City of Northampton 6. 1 City Hall OWT IN� Northampton, MA 01060 RE: Pioneer Valley Nursing Home Dear Mr. Tewhill On behalf of Frederick and Nancy Hayden of 542 Elm Street , Northampton, abuttors of Pioneer Valley Nursing Home , I hereby make the following requests of you in your official capacity as building inspector for the City of Northampton in accordance with Massachusetts General Laws , Chapter 40A, Sec . 7 . 1) We believe that the intensity of use of the Nursing Home has increased dramatically without the Nursing Home home having first obtained a zoning permit in accordance with sec . 10 . 2 of the City of Northampton Zoning ordinance in that the number of employees has recently increased almost two-fold and a new head trauma unit has been recently established at the Nursing Home. 2) Said extension has also taken place without the benefit of a Special Permit as required in sec . 9.3 of the City' s Zoning ordinance. We call upon your office to immediately issue a cease and desist order and further require that the Nursing Home immediately apply for a Special and Zoning Permit . 3) The Pioneer Valley Nursing Home obtained. a Special Permit to construct another story on a portion of the existing building on April 20 , 1983 . No construction has commenced to date nor to our knowledge has as,building permit been issued . We call upon your office to notify the Pioneer Valley Nursing Home that this permit has lapsed in accordance with sec . 1046 of the Zoning ordinance . We further call upon your office to enforce the provisions of sec . Pale 2 April 25 , 1985 10 . 7 and sec . 10 . 8 of the Zoning ordinance in the event that the Pioneer Valley Nursing Home takes no action on your requests. We would expect to have your reply by May 14, 1985 in accordance with said. Section 7 . Very truly yours , ktiv • scan E . O'Leary AN 2 9 J11 Attorney for the Haydens . m$ t�C�P15PEC7 oNs 0��'33GJv, mA:.011160 SO/me CERTIFIED MAIL NO. •p620350581 wllimr",l Law Offices of SEAN E. O'LEARY _Z�":�.._._�-_;• t JAMES E. BARNETT JR. ASSOC. `f�"CNAMAV*1.4,--�` .s.P -'K 184 Northampton Street It7 APR26'85 z L.S.N�SiAGt '�:.� E_i .6 7 Easthampton, MA 01027 s p, �,� CLAIM CHECK NO. Mr . Edward Tewhill ❑HoLo Building Inspector DATE City of Northampton CERTIFIED City Hall Annex 1ST Northampton, MA 01060 P 620 350 581 2ND NOTIC MAIL RETURN 2 Detached from PS Form 3849-A Oct.1980