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2018 00078190
Bk: 50309 Pg: 56 Page: 1 of 1
Recorded: 09/19/2018 01 :14 PM
ATTEST: John R. Buckley, Jr. Regist<
Plymouth County Registry of Deeds
Notice of Actions Pursuant to Mass. Gen. L. ch. 40A, §7
324 Front St., Marion, Massachusetts, County of Plymouth

Notice is hereby given, pursuant to MGL ch. 40A, §7 of

(1) the action entitled "324 Front Street, JV, LLC, Plaintiff vs. Marc Leblanc, Elizabeth S. Dunn, Michelle
Smith, Katherine Mahoney, Tad Wollenhaupt, Domingo P. Alves, David Bramley, and Louise Nadler, as
they are members of the Zoning Board -of Appeals of the Town of Marion, Massachusetts, and Peter R.
Douglas, Defendants" filed on July 10, 2018 in Superior Court, Plymouth County, Commonwealth of
Massachusetts (Docket Civ. No. 1883CV00744) (the "Zoning Enforcement Constructive Approval Action")
relating to the property located at and known as 324 Front St., Marion, County of Plymouth, Massachusetts
02738-1528, referred to in Plymouth County Registry of Deeds Book 48022, Page 321, and any and all
structures located at or on such property (collectively, the "Property" or the "324 Front St. Property" and
(2) the action entitled "Peter R. Douglas, Plaintiff v. Marion Zoning Board of Appeals, and Marc Leblanc,
Elizabeth Dunn, Michelle Smith, Kathleen Mahoney, and Tad Wollenhaupt, as they are members of the
Zoning Board of Appeals, and 324 Front Street JV LLC and-324 Front Street Owner LLC, Defendants"
filed on August 13, 2018 in Superior Court, Plymouth County, Commonwealth of Massachusetts (Docket Civ. No.
1883CV00868) (the "Zoning Enforcement Determination Action" and, together with the Zoning Enforcement
Constructive Approval Action, the "Zoning Enforcement Actions") relating to the 324 Front St. Property referred
to above and in Plymouth County Registry of Deeds Book 48022, Page 321.

Pursuant to MGL ch. 40A, §7, this Notice of Actions also states that (i) the person initiating the Zoning
Enforcement Constructive Approval Action is 324 Front Street, JV, LLC and the Defendant therein asserting
claims againstthe Property and any owners thereof in such action is Peter R~ Douglas, residing at 326 Front
St., Marion, MA 02738 ("Peter R. Douglas"), (ii) the person initiating the Zoning Enforcement
Determination Action is said Peter R. Douglas, (iii) 324 Front Street Owner LLC is an owner of the 324 _
Front St. Property, (iv) the Zoning Enforcement Actions relate to the 324 Front St. Property and all
structures now or hereafter located at the Property, and (v) the violations of Massachusetts law and the
Zoning Bylaws-of the Town-of Marion at issue in-the Zoning Enforcement Actions -comprise (a)the violation
of Mass. Gen. L. ch. 40A and the Zoning Bylaws of the Town of Marion thereunder, including Town of
Marion Zoning Bylaws §§230-5.1, 5.2, 6.lD, 6.1 G, 11.1 and 11.2 and predecessor bylaws and (b) in the case
ofthe Zoning Enforcement Constructive ApprovalAction, violation by tlie Town of-M arion Zoning Board
of Appeals of Mass. Gen. L. ch. 40A §15.

This notice therefore constitutes official notice to all present and future parties in interest and successors in interest
to all or any portion of the 324 Front St. Property of the Zoning Enforcement Constructive Approval Action and
the Zoning Enforcement Determination-Action and the claims-now or at any time made in each of such Zoning
Enforcement Actions by said Peter R. Douglas against the 324 Front St. Property, any and all structures located at
or on such property, and any and all owners thereof and any and all successors in interest thereto, in any such case
now or at any tiine hereafter the filiilg hereof. fz-.-
IN WITNESS WHEREOF, the undersigne as set his ~d this !i_ day of September ;:i18:
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Peter R. Douglas g. @ [;
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Commonwealth of Massachusetts :::v
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The above-named Peter R. Douglas, personally known ti me:lo "5e tlfe p&ison
whose name is signed above, personally appeared and aclmo;wlegge&'bef.gre me the
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-~~RETURN TO:
foregoing instrument to be his free act and deed.
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Peter Douglas ~=~1~-:Q~~ 9 ~ ~ ~ ~
326 Front St. My Commission Expires:
Marfon, MA 02738