COMMONWEALTH OF MASSACHUSETTS

SUFFOLK. SS SUPERIOR COURT DEPARTMENT

OF THE TRIAL COURT
CIVILACTION NO.

REGAN COMMUNICATIONS I

GROUP.INC., I

PLAINTIFF I

VS. I COMPLAINT
I

HERITAGE MUSEUMS & GARDENS, I

DEFENDANT I

and I

JUDITH K. GOETZ. I

DEFENDANT I

PARTIES

1. The Plaintiff, Regan Communications Group, Inc. (hereafter alternatively referred to as

"RCGI" or "Plaintiff') is a Massachusetts corporation, duly organized by law and having a usual

place of business in Boston, Suffolk County, Massachusetts.

2. The Defendant, Heritage Museums & Gardens, (hereafter alternatively referred to as

"HEzuTAGE" or "Defendant") is a private, not-for-proflt, tax-exempt organization located in

Sandwich, Barnstable County, Massachusetts.

3. The Defendant, Judith K. Goetz, (hereafter alternatively "GOYIZ" or "Defendant") is an

individual residing in East Sandrvich, Barnstable County, Massachusetts.

 FACTS COMMON TO ALL COUNTS

4. On or about January 1'7,2013, for the mutual promises contained therein, and other valuable

consideration, RCGI and GOETZ entered into an Agreement (the "AGREEMENT"), a copy of

rvhich is attached marked EXHIBIT "A".

5. Pursuant to the AGREEMENT, GOETZbegan her employment with RCGI in January, 2013

and continued her employment lvith RCGI until October,2OL7.

6. In the course of her employment with RCGI, GOETZ worked in the capacity of marketing

and public relations on behalf of many of RCGI'S clients.

7. HEzuTAGE was a client of RCGI during the period from January l,2016 through

December 31,2016.

8. During the course of her employment by RCGI and while HERITAGE was a client of RCGI,

one of the accounts on rvhich GOETZ worked was that of HERITAGE.

9. In August, 2017, as part of an attempt by RCGI to do business rvith HERITAGE, GOETZ

prepared a proposal for an Indy 500 exhibit to be held at HERITAGE. The proposal was

submitted to HERITAGE on or about August 3O,2O17.

10. Paragraph 4 of the AGREEMENT, (titled "NON COMPETE") states, in part,

"... It is thereforeunderstood and agreed that throughout the term

of Employee's employment rvith Regan and fbr a period of trvo (2) years
after the date of termination of employment for ll,hatel'er reason, Employee
shall not, directll,or indirectly, in any capacity u'hatsoever, rvhether
individuall),of for a company, or a partnership, or for any entity and in any
form rvhatsoe\/er contact, solicit or perform services for any account or
client with rvhich Regan did business or was attempting to do business with
during the trvelve ( l2)months prior to the date of termination of
employment of Employee... "

11. GOETZ commenced employment with HERITAGE in October,20l"7. GOETZ'S title with

HERITAGE is "Director of Marketing and Public Relations".

12. The date on rvhich GOETZ commenced employment with HERITAGE was within the two

(2) year period after the date of termination of her employment rvith RCGI.

13. The date on which RCGI submitted the proposal in an attempt to do business with

HERITAGE was rvithin the twelve (12) month period prior to the date of termination of

GOETZ'S employment with RCGI,

COUNT I

L4. The Plaintiff restates the allegations of Paragraphs 1 through 13 as if more fully set

forth herein.

15. The performance of services by GOEIZ for HERITAGE within trvo (2) years after

GOETZ'S termination of employment with RCGI, constitutes a breach of the AGREEMENT.

16. Upon discovery of the fact that GOETZ rvas performing services for HEzuTAGE, RCGI

sent to Ellen Spear (hereafter alternatively "SPEAR"), President and CEO of HERITAGE, a

copy of the non-compete clause and, at SPEAR'S request, a complete copy of the

AGREEMENT.

17. Neither GOETZ nor HERITAGE have responded since RCGI provided a copy of the

AGREEMENT to HEzuTAGE, and GOEIZ continues to perform services for and to be

employed by HERITAGE.

18. Paragraph 6 of the AGREEMENT, (titled "REMEDIES") states, in part,

"... Accordingly, Regan, in addition to any other remedy to lvhich it

may be entitled, shall be entitled to an injunction or injunctions to
prevent breaches of the provisions of this Agreement and to compel
specific performance of the provisions thereof... "

19. RCGI has no plain, complete or adequate remedy at larv for the continued breach of the

AGREEMENT consisting of GOETZ'S performing services for HERITAGE, and RCGI is

irreparably harmed thereby.

WHEREFORE, Plaintiff respectfully requests that this Honorable Court

1. enter judgment that the Defendant, Judith K. Goetz, has breached the Agreement with Regan

Communications Group, Inc. by the continued provision of services for the Defendant, Heritage

Museums & Gardens;

2. enter judgment that the Defendant, Judith K. Goetz, has breached the Agreement with Regan

Communications Group, Inc. by continuing her employment by the Defendant, Heritage

Museums & Gardens;

3. enter a Preliminary Injunction enjoining the Defendant, Judith K. Goetz, from providing

services for the Defendant, Heritage Museums & Gardens, in any capacity pending the outcome

of this case and until October, 2019, or such other date as this Court deems just;

4. enter a Preliminary Injunction enjoining the Defendant, Judith K. Goetz, from being

employed by the Defendant, Heritage Museums & Gardens, in any capacity pending the outcome

of this case and until October,2OI9, or such other date as this Court deems just;

5. enter a Preliminary Injunction enjoining the Defendant, Heritage Museums & Gardens,

from accepting services provided by the Defendant, Judith K. Goetz, in any capacity pending the

outcome of this case and until October,2Ol9, or such other date as this Court deems just;

6. enter a Preliminary Injunction enjoining the Defendant, Heritage Museums & Gardens,

from employing the Defendant, Judith K. Goetz, in any capacity pending the outcome of this

case and until October,2Ol9, or such other date as this Court deems just;

7. grant such other and further relief as this Court deems just.
 COUNT II

20. The Plaintiff restates the allegations of Paragraphs 1 through 19 as if more fully set

forth herein.

?1. On or about August 11,20I'7, SPEAR sent an email to RCGI, copy of rvhich is attached as

EXHIBIT "B". That email states, in part,

"... Manv thanks for lunch toda1,. I look fonvard to a proposal

about u,hat ,l ou might do for us lbr the Ind_v erhibit. . . "

22. RCGI submitted its proposal to HERITAGE on or about Au-qust 3 I,2OI7 .

23. On or about 9lI3|2OT7, SPEAR sent an email to RCGI, copy of rvhich is attached

as EXHIBIT "C". That email states, in part,

"... Please let George [Regan, President of RCGI] knorv $,e won't
be considering anl,additional help until our 2018 budget process u,hich
starts in Nor.'ember. At the moment it looks doubtful u,e'll have the
room lor outside help, much as we'd like it..."

?4. As referred to in Paragraph 5 herein, GOETZ continued her employment rvith RCGI until

October, 2Ol7 . As referred to in Paragraph 11 herein, GOEfZ commenced employment rvith

HEzuTAGE in October, 2Ol'7 .

25. Based on the facts herein, RCGI believes and therefore alleges that HERITAGE obtained

RCGI's proposal under the false pretense that RCGI actually had a legitimate chance of entering

into a mutually beneficial contractual relationship with HERITAGE b,v w,hich RCGI rvould

provide services of the nature of public relations for HERITAGE. RCGI believes and therefore

alleges that HERITAGE never intended to give RCGI a legitimate chance that its proposal u,ould

be considered, let alone accepted.

26. In fact, had RCGI not been rnisled into believing that it had a legitimate chance that its

proposal would be accepted, RCGI rvould not have spent the time and resources necessary to

produce the same on HERITAGE'S behalf.

27. RCGI has suffered a loss of the monetar)' compensation it would have -eained had

HERITAGE accepted RCGI's proposal. At the same time, HEzuTAGE has had the beneflt of

receiving the proposal and, instead of hirin-e RCGI for the public relations, applying w'hat

HEzuTAGE rvould have paid to RCGI to the hiring of, RCGI's employee, GOVTZ.

WHEREFORE, Plaintiff respectfully requests judgment against the Defendant,

under Count II in the amount of $36,000.00, the value of the proposal, or such other value as

this Court shall deem reasonable, together with interest from the date of the breach, plus costs.

COUNT iII
28. The Plaintiff restates the allegations of Paragraphs i through 27 as if more fully set

forth herein.

29. The acts of HERITAGE, collectively, were unfair and deceptive, and HERITAGE acted in

bad faith, as a result of which RCGI has expended time and resources necessary to develop the

proposal, has lost an oppoftunity to enter into a beneficial contractual relationship with

HERITAGE, and has lost an employee, as a result of which RCGI has suffered loss of income

and other damages.

30. The acts of HERITAGE, collectively, were intentional. As a result, HERITAGE has

violated the provisions of M.G.L. c. 93A, s. 11, thus entitling RCGI with additional damages

plus its reasonable attorney's fees.

WHEREFORE, Plaintiff respectfulll, requests judgment against the Defendant,

under Count III in the amount of $36,000.00, the value of the proposal, or such other value as

this Court shall deem reasonable, and that said amount be increased in accordance with the

provisions of M.G.L c. 93A, s. 11, together rvith interest from the date of the breach, plus costs,

including Plaintiff 's reasonable attorney's fees.

Respectttrlll' submitted,

Regan Communications Group, Inc.,

Robelt Bernheimer,
27 Barnstable Road
Neg'ton, MA 02465
Tel.: (339) 222-8899
Email: rbernhermer@ aol.com
BBO# 040900

Dated: February 28,2018

7
 A(;REIi}IT'N'T

Aclttiil\18\ I' marlc as ol'thc l7th ila1, oi'Jirnuarl 2{i13. b-v anci betu'ccrr .lrrriith
K. (ioetz (hcreinalier the "l:mployce') ancl l{egarr Contntunicatiotts (iroup. I:ic. it
l,lassachusctts corporatiorr n'ith a princilric placc ol'busittess located at 1 06 [ lnion Wl:arl.
lloston. Mz\ 02109 (hererinafter rcfemed to as "i{egan"). inc:iuding its irrescnt and {'uttrrc
suirsidiarics. assigns antl alllliates. lf Rcsart shall be nicrgeC rvith. or corsolidated into
aul other corpr)ratir)r1. or in thc cvent tirat it shali sell and transf'er suhstantialll" all ol'its
ilssels to anothcr ctrrporatiou or entitl'. the tcrms ol'this Agrr:ernent sitail inurc io the
bcnefit o1. anci bc assumed b1' the corporation or cntitl' resulting lrom such lllcrger or
coilsolidation^ or to uhicii the compan)"s assets should he trititsicrrgd.

in consideration ol ths mutual covenants sr:ntained hercirt. and lbr good and
valuable consideration. thc sufticicncl, of rvhich is hereby ackttou'ledgcd. thc partics
hcreto havc agrccd aud dtr agree as lblleirvs:
-l
I
1. I:',\ { f l. ( ) }',\ I }i *
Ilcgan hereb,v cr:rplo1,s I:mplo3'ee and llmplol'cc agrccs ro pcrt'ornt services in thc
iicld o1'puirlic rclatious. limployee reprcsents and'rvarranls thar F.mplovee is licc
ro eutcr iuto ttris :\grecmcnt arrd tlrr-, Irmplo,vcc is no1 sub.icci to any' restrictive
covenallt or other coutractual agrcetnuni. or ohligation that rcstricts Ilntploycc's
ability to clltcr into this agrecnlenl. ilnd perfbmr scrviccs tbr Regan. l:urpkrl'cc
shallrvork exclusivcil' 1'or l{cgari arrd clcvole all of l:mployue's business timc.
attcntion. skili arrtl cilorts cxclusivcll" to the business and allairs ol l{cgan.
Iimployce ma).not cngage in arn'oulsi(le protbssior:al activitl'rvithout thc
cxflrdss. rvrittcri coilsont of Regan. I:nrpkrl'ce shall ai all time comply *ith all
tu'rns and condilions trf thc I{e gan Staff l-landb<rok. a copy of rvlrich is availatrle
on the Rcgan courputcr s.vstem. lt is agrecd and unclcrstood the limplol'ee is an
enrlrloy'ec-at-u'i ii.

i
2. {l ( )N I; I t) llNT I L I x* l; O R t\f.47' I ( ) *'.
l.,,ruployee rccognizes ihat tiue to trmployce's elnployn'rent by Reg:ur and thc
uaiurc r''lthc scrvices to bc providcd hcrcun<lcr- lrrnplol,cc u'ill have acccss to and
rvill acquirc. artd tna_v- assist in clevclrping. Conlidcirtial Intbrnraiion. Employee
acknou'ledges that tlrc (lonllden{ial infirrmation has trcen ernd u'ill conlinlre to bc
oi'critical importancc Lo thc operations of i{cgan anci its business. Accordingl,v.
except as othcnvise requitcd by laivlul proccss. l:urployee shall keep couildeutial
an1' and all Conlidcntial Inlbrmation that is norv knorvn or that nra1,' helealier
beconre ktiorr'n hv Lniplol'ce" rvhcthcr or not leamcd during the perlbrmancc rrJ'
this Agrcemenl. and r"-ill usc Confidcntial Inlormation onll, in lhc coursc ol
F)mploycc's authorizcd duties on hehalf ol'Regan. ancl not. directl; ol indircctl3'.
at an)' tirne (cluring or aller IimpL)_yr:c's crnplol"rncnt rlith ltcgan) fbr I'inrpl<-ryce's
pcrsoual henefit. tbr the benclit r:f ani'other person or cntity. or in an'r' rnanner
adversc to ti:e irttcrcsts rlf ilegan. Firnploycc agrces t() take all rcasonablc actions

(. ,.n rrl i | t,t

f,\
 ncccssar) t() p)pe1g.1 thE L'onlidcntial InfOrniation in I'inrplolcc's possession or
control tiom bcing disclosed to ant individual. comparl\' or entitv othcr than those
authorizr.'d by'Rcgan, I:mplolcc shall intmcdiatcll inlirrnt Rcgatt upon becttntirtg
A\\ilrc olanl lcgai proccss rcque'sting Conl'idcntial Inlirnnation. and agrees 1c)
cr)opcratc rrith l{cgan in respondirlg to an}' such rcqucs1. I lpon t]'lc tcrminalion of
cmplo),mr-r1t riith l{cgan.Iimpltllr'c. or Lmplorec's ht'irs or legal rcpresentatir,es.
shali rc'turn to Rcgan all ('onlldc'ntial Inli-rrmation ernbodi.'d in a tangiblc fbrm.
atl)-sxccrpts o1'such Coutidential Inli''rn:ation and an1-othcr rvrititrg containing
an1'Contidcntiai Intbnnation or arrl anallses ()r stud\ including such Conlidc'ntial
Inl'orrnation. and l:mployce shali rctain no copics of such matcrial tbr arr reason
shatsocver. I:mplo1'ee's obligation to maintain the contidcntialitl' ol'thc
Contldcntial Inftrrmation shall sun,irr- the tcrmination or c.':piration ot'this
,\srcctttcttt. l;or ths purposcs ol'this Agrccrncnt. "Conlidcntial Iulbr:rnation" shail
r:rr--an all intonrration rclating to thc husiness arrd afi'airs of Rq:gan" including but
not lir:rited to clicnt lists. prospcctirc clicnt lists. rnarketing plans. operational
plans. Stafl'llandbooks. salary infomration and companr e-mails.

3. H;ORK PRODI (''t

Work product. including but not limited to. ali prcss plans and relcases. business
proptlsals. clicnt infirnlation. dcsigns. logos. cop1,' and othe.r nraterial. rvhether
u'rittcn. printcd tlr drawrt. n'hc'ther or not sub.it'ct to copvright. madr-' or dcvised
(indir idualll' or q ith otircrs). during l:mplol cc's cmpkx'mcnt shall remain the
sole and cxciusive propcrt), o1'Regan.

1.,\ ( ),\. (', ( ),1 I I' l:'l' 1..

l-.mplo;-ec is lamiliar. or *'ill bccomc t'amiliar ri itl'r thc busincss ol Regan- thc
ctlnrrncrcial and cornpctitivs traturc ol'this industry. and thc suhstantial
commilmcnt Regan tnakes in I:mployc'c. Iinrplovcu' tunher rccognizes that thc
ralue olRegan's busincss rvould bc injured il'Emplol,ec obtained emplol,'ment or
pcrlbrmed sc'rvices in a similar industrl' and attemptcd to corrtact. solicit or work
tt ith individuals rlr cntities u'ho u'erc clients or prospective clients of'Regan prior
to F.mpiol'cc"s dcpanurc'. It is theref<rrc undcrstoo<l and agrccd that throughout the
tr.'rnr ol'I:mplo1'cc's cmp1o1,'mc.nt r,''ith Rcgan ar:d t'or a pcriod ol'trvo (2) )'ears
altcr the datc o1'tcrmination ol'cmployment lor u,halerc.r rl'ason. Enrploy-ee shall
not. dirr'ctl! or indirectlr. in an5' capacity rvhatsoevcr- rvhcthcr individualh or lbr
a compan)'. or a partnership. ()r tbr an1,. entitl.' and in anl' ltrnn $'halsocver contact-
solicit or pc'rlirnu sen'ices ftrr an-v account or client rvith u,hich Regan did
husincss or \\'as altLxnpting to do business u'ith during the rwclvc ( ll) months
prior 1<; the date ol'tennination oletnplo),nrenl of Emplolec. 'fhe compcnsation
paid to I:mplolec h1' Regiu:r servL's as full and complctc consideration lbr this
covenant not to compete. Il'an1'provisions o1'this Agrcenrent arc deemcd
prohihited or unrcasonilble or in any,' respects unentbrccable bv a court.
s()\'crnnlerlt agenc\ or triburral in anr'.iurisdiction bl.reason ol-its duration of
tintc. gcographic area. rangc olactivities. or other issues. this agrcement shall be
modilicd and interpretcd to r-'xtr-'nd onll tbr thc maxinrum period oltime'.
eettgraphic area or range olactivitiss. or other issues as to \\,hich it mal be
 cnlbrceahle. r\s sc'r limited or rcstrictcd. thc covcnants containcd hcrc'in shall
rernain in lirll lirrce andc'llbct. In thccvcntthat an!'covenimt orcovcnants shall
bc uncnl'tlrceabic thc rcmaining covunal'rts sltall rcnraitr in lirll lbrcc and cftcct.
l.:n'rploy ce acknou ledges that thc restrictions sct oLrt in this Agreenlcnt arc
tlecL'ssar], to protect thc legitimate business intr'rcsts ol llcgan and arc ol'
signilicant vaiue to Rcgan. ivhich is tairll' rcflected irt l:tnpiolcc's ct;mpettsittittt.t.
I:,mpio1,ce turther acknorvlcdgcs ihat all of thc rcslrictions contained in this
scctir'ln arc reasonablc' in all respects. including duration. territrlry and scopc of
activity restrictcd. limplolec also acknowledges that the restrictions containcd in
this section u ill not prevent I:mplity'ee tiorn oblaining any. other emplovmL'nt- and
l:mploy'ce agrces that Emplol'cc will be ablc to carn an adcquatc lirelihood if this
rcstriction is cnforccd. Empioyee agrces that the existencc of an-r- claim or causc
trl'action by Ilmplolec against Regatt. u'hether predicated on this Agrcement or
othenvisc. shall not constitute a dct'cnse to thc entorccnlcnt by Regan of this
covcnant not to colnpctc.

.\ ( ),\ s( )L K', t'l .1 l' I ( ).\

'I'hroughout thc tcrnr of }:mplo1,ee's enrployment with Rcgan and firr a pcriod rll'
onc ( I ) l ear alicr the date of tcrmination lor an)' reason. I;mplo1'ec shall not
directll'or indircctll' solicit" enlice a\!av or interl'ere u'ith Regan's relationships
with anl' custonlcr. client. olficcr or employcc of thc Corrrpany. or attcmpt to
induce arrl' cr:rplolec ol'Regart to lcavc thc employ of Regan . or in anv way
interfcrc rvith the rclationship bet'vveen such enrploree and Ilegan . il'such
employcc is currcntlr ()r u'as at an)' time during the preccdinq onc ( I ) l'ear
emplo;*cd by' Itegan.

(r. RE}IEDIES
Fmplol'cc acknowlcdges that" in the cvent of anv bre-ach ol'this Agrecment by-
I:mplo1,cc. Regan '"rould be harmed ineparably iurd immediatcll' and could not he
rnadc rr'hole bv monctarl damagcs. Accordingly. Regan. in addition to an)'other
rcmedy to *'hich it may bc cntitled. shall be entitled to an injunction or
injunctions to prcvent brcachcs ol thc pror isions ol'this :\erccment and to compr'l
specilic perlbrmancc'olthe provisions hcrcol. Regan shnll not be required [o post
a bond or othcr sccuritr in connection u,ith anv action filr such relicl. T'hese
reniedics shall not be deemed to be exclusivc remedies tbr a violation of this
Agreement but shall he in addition t() all other rcmedies availahrle to Regan al la\\
or in equitl. Irmployee's agreerncnt as set li)rth in this .,\greeurent shall surrir-c.
terminat ion o t' l:rnpl o.vec' s emplo-vment with Regan.

t :.\" t' I R t-:c R E Ii I t t;.\' 7'

..1
'l'his
Agreemcnt constitutcs thc cntire agreement among thc parties hereto
penaining to the subject matter hereol'and supcrscdes all othcr prior and
contL'mporaneous agrccments. understandings. negotialions and discussions.
uhcthe'r oral or rvrittcn. of the partics. 'lhere are no other agrcemcnts bclrvcc-n the
panies itr connection rvith the subject mattcr hereol'except as specif icalll, set lorth
 Itcrein. 'l'his Agrr'clul'nt rna-\ only hc amcnded or mudiiir'd iu a u'riting signcd b1
the p-lat11 against rl'hour erntbrcernent o1'such amendment or modification is
sought. An1 of the tcrms or conditions of this Agrecmenl ma-v.. be u'aived at auv
time b.v" the party cntitled to the benelit thereol: but onll'b1'a rvriting signed b1,
the partl' rvaiving such terms or conditions. Ilegan's clcctiou not to insist on
compliance h1 I:mplovce nith an) particular provision ol'this Agreemcnt shali
nt'rt be dcemed a u'aiver olRegan's right to insist on compliance in the lirurc or to
r--ntirrce its rights hereundcr. 'l'his r\grec'ment shall be governe'd b,v and construed
in accordancc u'ith thc larvs of thc Commonrvealth ol'Massachusetls r.r,ithout
relbrcnce to choicc ollart principics thcrcot. ernd tl'rc parties agrce 1() submit to the
jurisdiction atrd vcnuc oi'the courts locatecl in rht Commonrvcalth ol'
Massachusetts. 'fhe parties tirrther agree that thc prevailing parti. in an1 litigation.
as determined b1' thc' trier of lact. shall havc ils costs and reusonable altorncvs'
l'ces paid b-"- thc' non-prevailing part].

8. .-l(' K.\' ( )Ll',l.l.,D(;,v li\T'

lrmployce. acknorvlcdgcs that [inrploy'ee has rcad this cntire Agreement
completeiy'and carc't'ull)'. that [:nrplolr't-'undcrstands this Agreemcnt and thar
l:ntplovee iras bcen advised to c<lnsult rvith counsei prior to entering into this
z\grcemcnt. L.mplol'cc acknorvlcdges that Lmploycc is signing this voluntarily' b1
EmploS'ee's oul l-ree act.

i\ $'l INI:SS \\'t-ll:l{i:Olj. this Acrecment is exccuted as ol'thc lirst date abovc u'rittcn.

Regan Cornmunications (iroup. Inc.

ilr: I)1 :

.ludith K. (ioetz

\\ iinc.s:
---Original Message---
From: Ellen Spear Imailto:espear@heritagemuseurns.orgJ
Sent: Friday, August Ll,2Al7 1:46 PM
To:'Ashley Boiardi (aboiardl@regancomm.com)' <aboiardi@regancomm.com>
Subject: Herita8e

HiAshley:
Could you pass on this message and document to George? Thanksl

George;

Many thanks for lunch today. I look fonrrard to a proposal about what you might do for us for the lndy exhibit. Attached, our
sponsorship piece. Feel free to distribute widely!

Best,
Ellen

Ellen Spear, President & CEO

Heritage Museums & Gardens
67 Grove St.
Sandu.rich, MA 02563
(508) 888-3300 x 143
espear@heritagemuseums.orgcmailto:espear@ heritagemuseums.o rg>
www.heritagemuseums.orgchttp://www.heritagemuseums.org/>

Something's blooming at Heritage

Ihmg_logo_emaili
----Original Message---
Froml Ellen Spear [mailto:espear@heritagemuseums.org]
Sent: Wednesday, September 13, 2017 9:33 AM
To: Ashley Boiardi <aboiardi@regancomm.com>
Subject; RE: Heritage

Ashley;
Please let George know we won't be considering any additional help til our 2018 budget process which starts in November. At
the moment it looks doubtful we'll have the room for outside help, much as we'd like it.
Best,
Ellen

f- ,' ,: i,, ,1
 COMMONWEALTH OF MASSACHUSETTS

SUFFOLK, SS SUPERIOR COURT DEPARTMENT

OF THE TRIAL COURT
CIVIL ACTION NO.

___________________________________
REGAN COMMUNICATIONS |
GROUP, INC., |
PLAINTIFF |
|
VS. |
|
HERITAGE MUSEUMS & GARDENS, |
DEFENDANT |
|
and |
|
JUDITH K. GOETZ, |
DEFENDANT |

MOTION FOR PRELIMINARY INJUNCTIONS

Now comes the Plaintiff and moves for the issuance of Preliminary Injunctions as

requested in its Complaint (page 4, requests for relief numbered 3 through 6).

All of the foregoing requests are based on the facts contained in the Plaintiff’s Complaint

and in the Affidavit of George Regan, both of which have been filed with the Court, and both of

which are incorporated herein by reference.

 Regan Communications Group, Inc.,

By its Attorney,

__________________________
Robert Bernheimer, Esq.
27 Barnstable Road
Newton, MA 02465
Tel.: (339) 222-8899
Fax: (617) 244-7718
BBO# 040900

Dated: February 28, 2018