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b. James E. Regan III <br /> 16 Brookside Circle <br /> Mashpee, MA 02649 <br /> C. Richard T. Guerrera <br /> 9 James Circle <br /> Mashpee, MA 02649 <br /> 3. The defendant, Fred Glass, is an individual who was the applicant <br /> for the permit before the Zoning Board of Appeals. Said defendants' residential address <br /> is: 121 Regatta Drive, Jupiter, FL 33477-4052. <br /> 11. FACTS <br /> 4. On or about August 23, 1999, upon information and belief, the <br /> Zoning Board of Appeals for the Town of Mashpee received a written request for a <br /> modification of a previously granted variance #V-99-24. <br /> 5. The defendant, Fred Glass, through his representatives, upon <br /> information and belief, sought permission to enlarge the size of the dwelling permitted <br /> pursuant to the Zoning Board of Appeals Variance#V-99-24, and engage in conduct <br /> otherwise not permitted by the zoning by-law in the absence of relief from the Zoning <br /> Board of Appeals by way of the variance from the zoning by-law. <br /> 6. The defendant, Mashpee Zoning Board of Appeals, failed, <br /> neglected, or refused to provide notice to the plaintiffs as required by law, or to hold a <br /> public hearing upon said request made by the defendant, Fred Glass. <br /> 7. On September 27, 1997, the defendant, Zoning Board of Appeals, <br /> filed with the Mashpee Town Clerk a "decision for modification of a variance", a true <br /> copy of which is attached hereto as Exhibit "A" and incorporated herein by reference. <br /> 2 <br />