Former Cohasset town manager Mike Coughlin is in the process of preparing to depose the persons mentioned in the lawsuit and others. See document requests below.
On March 14th, 2013 Coughlin filed a Civil Action NO. 12-01944 in Norfolk Superior Court asking the Town for the production of Documents to the Board of Selectmen Peter DeCaprio and the Board of Selectmen. Harold L. Lichten of Lichten & Liss-Riordan, P.C. is representing Coughlin.
On December 5, 2012 we reported in our blog (http://www.tinytownunleashed.com/tinytowns/couhglin-files-whistleblower-against-cohasset-decaprio/) that Coughlin had filed a whistleblower suite against the Town of Cohasset and Peter DeCaprio, chairman of the town’s water commission. In his suit he said he wanted his job back.
Coughlin named the Town of Cohasset, Board of Selectmen at the time he served (Ted Carr, Paul Calrson, Diane Kennedy, Fred Koed and Leland Jenkins and Peter DeCaprio, both individually and in his capacity as a water commissioner. Click on the address in paragraph two to read the complete Whistleblower suit on Tinytown Unleashed.
Document Requests /Town of Cohasset
Request No. 1: All e-mails between Plaintiff Coughlin and Ted Carr on town computers and/or servers.
Request No. 2: All documents, e-mails, and notes relating or referring to Peter DeCaprio.
Request No. 3: All documents, e-mails, and notes maintained by Plaintiff Coughlin, Mark Brennan, Peter DeCaprio, Ted Carr, or any other member of the Board of Selectmen which relate or refer to the subject matter of this lawsuit including but not limited to, documents and e-mails relating to the contract between the Town of Cohasset and American Water, the request for proposals relating to the water operations of the Town including any documents between the Town and Aquarian responding to such requests for proposals.
Request No. 4: All documents relating to the performance of Plaintiff Coughlin.
Request No. 5: All documents relating to the decision to terminate Coughlin, suspend him, and all documents raising concerns about Coughlin including e-mails between members of the Board of Selectmen, and/or Board of Water Commissioners.
Request No. 6: All documents and e-mails between any members of the Board of Selectmen and anyone else including Peter DeCaprio or Mr. Coughlin, relating to the controversy relating to the request for proposals for a new vendor to run the water operations of the Town of Cohasset and any concerns relating to Mr. Coughlin’s involvement in that.
Request No. 7: All documents, e-mails, and notes between Mark Brennan, former director of the Department of Public Works, and Peter DeCaprio, members of the Board of Selectmen, or Mr. Coughlin, relating to water and/or water and sewer operations.
Request No. 8: All minutes of the Board of Selectmen, notices of or minutes of executive sessions which relate or refer to Mr. Coughlin, his suspension, termination, or separation from employment, and/or issues relating to the controversy between him and Mr. DeCaprio and/or requests for proposals in any other matters relating to obtaining vendors to operate the water and water and sewer operations of Cohasset.
Request No. 9: All documents maintained by the Water and Sewer Commission, the Town of Cohasset, and anyone else working for the Town of Cohasset which relate to legal work performed by Jay Talerman, or the law firm of Blatman, Bobrowski and Mead (hereinafter, “BB&M”) relating to legal services performed by such entities for the Board of Water Commissioners, or the Cohasset Water Company, or any other town entity.
Request No. 10: All documents relating to any investigations, inquiries, or documents relating to whether Peter DeCaprio utilized BB&M and/or Jay Talerman to perform personal legal services for him during any period of time in which Talerman and BB&M were associated with providing legal representation to the water company operations of the Town of Cohasset or the Board of Water Commissioners.
Request No. 11: All documents, notes, and e-mails relating to the decision or consideration of suspending or terminating Michael Coughlin from his position as Town Manager.
Request No. 12: All disclosures made by Peter DeCaprio to the Town, the water company, the Board of Water Commissioners, or the Selectmen relating to his relationship with Jay Talerman, BB&M, Aquarian Company, Macquarie Bank, Core Point Partners and American Water Company.
Document Requests / Peter DeCaprio
Request No. 1: All e-mails and other documents in your possession which relate to Plaintiff Coughlin.
Request No. 2: All notes, documents, e-mail and other materials between you, any member of the Board of Selectmen of the Town of Cohasset and any employee or manager of the Town of Cohasset, including any member of the Board of Water Commissioners that relate or refer to Plaintiff Coughlin.
Request No. 3: All documents, e-mails (appropriately redacted), which reflect work performed by Jay Talerman, or the law firm of Blatman, Bobrowski and Mead (hereinafter, “BB&M”) for Peter DeCaprio personally or any private business entities associated with DeCaprio during the years 2011 and 2012.
Request No. 4: All documents between or which refer or relate to or demonstrate any relationship between Defendant DeCaprio and Crow Point Partners, Macquarie Company, and Aquarian Company including any investments therein; any investments between Macquarie and Crow Point Partners and any documents, e-mail or notes which relate or refer to Crow Point Partners and Peter DeCaprio and/or Peter DeCaprio and Aquarian or Macquarie Bank.
Request No. 5: All e-mails whether on a private e-mail account or public e-mail account by DeCaprio or to DeCaprio which relate to Coughlin.
Request No. 6: All documents which relate to any executive sessions, discussions, or consideration by the Board of Selectmen regarding any proposals or requests made by DeCaprio relating to RFP’s for the Cohasset Water Company for 2011 and 2012.
Request No. 7: Any e-mails between DeCaprio and any member of the Board of Selectmen relating to Coughlin, whether on private or public e-mails.
Request No. 8: All documents, notes, e-mails, etc. between DeCaprio and Aquarian Company or American Water Company during the years 2010 – 2012.
Request No. 9: All documents, drafts and other materials which relate or refer to a request for proposal being put out by the Cohasset Water Company for bids to undertake providing water service for the Cohasset Water Company.
Request No. 10: All documents which reflect or relate to any concerns regarding the performance of Town Manager Coughlin in the possession of DeCaprio.
Request No. 11: All legal memorandum or opinion letters received by the Cohasset Water Commissioners or the Cohasset Water Company which relate or refer to the legal representation of the Cohasset Water Company, or which relate to the authority or ability to the Town Manager to have involvement in decisions relating to Cohasset Water Company.
Request No. 12: All phone records, whether cell phone, private phone, or water company phone for the months November of 2011 through March of 2012 which relate to any phone calls made by DeCaprio or anyone working on his behalf between DeCaprio and a member of the Board of Water Commissioners, a member of the Board of Selectmen, Aquarian Company or Macquarie Bank.
Expanded document request:
Former town manager Mike Coughlin e-mailed Tinytown Unleashed on the Ides of March 2013 saying that he has expanded his request for documents. Cohasset Capital Budget members Steve Gaumer and Jack Kenilley have been added to the list. Kenilley is also a member of the governance structure committee. Coughlin had previously requested documents from Capital budget member Peter DeCaprio, who also is a water commissioner.
Also, George Chamillard, a member the Cohasset Advisory committee, Peter Pescatore, chairman of the Cohasset Advisory committee, acting town manager Mike Milanoski and Lenora Jenkins, a member of the Cohasset Water commission, along with her husband, Selectman Leland Jenkins (Leland was previously reported.
Selectman Leland Jenkins and Steve Gaumer have both filed papers to run for selectman this year. There are two seats up. Russ Bonetti, chairman of the Cohasset Preservation Commission has taken out papers but has not yet filed. Coughlin has made no request for documents for Bonetti.
Q. Will Coughlin have to pay $80 an hour for the town to research this information?
A. No – the Town must produce the information at no charge to the plaintif
© Copyright 2013 Tanna K, All rights Reserved. Written For: Tinytown Unleashed