Lafayette v. S Burlington Police

7ermont Superior Court
Filed 05/27/25
Chittenden UUnit

VERMONT SUPERIOR COURT CIVIL DIVISION
Chittenden Unit Case No. 24-CV-03907
175 Main Street
Burlington VT 05401
802-863-3467
www.vermontjudiciary.org

Robert Lafayette v. South Burlington Police Department et al.!

DECISION ON DEFENDANTS' MOTIONS TO DISMISS
AND PLAINTIFF'S MOTION TO AMEND

Plaintiff Robert Lafayette brings this civil rights action against the City of South Burlington,
the City's police chief, three South Burlington police officers, South Burlington's school

superintendent Violet Nichols, and Chittenden County Deputy State's Attorney Alexandra Sturges. As
to the South Burlington defendants, he alleges claims of First Amendment retaliation pursuant to 42

U.S.C. § 1983, abuse of process, violation of the Vermont Constitution's Common Benefits Clause,
and negligent supervision. As to Deputy State's Attorney Sturges, he alleges claims of abuse of

process and malicious prosecution. The City and the four police defendants move to dismiss for failure
to state a claim. Deputy State's Attorney Sturges has filed her own motion, seeking the same relief.

While these motions were pending, Mr. Lafayette filed a motion to amend his complaint for the third
time. The court grants the motions to dismiss and denies the motion to amend.

I. MOTION TO DISMISS (City and Police Officers)
The court first addresses the City Defendants' motion to dismiss. In deciding a motion to
dismiss pursuant to Rule 12(b)(6), the court considers whether "it appears beyond doubt that there exist
no facts or circumstances that would entitle the plaintiff to relief." Davis v. American Legion, Dept. of

Vermont, 2014 VT 134, § 12 (quotation omitted). Motions to dismiss for failure to state a claim are
"disfavored." Bock v. Gold, 2008 VT 81, 1 4, 184 Vt. 575. "Nonetheless, where the plaintiff does not

allege a legally cognizable claim, dismissal is appropriate." Montague v. Hundred Acre Homestead,
LLC, 2019 VT 16, { 11, 209 Vt. 514.

'Mr. Lafayette originally sued the South Burlington Police Department as a defendant. While the court's electronic case
management system still names the Police Department in the caption for this case, Mr. Lafayette has since replaced the
Police Department with the City of South Burlington as a defendant.
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Alleged Facts
The following facts are alleged in the Amended Complaint, drawn from documents as to which
the court takes judicial notice, or taken from the affidavit of probable cause, which was specifically
referenced in the Complaint and submitted by Mr. Lafayette as Exhibit 1 along with his Amended
Complaint on January 3, 2025. See Kaplan v. Morgan Stanley & Co., 2009 VT 78, ¶ 10 n. 4, 186 Vt.
605 (mem.). The court makes no finding as to their accuracy at this stage of the proceedings. See
Montague, 2019 VT 16, ¶ 10. The court does not, however, accept as true “conclusory allegations or
legal conclusions masquerading as factual conclusions.” Vitale v. Bellows Falls Union High Sch., 2023
VT 15, ¶ 28, 217 Vt. 611 (quotation omitted). Nor does the court accept as true “facts” alleged in the
complaint that are blatantly contradicted by documentary evidence upon which the complaint relies.
According to Mr. Lafayette, his legal claims stem from several incidents of public advocacy he
engaged in with the South Burlington School District, including:
 a February 9, 2024 Title IX complaint he filed with the U.S. Education Department’s Office for
Civil Rights, alleging Title IX violations by the South Burlington School District;

 a February 21, 2024 South Burlington school board residency hearing regarding Mr.
Lafayette’s children, where he “challeng[ed] the district’s residency determinations and
advocat[ed] for the rights of his children”;

 a March 12, 2024 formal residency hearing resulting from Mr. Lafayette’s appeal of the
residency determinations for his children;

 multiple records requests made throughout 2024 seeking to “[s]hed light on the district’s
handling of residency and Title IX matters”;

 an August 4, 2024 second formal complaint with the Education Department’s Office for Civil
Rights, alleging additional violations by the South Burlington School District; and

 a September 11, 2024 report to the South Burlington Police Department about a June 26, 2024
incident during a varsity basketball practice at South Burlington High School where a coach
reportedly “yelled at” Mr. Lafayette’s son, “raised a fist in an intimidating manner, and made
comments referencing [Mr. Lafayette’s] legal actions.” Am. Compl., p.9.

Mr. Lafayette alleges that he requested an investigation and formal report about the basketball practice
incident, and that the officer documented the complaint but did not conduct any investigation or take
protective action. He alleges that the officer “falsely characterized Lafayette as a frequent complainant
against the school district, despite this being his first report.” Am. Compl., p.10.2 On September 18,

2 Because Mr. Lafayette does not consistently number the paragraphs in his Amended Complaint, the court cites to page

numbers instead.

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2024, South Burlington school superintendent Violet Nichols approached the Shelburne Police
Department to “pursue criminal charges” against Mr. Lafayette. Am. Compl., p.10. Shelburne Police
declined to pursue charges and instead advised Nichols to file a civil stalking order. The South
Burlington Police also advised her to seek a stalking order, which she did on September 19, 2024. This
court granted a temporary restraining order, and then held a contested hearing on the request:
At the hearing, plaintiff testified about defendant’s behavior.3 She stated
that she was concerned for her safety and that of her family. She testified that
since January 2024, defendant had been threatening and harassing her through
email and by telephone. She indicated that at a school board meeting in February
2024, defendant attended, was agitated, and threatened her physical safety by
stating that he hoped she got hit by a car. She stated that defendant emailed her
daily, sometimes multiple times a day, and called her office with such frequency
that staff were afraid to be at work. She explained that some emails were lengthy
and included profanities, threats, and intimidating language. She indicated that
defendant had filed numerous suits against her. She testified that defendant
obtained her personal cell phone number that is not publicly listed and in
September 2024 left a voicemail, indicating that because his family was suffering,
hers would too, and listing her family members by name. Plaintiff stated that she
had altered her daily patterns to protect herself and her family, and that the
harassment impacted her ability to do her job or live without fear. She explained
that she had a safety plan and did not communicate directly with defendant,
instead directing all communication through her attorney.

Defendant also testified. He stated that he had never spoken directly to
plaintiff or made any actionable threat. He argued that his communications were
legally protected because he was advocating for his children to a public official.
Defendant admitted that in frustration at the school board meeting he said that he
hoped plaintiff got hit by a bus. He argued that it was merely a frustrated
comment and not a threat. He stated that he did not intend to threaten plaintiff or
cause any physical harm.

The court found by a preponderance of the evidence that defendant
engaged in a pattern of threatening behavior and following plaintiff that amounted
to stalking based on the following findings. Defendant made threats against
plaintiff at the school board meeting in February 2024. Subsequently, defendant
contacted plaintiff consistently with a level of persistence that indicated animosity
when combined with the earlier threats of harm. Defendant located plaintiff’s
unlisted telephone number and used that number to make threatening statements,
including stating that if his son had to suffer then plaintiff and plaintiff's family
would suffer as well. The court found that defendant conducted himself in a way
that would make a reasonable person fear for their safety and to suffer emotional
distress and indeed plaintiff changed her behavior in response. The court ordered
defendant to stay 300 feet away from plaintiff and plaintiff’s children. The court

3 In this block quotation, “plaintiff” refers to Ms. Nicols and “defendant” refers to Mr. Lafayette.

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provided an exception allowing defendant to go to the school to drop off or pick
up his children and attend their athletic events.

Nichols v. Lafayette, No. 24-AP-288, 2025 WL 826911, at *1 (Vt. Mar. 14, 2025) (unpub. mem.). The
Vermont Supreme Court affirmed the stalking order. Id. at *3.
Later in September 2024, South Burlington Police prepared an affidavit of probable cause and
issued a citation for Mr. Lafayette. A judge found probable cause for the charges of misdemeanor
stalking and misdemeanor disturbing the peace by telephone. See State v. Lafayette, 24-CR-10001. A
different judge then denied Mr. Lafayette’s motion to reconsider the finding of probable cause. See id.
The criminal case remains pending. Mr. Lafayette alleges that the affidavit included false claims, “such
as the fabricated allegation that Lafayette threatened to use his car to harm others.” Am. Compl., p.11.
He also alleges that the affidavit “explicitly referenced” the “financial burden” of his lawsuits on the
South Burlington School District, and that this “demonstrate[es] that Defendants’ actions were driven
by retaliatory motives rather than legitimate law enforcement concerns.” Am. Compl., p.11–12.
Discussion
The City and the four police defendants move to dismiss on grounds of sovereign immunity,
qualified immunity, and failure to state a claim as to each claim asserted. The crux of all of Mr.
Lafayette’s claims is his allegation that South Burlington Police officers lied in the affidavit of
probable cause by “reclassif[ying] his constitutionally protected speech as criminal conduct.” Am.
Compl., p.11. This contention is directly belied by the affidavit itself, which Mr. Lafayette submitted
along with his amended complaint. The affidavit indeed references Mr. Lafayette’s history of filing
complaints and reports with public officials, making records requests, and participating in
administrative hearings with the South Burlington School District regarding his children’s residency
status. But it expressly did not “reclassify” this conduct as criminal conduct, nor did it otherwise
attempt to criminally charge him for First Amendment-protected activity. Instead, after laying out the
timeline of Mr. Lafayette’s interactions with the School District and public officials in painstaking
detail, the Affidavit explicitly recognized his ongoing complaints and litigation and concluded that his
conduct had “elevated” to the point of criminal conduct: “Lafayette and the South Burlington School
District appear to be heavily involved with ongoing complaints and other legal litigation related to
Lafayette and his children. However, the legal proceedings have elevated to the point of Lafayette
stalking Violet Nichols.” Aff. of Prob. Cause ¶ 27. The Affidavit even observes that, after the February
21, 2024 school board meeting (months before the officers found probable cause to arrest Mr.
Lafayette), “South Burlington Police reviewed the meeting, and determined at that time the comments

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of Lafayette did not rise to the level of a criminal offense.” Aff. of Prob. Cause ¶ 5. This directly
contradicts any contention that the police treated Mr. Lafayette’s constitutionally protected speech as
criminal conduct.
While Mr. Lafayette may have engaged in “protected advocacy,” Am. Compl., p.13, that
advocacy is plainly not what the officers charged him for. Rather, they charged him for his threatening
behavior. It is well established that “there is no First Amendment right to engage in true threats.”
Nichols v. Lafayette, No. 24-AP-288, 2025 WL 826911, at *2 (Vt. Mar. 14, 2025) (unpub. mem.)
(citing State v. Noll, 2018 VT 106, ¶ 22, 208 Vt. 474). As our Supreme Court has already concluded
with respect to the same conduct that was at issue in Mr. Lafayette’s stalking case:
Regardless of whether plaintiff is a public official, the First Amendment does not
entitle [Mr. Lafayette] to engage in threatening behavior. [Mr. Lafayette’s]
actions here went beyond expressing criticism or lawful advocacy; the court
found that defendant threatened plaintiff and her family and that in the context of
defendant’s other behavior, plaintiff reasonabl[y] feared for her safety. See Noll,
2018 VT 106, ¶¶ 37–39 (explaining that true threats include actions that would
objectively cause a reasonable person familiar with the context of the
communication to interpret it as a “threat of injury” (quotation omitted)). This
behavior is not protected speech, and therefore there was no First Amendment
violation.

Id. There is absolutely no indication—aside from Mr. Lafayette’s wholly conclusory allegations—that
the officers somehow “lied” by classifying his First Amendment-protected conduct as criminal.
Mr. Lafayette also alleges that the Affidavit makes a specific “false claim,” that is, “the
fabricated allegation that Lafayette threatened to use his car to harm others.” Am. Compl., p.11. He
references page 6 of the Affidavit, which in turn references Ms. Nichols’s report to police that
“Lafayette has threatened to run her and the school attorney, Mark McDermott, over and has made
gestures of hanging them with his earbuds.” Aff. of Prob. Cause ¶ 14. In his amended complaint, Mr.
Lafayette concedes saying, “sure . . . I hope you get hit by a bus too!” though he defends that comment
as “hyperbolic.” Am. Compl., p.11. A person familiar with the context could reasonably interpret Mr.
Lafayette’s comment as a threat to run over individuals with a car. See Noll, 2018 VT 106, ¶ 37 (We
evaluate whether speech rises to the level of a true threat objectively—that is, whether an ordinary,
reasonable person familiar with the context of the communication would interpret it as a threat of
injury.”) (quotations omitted) Courts do “not engage in a rigid adherence to the literal meaning of a
communication without regard to its reasonable connotations.” Id. ¶ 38; see also State v. Hinchliffe,
2009 VT 111, ¶ 27, 186 Vt. 487 (“Without context, some behaviors do not seem inherently
threatening.”). Moreover, this court already found that Mr. Lafayette’s comment that “he hoped [Ms.
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Nichols] got hit by a [vehicle]” was a threat and part of a pattern of threatening behavior that amounted
to stalking. Nichols, 2025 WL 826911, at *1.
All of Mr. Lafayette’s claims depend to some degree on the allegation that the officers lied in
the Affidavit of Probable Cause. Thus, without a colorable claim that the Affidavit was falsified,
almost all of Mr. Lafayette’s claims fail for that reason alone. His First Amendment retaliation claim,
for instance, alleges that he “engaged in protected advocacy,” and that Ms. Nichols and the police
officer defendants contributed to the submission of a “false affidavit mischaracterizing [Mr.
Lafayette’s] speech to justify retaliatory criminal charges.” Am. Compl., p.13. His First Amendment
claims against Chief Burke and the City are merely vague and conclusory allegations: he claims that
Chief Burke “[f]ailed to supervise officers, allowing the retaliatory actions to proceed,” and that the
City “[n]eglected to ensure that [police] officers upheld constitutional protections, enabling systematic
retaliation.” Id. He alleges that the Affidavit’s “explicit[] reference[]” to the “financial burden of
Lafayette’s lawsuits” on the school district “demonstrat[es] that [his] actions were driven by retaliatory
motives rather than legitimate law enforcement concerns.” Id., pp.11–12. While the Affidavit mentions
that “Nichols stated Mr. Lafayette is constantly threatening to sue the district and is making multiple
public records requests, which are costing the district money,” Aff. of Prob. Cause ¶ 10, that is patently
not the basis for the arrest and that reference in the Affidavit fails to demonstrate any retaliatory
motive. As discussed above, the officers concluded that there was probable cause based on Mr.
Lafayette’s threatening behavior that went beyond First Amendment-protected activity.
Mr. Lafayette cites two U.S. Supreme Court cases to support his argument that “even when
probable cause exists, a First Amendment retaliation claim still survives if the government’s adverse
action was motivated by protected speech.” Pl.’s Sur-Reply at 18. In fact, those cases actually affirm
that “probable cause should generally defeat a retaliatory arrest claim,” but that
a narrow qualification is warranted for circumstances where officers have
probable cause to make arrests, but typically exercise their discretion not to do so.
In such cases, an unyielding requirement to show the absence of probable cause
could pose “a risk that some police officers may exploit the arrest power as a
means of suppressing speech.” . . . For example, at many intersections, jaywalking
is endemic but rarely results in arrest. If an individual who has been vocally
complaining about police conduct is arrested for jaywalking at such an
intersection, it would seem insufficiently protective of First Amendment rights to
dismiss the individual’s retaliatory arrest claim on the ground that there was
undoubted probable cause for the arrest. In such a case, [] probable cause does
little to prove or disprove the causal connection between animus and injury.

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Nieves v. Bartlett, 587 U.S. 391, 406–07 (2019) (quoting Lozman v. Riviera Beach, 585 U.S. 87, 99
(2018)). Here, of course, the conduct for which Mr. Lafayette was arrested was stalking and
threatening, a far cry from the jaywalking example that Chief Justice Roberts provided in Nieves.
There is no allegation, nor can the court otherwise conclude that stalking and threatening behavior is
something for which officers typically exercise their discretion not to arrest. Moreover, as discussed
above, Mr. Lafayette has failed to adequately plead any retaliatory motive for his arrest, and the
Affidavit of Probable Cause demonstrates that there was no such motive. Nieves and Lozman do not
aid Mr. Lafayette’s cause.
Mr. Lafayette’s other claims fare no better. His abuse of process claim alleges that “Defendants
misused legal processes by filing a false affidavit and pursuing criminal charges for the improper
purpose of silencing Plaintiff’s advocacy.” Am. Compl., p.14. His Common Benefits claim alleges that
Defendants treated him “unequally” by, among other things, “[r]eclassif[ying] his constitutionally
protected speech as criminal conduct. Id., p.15. And his negligent supervision claim alleges that Chief
Burke negligently supervised his officers by allowing “[t]he submission of a false affidavit” and “[t]he
reclassification of constitutionally protected speech as criminal conduct.” Id., p.16.
To the extent his Common Benefits and negligent supervision claims rely on distinct factual
allegations, the claims still fail. For example, he alleges that Defendants violated the Common Benefits
Clause by “ignor[ing] his credible September 11, 2024 report of harassment,” “influenc[ing] law
enforcement to target [him] unfairly,” and—as to the City—by allowing the officer to “engage in
selective enforcement.” But, simply put, he wholly fails to satisfy the requirements for pleading a
Common Benefits violation. See Vitale v. Bellows Falls Union High Sch., 2023 VT 15, ¶ 24, 217 Vt.
611 (To state a Common Benefits claim, “[t]he complaint must contain a short and plain statement that
(1) defines the part of the community disadvantaged by the legal requirement; (2) identifies the
governmental purpose, if any is known, in excluding a part of the community from the benefit; and (3)
explains how the omission of a part of the community from the benefit does not bear a reasonable and
just relation to a governmental purpose identified.”) (quotation and footnote omitted). It is “insufficient
to assert that there is a law that results in some people having a benefit and others not, accompanied by
the legal conclusion that this difference in treatment violates the Vermont Constitution.” Id. Mr.
Lafayette has completely failed to meet his burden and, thus, has not overcome the presumption of
constitutionality. See id. ¶ 21.
In his negligent supervision claim, Mr. Lafayette also alleges that Chief Burke negligently
supervised his officers by allowing Officer Lasker to “dismiss” his September 11, 2024 “report”

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concerning the alleged June 26, 2024 incident with his son and a basketball coach at the high school.
Am. Compl., p.16; see also id., pp. 9–10. According to the Affidavit of Probable Cause: “Lafayette
reported that his son was harassed and physically intimidated by a coach when the coach yelled at his
son and raised a fist in a[n] intimidating manner. This report was documented and based on the
information provided didn’t rise to the level of a criminal offense.” Aff. of Prob. Cause ¶ 12. The
officers are plainly entitled to qualified immunity for this alleged failure to investigate. “Qualified
immunity attaches to public officials who are (1) acting during the course of their employment and
acting, or reasonably believing they are acting, within the scope of their authority; (2) acting in good
faith; and (3) performing discretionary, as opposed to ministerial, acts. Good faith exists where an
official’s acts did not violate clearly established rights of which the official reasonably should have
known.” Baptie v. Bruno, 2013 VT 117, ¶ 11, 195 Vt. 308 (citation and quotations omitted). The scope
of a police officer’s investigation into a complaint is “at the heart of his official and discretionary
duties as a police officer.” Id. ¶ 12. Here, the officers were plainly acting during the course of their
employment and within the scope of their authority, there is no indication in the pleadings that they
acted in bad faith, and the failure to investigate further is plainly a discretionary act. See, e.g., id. ¶ 12–
13) (police officer entitled to qualified immunity in suit alleging liability for negligent investigation of
complaint against man who thereafter murdered victim); Winfield v. State, 172 Vt. 591, 593–94 (2001)
(concluding, on motion to dismiss, that “game warden’s decision to issue an investigative report” was
a discretionary duty and protected by qualified immunity); Kane v. Lamothe, 2007 VT 91, ¶ 10, 182
Vt. 241 (“a police officer’s decision to arrest . . . is inherently discretionary”); Czechorowski v. State,
2005 VT 40, ¶ 21, 178 Vt. 524 (“The decision whether to investigate further was a discretionary one,
and therefore protected from suit.”). Moreover, there is no indication in the pleadings or otherwise that
the officers “violate[d] clearly established rights of which the [officers] reasonably should have
known.” Livingston v. Town of Hartford, 2009 VT 54, ¶ 14, 186 Vt. 547. There is certainly no right to
demand that an officer further investigate a complaint or issue a report.4
Because the Amended Complaint plainly fails to state a claim based on the reasoning above,
there is no need to wade into the sovereign immunity arguments. The court notes, however, that the
only defense to sovereign immunity raised by Mr. Lafayette is his contention that the U.S. Supreme
Court “eliminated sovereign immunity for municipalities in civil rights cases” in Monell v. Department
of Social Services, 436 U.S. 658 (1978). Monell indeed held that municipalities “can be sued directly
4 Mr. Lafayette argues that qualified immunity requires factual development and cannot be decided on a motion to dismiss.

Not so. While qualified immunity often requires factual development, it can be decided at the pleading stage in the
appropriate case. See, e.g., Winfield, 172 Vt. at 593–94.

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under § 1983 for monetary, declaratory, or injunctive relief” where the alleged unconstitutional action
implements or executes a municipal policy or custom. Id. at 690–91. But Mr. Lafayette alleges no
unconstitutional action, let alone a municipal policy or custom that implements such action. As
discussed above, he fails properly to plead any constitutional violation.
Lastly, with respect to this motion, the court observes that Mr. Lafayette makes multiple
requests for Rule 11 sanctions against Defendants in his 36-page—and at times bombastic—sur-reply.
See, e.g., Pl.’s Sur-Reply at 4. That request is improper because he did not file a separate motion for
sanctions as required by Rule 11. See V.R.C.P. 11(c)(1)(A) (“A motion for sanctions under this rule
shall be made separately from other motions or requests and shall describe the specific conduct alleged
to violate subdivision (b). It shall be served as provided in Rule 5, but shall not be filed with or
presented to the court unless, within 21 days after service of the motion (or such other period as the
court may prescribe), the challenged paper, claim, defense, contention, allegation, or denial is not
withdrawn or appropriately corrected.”). Moreover, his request for sanctions is completely meritless
and the court would deny it even if he had properly filed a Rule 11 motion.5
II. MOTION TO DISMISS (Attorney Sturges)
Deputy State’s Attorney Sturges separately moves to dismiss the claims against her on grounds
of absolute prosecutorial immunity and failure to state a claim for either abuse of process or malicious
prosecution. Mr. Lafayette has not filed an opposition to that motion. The court grants the motion for
the reasons aptly articulated therein. See Pharmacists Mut. Ins. Co. v. Myer, 2010 VT 10, ¶ 18, 187 Vt.
323 (Where party “filed no opposition to the motion to dismiss,” his “failure to oppose the motion
effectively waived the claims.”).
III. MOTION TO AMEND
Mr. Lafayette attempts to remedy the fatal infirmities as to his claims against Attorney Sturgess
in his Second Amended Complaint by moving to amend for the third time.6 That attempt is in vain. As
grounds for his proposed third amendment, he alleges “newly discovered evidence” and that the
proposed amendment “refine[s]” his legal claims. Bluntly, none of his new allegations so much as
move the needle. The so-called “newly discovered evidence” he refers to includes motions for standby
counsel and for a competency evaluation that were filed in his criminal case, which Mr. Lafayette
suggests were somehow “used strategically to undermine [his] self-representation and civil claims.” He

5 Indeed, Mr. Lafayette’s sanctions request is itself at least borderline frivolous and possibly sanctionable.
6 Mr. Lafayette filed his Amended Complaint on January 3, 2025, and Defendants moved to dismiss on January 17. Mr.

Lafayette then filed his Second Amended Complaint on February 25, which merely added Defendant Sturges as a party and
did not affect the claims as to the other Defendants. Then, on April 23, Mr. Lafayette moved to file a Third Amended
Complaint.
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also refers to a temporary restraining order that was apparently served by the South Burlington Police
Department rather than the Burlington Police Department. There is no reason any of those allegations
would allow his proposed Third Amended Complaint to survive a motion to dismiss. Similarly, Mr.
Lafayette’s “refinement” of his allegations concerning malicious prosecution, abuse of process, and
prosecutorial immunity add nothing to the mix that would save his claims.
ORDER
The court grants Defendants’ motions to dismiss and denies Plaintiff’s motion to amend. All
claims against the City of South Burlington Defendants (the City itself, its police chief, and the three
South Burlington police officers) and Chittenden County Deputy State’s Attorney Alexandra Sturges
are dismissed with prejudice. This leaves only Mr. Lafayette’s claims against Defendant Violet
Nichols. As far as appears from the court’s file, she has not yet been served, now well past 6 months
from the filing of this case. Thus, the court orders that Plaintiff show cause, within 10 days of this
Order, why it should not dismiss all claims against her pursuant to V.R.C.P. 41(b)(1)(iii).

Electronically signed pursuant to V.R.E.F. 9(d): 5/27/2025 1:11 PM

___________________________
Samuel Hoar, Jr.
Superior Court Judge

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