F L. I G H T L EVE L 

A V I A T I 0 1\J 

Ph: 781-769-8680 

Fax: 781-769-7180 

www.flightlevelnorwood.com 

www.flightlevelaviation.com 

VIA ELECTRONIC MAIL ONLY 

chris'ii'bostonewcutireheljcoptcr,.com 

Chri,topherdonovan ltiii!OHJil.com 

February 14, 20 15 

Mr. Christopher Donovan 

Boston Executive Helicopters 

125 Access Road, 

Norwood, MA 02062 

Re: NOTICE OF TRESPASS I CEASE AND DESIST 

Norwood Memorial Airport 

Lease Lots G and H 

Dear Mr. Donovan: 

I represent FlightLevel Norwood, LLC ("FiightLevel"), the controlling sublessee of Lots G and Hat the Norwood 

Memorial Airport (the "Airport"). By letters dated December 5, 2013 and July 20, 2014, l placed you and your 

attorney on notice that Boston Executive Helicopter ("BEH") has no legal or exercisable right to use my client's 

Lot G in connection with its activities on Lot F. By letter dated February 6, 2015 you were commanded to cease 

and desist utilization of my client's Lots G and H in cmmection with BEH's operations on Lot F. You were flllther 

commanded to cease and desist all snow removal activity on my clients Lot G and H, and to terminate, forthwith, 

all efforts to harm, harass, interfere with and disrupt the business operations of my client. As each ofthese letters 

has gone unanswered, I assume you are no longer represented, and I am therefore writing directly to you, as 

principal of Boston Executive Helicopters. 

On several occasions now, you, your employees, or agents of you and/or Boston Executive Helicopters acting 

under your authority, have entered onto my client's leaseholds at the Airport, and with intent to harm, harass, 

interfere with and disrupt the business operations of my client, have engaged in conduct arising to the level of 

sabotage. Recently, on January 27, 2015, and again on February 2 and 3, you and/or your organization, acting with 

intent to harm, deliberately blockaded my client's fueling system, rendering it impossible for FlightLevel to 

receive fuel deliveries at the Airpmt. 
Mr. Christopher Donovan 

February 14, 20 15 

Page 2. 

On February 13, 2015, to protect its property, ameliorate other and fmther injury from you and your employees, 

and in the presence of Norwood Police, my client erected sixteen, eight foot long aviation-compliant barriers 

containing approximately 480 gallons of glycol propylene, on its Lot G, along a line professionally surveyed for 

the purpose. You and your employee, Rob Sylva, were witnessed emptying the contents of at least eleven of these 

barriers directly onto the ground on my client's property. 

ln accordance with applicable SPCC protocol, my client has placed the appropriate authorities, including the 

Norwood Police, Airp01t Administration, and Mass DEP on notice. My client has been directed to ensure that the 

affected area is not disturbed by plowing or otherwise until professionally assessed and remediated as necessary or 

until otherwise directed by the DEP. You, your employees, agents and servants are hereby notified accordingly. 

These actions have caused and will continue to cause my client to suffer monetary damages, including in the most 

recent case the cost of remediation, replacement of its barriers, lost glycol, lost business opp011unity associated 

with the incident, and present and future expenses arising in connection therewith, all of which it will seek to 

recover from you and BEH. 

Please direct any response to this letter through your attorney of record. 

Sincerely, ~ // 

/ p~/ (_ iciCBurlingham 

General Counsel 

FlightLevel Aviation 

860-235-5786 

Cc: Joshua M Fox, Esq. 

Rollins, Rollins & Fox 

36 Glen A venue 

Newton, MA 02459 

617-969-7555 

jfox@rrf·law.com 

Russ Maguire 

Airport Manager's Office 

125 Access Road, 

Norwood, MA 02062 

781-255-5616 

nnaguire@norwoodma.gm· 

2 

FLIGII'J'L E VEL AVIATI O N 

125 ACCESS RO AD 

NO HWOOD , MA 02062 

71\1 -7 69- 8680 F AX 711 1-76 9 -7 180