# 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 ofLots 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 ofmy 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 ofyou 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 ofmy 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 ofNorwood Police, my client erected sixteen, eight foot long aviation-compliant barriers containing approximately 480 gallons ofglycol propylene, on its Lot G, along a line professionally surveyed for the purpose. You and your employee, Rob Sylva, were witnessed emptying the contents ofat least eleven ofthese 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 ofremediation, replacement ofits barriers, lost glycol, lost business opp011unity associated with the incident, and present and future expenses arising in connection therewith, all ofwhich it will seek to recover from you and BEH. Please direct any response to this letter through your attorney ofrecord

. Sincerely,

**~** 

# //

**p~ /**  / (_ iciCBurlingham General Counsel FlightLevel Aviation 860-235-5786 Cc: Joshua M Fox, Esq
. Rollins , Rollins & Fox 36 Glen Avenue 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 1 25 ACCESS RO AD NO HWOOD , MA 02062 71\1 -7 69- 8680 F AX 711 1 -76 9 -7 1 80