Hello Guys,

I have attached Halpin's submission to DLR. As I suspected he is trying to transform assignments to the Policy Review and Accreditation teams to "bargaining" which is total bullshit, undermines the labor/management relationship and makes a mockery of c.150E. Apparently, he didn't review the CBA recognition Article which designates HRD as the exclusive bargaining representative of the Commonwealth. This Motion Is little more than a desperate attempt to distract from the merits of our case.

In any event this is merely a distraction and we will put our case on as planned.

I copied Matt and Shawn on this email because their names were invoked and used in Patty's Affidavit.

Paul T. Hynes, Esq.

Angoff, Goldman, Manning & Hynes, P.C.

100 River Ridge Drive

Suite 203

Norwood, Massachusetts 02062

781-255-7700 (Telephone)

781-255-7750 (Facsimile)

phynes@angoffgoldman.com (Website)

---------- Forwarded message ---------
From: Halpin, Michael (POL) <michael.halpin@state.ma.us>
Date: Fri, Apr 30, 2021 at 5:34 PM
Subject: SUP-21-8482
To: EFile DLR (DLR) <efile.dlr@state.ma.us>
Cc: Ventrella, Meghan E (DLR) <meghan.e.ventrella@state.ma.us>, phynes <phynes@angoffgoldman.com>, Patrick Hanley <hanley@buttersbrazilian.com>

Dear Sir / Madam:

Enclosed for filing in the above-referenced matter, please find the Respondent, Department of State Police’s Motion to Dismiss the above-referenced Charge of Prohibited Practice . In the event the Motion is denied and/or action on the same is deferred, please be aware that the Department intends to present one or more of the Exhibits accompanying the Motion at the Investigation Conference scheduled for May 4, 2021.

Please let me if there are any questions or concerns. Thank you.

Sincerely,

Michael B. Halpin

Special Counsel to the Colonel

Massachusetts State Police

470 Worcester Road

Framingham, MA 01702

Tel: (508) 820-2303

Fax: (508) 820-2649