City Council
Regular MeetingSalem, MA · March 10, 2025
Minutes
City of Salem, Massachusetts
“Know Your Rights Under the Open Meeting Law, M.G.L. c. 30A ss. 18-25 and
City Ordinance Sections 2-2028 through 2-2033.”
The City Council Committee on Committee of the Whole____________________________________________
met in the Council Chamber on __Monday March 10, 2025________________________ at _______6:00 PM________
for the purpose of discussing the matters(s) listed below. Notice of this meeting was posted on
_________________March 5, 2025_____________________ at _________1:43 P.M.__________________
(This meeting is being recorded)
ATTENDANCE
All members of the COW were in attendance along with Jason Etheridge, President of Lifebridge and Andrew DeFranza,
Executive Director of Harbor Light Homes.
ABSENT WERE: None
#574 Meeting with Andrew DeFranza and Jason Etheridge to discuss the project at Margin St – Life Bridge.
Prosniewski - This is an informational meeting only. This is only to update the Council on current plans which continue to
change as input is being provided to Lifebridge by the city and by the public. There will be no votes taken on any issues tonight.
The permitting process has not begun, nor has there been any proposed zoning changes. We will begin this meeting with a
presentation by the Lifebridge Committee. which will be followed by a question-and-answer period by city councilors. If time
allows, we will open the meeting up to public comment. I hope this meeting will answer many of our questions and concerns.
and we welcome any fresh and constructive dialogue to better understand the feasibility of this project.
Zoning Information -
40R – The Smart Growth Zoning Overlay District Act, Chapter 149 of the Acts of 2004, codified as M.G.L. chapter 40R (the Act),
encourages communities to create dense residential or mixed-use smart growth zoning districts, including a high percentage of
affordable housing units, to be located near transit stations, in areas of concentrated development such as existing city and
town centers, and in other highly suitable locations.
Projects must be developable under the community's smart growth zoning adopted under Chapter 40R, either as-of-right or
through a limited plan review process akin to site plan review.
Upon state review and approval of a local overlay district, communities become eligible for Chapter 40R payments, as well as
other financial incentives.
Chapter 40R seeks to substantially increase the supply of housing and decrease its cost, by increasing the amount of land
zoned for dense housing. It targets the shortfall in housing for low- and moderate-income households, by requiring the
inclusion of affordable units in most private projects.
40B – Chapter 40B is a state statute, which enables local Zoning Boards of Appeals to approve affordable housing
developments under flexible rules if at least 20-25% of the units have long-term affordability restrictions.
Dover Amendment - Massachusetts state law that prevents towns from adopting zoning bylaws that "prohibit, regulate or
restrict the use of land or structures for... educational purposes on land owned or leased by ...a nonprofit educational
corporation".
Presentation by Lifebridge and Harbor Light Homes -
Etheridge – I am the President of Lifebridge North Shore and with me is Andrew Defranza who is the Executive Director of
Harbor Light Homes. We have some slides to go through to give you the most up to date information. Lifebridge is a nonprofit
headquartered in Salem. We focus on serving unhoused, recently housed and those at risk of becoming homeless. We serve
through intensive case management and supportive services. We also have programs in Beverly, Gloucester, Lynn and
Peabody. We have a regional approach to our mission. Our yearly operating budget is just under $7 million, and we have
almost 100 employees. Our goal is to continue our mission to help as many people as possible to recover from homelessness.
Lifebridge has been in Salem since 1978 with the Crombie Street Shelter. We have grown a lot since then.
One of our main goals is to create a more dignified, non-congregate shelter to replace our 2 congregate shelters that we're
currently running in Salem. What's the difference between congregate and non-congregate? A congregate shelter is one with
of cots and beds in open spaces, and a non-congregate shelter is one with barriers in between beds, like permanent walls. Our
proposal consists of 70 non-congregate beds which will provide a lot more dignity. The days of putting a bunch of people in a
large open space in the basement would be done. Our proposal is to take this to the next level. We are running a 50
congregate shelter bed on Margin Street, and upwards of 70 congregate shelter bed on Canal Street. We're proposing 70 non-
congregate beds in this new project. We really need to improve our facilities at Lifebridge and help improve the intensive case
management and the supportive service that we're currently doing there. Andrew will talk a lot more about the supportive
services. We would like to create 41 new apartments that will help these folks that we serve with long-term independence. We
are not doing this for the sake of doing this, we're doing this out of need. Many different needs. One that is hitting very close
to home lately is our aging facility. We love our property on Margin Street, but it is just about 100 years old and has fallen into
disrepair. It is very expensive to operate. I've been at Lifebridge for about 10 years, and we have done a lot of work on the
building in that time. We recently got a new roof, we renovated the kitchen, but every day there’s another project, another
physical project. The cost is becoming prohibitive at this point. So, we're really looking forward to doing something to improve
our facility and give something that provides a lot more dignity to the work we're doing.
A lot of folks don't know this, but Lifebridge has a community meals program. It serves anyone not just homeless individuals.
As a matter of fact, a lot of the folks that come to our community meals aren't homeless. Last year we served between 75,000
to 80,000 meals. Hot meals, breakfast, lunch, and dinner, and that came out of a kitchen that is probably around 300 square
feet. There’s a need for improvement, there’s a need for a non-congregate facility. As I stated before, we really are committed
to building something that is non-congregate. We must put folks into a space that has walls and provides dignity. We know
you're going through some really tough stuff when you end up at Lifebridge, and to do that in a milieu with 50 other strangers
in bunk beds tends to be difficult. We want to remove that barrier, and we want to start working with folks in a different way
and giving them a chance to have a quiet space, something that we can also manage, which is very important to us. We
learned a lot during covid. It's very difficult to manage congregate facilities during pandemics, and if it's not a pandemic, it's
anything like the flu. We'd like to use what we learned in these past few years and put them into practice.
There’s a lack of housing in Salem. There's not enough affordable housing. There's certainly not enough housing for the folks
we serve. which tends to be even below affordable housing, or we tend to think of affordable housing, and it’s more like
supportive and accessible housing. We are watching homelessness grow in the past 2 years. The current data says a 30%
increase in the last 2 years. And I think that's wildly underreported. We haven't really seen the numbers for 2024 yet.
There’s also an increased demand for services and not just at our Salem facility, but all our facilities and programs has seen a
tremendous increase for demand of services. In other words, more people are coming for more services, whether its food,
homelessness, prevention of homelessness, helping to pay for rent, basic case management, or connection to physical, mental
and behavioral health services. We're seeing a huge increase.
We started this project close to 3 years ago, conceptually. We may have more folks needing these types of services in all our
communities. So, we want to get ahead of that. I think it's only will get worse in terms of demand for services.
We are currently looking at a 40R project. We've heard a lot about that in our community in Salem. It's the smart growth
overlay district zoning but 40 B is always an option. It's a different set of rules and a different process. And lastly, we've been
spending some time looking at the Dover Amendment, which does protect nonprofit agencies from different zoning
restrictions, and has been successfully used in Massachusetts as recently as September of 2024 to do similar projects.
We will consider other options but prefer to continue to work through the 40 R process. The changes that we have made to
this project over the last 2 years are on our website for anyone that is interested. We did move away from housing for seniors.
We have agreed to keep the 54 Margin Street Church building intact and we are not moving a thrift store onto Margin Street.
We have made this project smaller because of the community’s concerns. You can see the drawings and how we've changed
the project over time. In the next part of the presentation, we will show slides of the proposed buildings and changes we
propose.
DeFranza - Harbor Light Homes is a local regional nonprofit. We develop affordable housing for many different types of people;
essential workers, senior citizens, disabled, and formerly homeless. We also advocate for that and operate it particularly with
service enriched features.
On the slides from right to left on Margin Street (see attached pictures), there’s a new building on the far right, which is the
white building with the peaked roof right next to the church. The former church does stay and there will be 2 wings created,
one to the right and one to the left, which connects the buildings. We are keeping the church building because we understand
that is important to the community. The church is going to get used for programming space, because it has big, wide-open
spaces. Next to that is the Lifebridge space. It will be programming space and 70 non congregate shelter beds. The primary
goal was to fix Lifebridge's facility and give them a better, more sustainable, more energy efficient, more humane shelter
space. Then to the left of that is the residential space and that goes around the corner. The building currently has 12 SRO
(single room occupancy) units with shared facilities, and they would be replaced by studio apartments. Every one of the
apartments would have its own kitchenette and its own bathroom all meant for single occupancy. The existing building will be
4 stories and around the corner and to the left on Endicott would be a 3-story building with pitched dormers. There would be
41 new studio apartments, plus the 12 that were existing for a total of 53. There's been some question about this roof line, so
we're continuing to work on this to make sure it would be acceptable to the neighbors so that roof line could still change.
There is small parking area which is under the building and then there would be the new Christopher Columbus Club. They
would like to stay, but can't manage the space that they're in, and the building needs are extensive as described, so that
building would get knocked down. The historic markers would get moved and displayed. The club would have their own space
and their own door. The historic markers and the bell that is owned by the club would be displayed and we will work with the
community on how best to display them, but we have an example of how they could be displayed in the front of the church on
Margin St. There is currently a playground behind the building. Originally, we had proposed to try to do something here and
build a new park and add some senior housing but that is not going to happen now.
Discussion:
Jerzylo – How many parking spaces in the garage?
Defranza – 12
Jerzylo – There’s only 12 parking spaces for 100 employees?
Etheridge – The 100 employees are not all in Salem and there are about 8 employees that work at Lifebridge at any given time.
Jerzylo – Where do the employees park now?
Etheridge – They park on the street.
Jerzylo – Will there be more employees after the project is complete?
Etheridge – If the programs are successful, then there may be more than 8 employees going forward.
Jerzylo – Will there be a common area because there isn’t one now and at a certain time of day, everyone must leave, and we
see them congregating outside at the flag poles in front of the post office?
Etheridge – There is currently a day center in the building next to the shelter which people can go to that is always open. It is a
common area that can accommodate about 100 people. The shelter itself closes very infrequently, but if it does, they can go
to the day center and we plan to continue to have the day center within the new project.
Morsillo – Can you explain what services that you currently offer and how you will be expanding services?
Etheridge – We plan to add services. Case management is key, and each person gets a one-on-one case manager. They work
with them on a multitude of things from getting a birth certificate or ID, to getting on housing lists and filling out the
applications. We also help with getting them behavioral health services. We would also like to help with workforce
development. About ½ of those that stay at Lifebridge do maintain a job which is a common misconception that homeless
people don’t work. They do but don’t make enough or work enough to afford housing. We would like to help them to work
more even as much as working in our kitchen. Right now, our kitchen is too small for that but a larger kitchen would allow us
to have them work there and they could learn some really great skills. We also have a lot of other services – music therapy and
art therapy are the most popular ones currently. We also have many yoga classes. We would be adding to our current services
and the one that I would really like to see if workforce development.
Morsillo – How many case managers do you have onsite?
Etheridge – We currently have 5 at the shelter on Margin St and 3 of them are licensed social workers. We also have 2 at the
day center and hoping to add another one soon. Those are working one on one with people, and we also have a robust direct
care staff.
Morsillo – Are they there 7 days a week?
Etheridge – The case managers are rotated in, and they are on call as well but there are direct care staff there overnight 7 days
a week.
Morsillo – Will there be any staff at the housing?
DeFranza – We are in 12 communities across the North Shore. We run Boston Street Crossing which has 26 studio apartments
for the formerly homeless. We have case managers onsite and we plan that this model will be similar. That model is very
effective. There would also be a full time property manager, full time maintenance person and a full time Resident Service
Coordinator supporting the ongoing stability and success of the residents separately from what is happening at the shelter.
Morsillo – Will there be anyone living there?
DeFranza – We could have someone living there. We don’t have anyone living at Boston Street Crossing, but we have a couple
other buildings with live in staff. We have staff on call.
Morsillo – Do you have other buildings of similar size as this project?
DeFranza – No not for people getting out of homelessness. We have one for seniors that is 30 units.
Morsillo – That is one of the things that is weighing on me. I have been in one of the buildings on Boston St and it’s great. One
of the buildings is in my ward and I haven’t had any complaints, so I know that they work, but they are smaller. Having 70
shelter beds and 53 units that are high needs in one square block concerns me.
Defranza – The advantage is that you have a much more efficient model. The volume of services to the proximity is much
better. There are similar models in other locations in Massachusetts as well as other states that are larger and have been very
successful.
Morsillo – My concern is the staffing.
DeFranza – We plan to have 3 staff, and we would be open to hiring a resident manager to live onsite.
Morsillo – I am also concerned about the lack of outdoor space. You’re adding 41 units and there is very little outdoor space.
DeFranza – You’re correct. There isn’t much outdoor space but to have more, the building would have to be taller, and we
know that a taller building is a concern.
Merkl – I agree that our unhoused population will grow for several reasons, and I thank Jason and Andrew for the difficult work
that they are doing. I am leaning in favor of this project. I’m okay with the number of new units because it is next to Lifebridge
with its services, and it is also close to transportation and MassHire. Having a shelter doesn’t make sense without supportive
housing that is permanent. And Boston Street Crossing has been very successful. This is needed. After supporting the
camping ordinance, it would be wrong to not support a program for more affordable housing. How many people attend the
day center? Does the drop in day center help them to gravitate towards using your other programs?
Etheridge – We average about 60 people per day at the day center. And yes, it does help having staff there that can engage
with the people to try to help them or get them to use our services.
Harvey – What about deliveries and dumpster?
DeFranza – There will be trash compactor in the building. They can put their trash in a shoot inside the building and it will be
compacted and then those will go outside to get picked up instead having a dumpster outside the building. There is also a
loading space for deliveries.
Hapworth – We spent a lot of time on the no camping ordinance last year and we had a lot of discussions around that
ordinance, but that ordinance is completely unenforceable without shelter beds. Can you tell us again how many shelter beds
we are adding?
Etheridge – There are currently 120 congregate shelter beds total in the 2 locations, and we want to create 70 non-congregate
beds.
Hapworth – I think a lot of people look at this like you would be creating a massive shelter in the middle of downtown Salem,
but that isn’t the case. You wouldn’t be adding any beds, just giving those living in the shelter more dignity and you are adding
studio apartments which has been shown to be a better solution to impact homelessness.
Etheridge – We believe a shelter is not the answer to homelessness. Housing is what we need. A new shelter is not the goal of
this project. The goal is a new non congregate shelter complimented with housing. We are willing to reduce the shelter beds
while adding more housing.
Hapworth – You said there are other similar models. What are the issues or problems that they have run into? What are their
successes? What have we learned from those communities that we are implementing here in this proposed project?
DeFranza – You need to staff it and the shared facilities that you have with SROs instead of the studio apartments with their
own kitchen and bathroom are tough. Having separate bathrooms and kitchens is more expensive, but it promotes
independence and cuts down on the chance of possible friction between the tenants. The main thing is that it works. If you
can house people on site and offer them services, they are more likely to recover and maintain their independence.
Hapworth –The concentration of the housing with the onsite services will lead this to work?
DeFranza – Yes.
Hapworth – Can you go through some of the security measures that you will have on site, like security cameras?
DeFranza – I can speak to the housing – we will have a sophisticated camera system around the building. Each unit will have a
screen inside so you can see who is at the door. There are cameras all around the building and the manager can see them in
their office and we will also have access to the cameras remotely.
Hapworth – Do you anticipate getting more people asking for shelter beds once this project is complete?
Etheridge – I don’t see this project pushing the needle one way or the other. People are going to show up. The homeless crisis
is going to continue to get worse and we turn away a lot of people every day. As far as security, we have cameras inside and
outside the building and our overnight staff is awake staff not sleeping staff.
Hapworth – Do you turn away people who are impaired or intoxicated?
Etheridge – We will turn away people based on behavior not on intoxication. And if they aren’t behaving in a manner where
they can stay at Lifebridge we would call the police. We also work with Salem Hospital if someone needs care. We wouldn’t
push someone out unless they had somewhere to go that will help.
Davis – I fully support this project although I am disappointed that the project isn’t as big as it was originally proposed.
Understanding there is a need to combat the housing crisis and homelessness crisis and the urgent need to house our most
vulnerable. I would like to address a question that I have been getting from a lot of people. People are asking why is Salem
putting more effort into fighting this crisis than other communities? I would urge folks that instead of opposing this expansion
to put pressure on other communities to do their part to fight these crises. It's a very fair question to bring up this imbalance,
but I am incredibly proud to live in a community that we have such amazing partners like you, and where something like this is
on the table. And I think that's something we can all be proud of, and I want to commend both of you. I've been incredibly
impressed throughout this process. Even as an elected official. I know that I've gotten only a tiny fraction of the vitriol that I've
seen be directed towards you, and through it all you've remained respectful.
Harvey – Is there a process for residents of the shelter to get a place at Harbor Light?
DeFranza – Getting into the housing is a lottery that is governed by the state. They complete an application and there is a
random drawing from there. The housing is only for those who are formerly homeless. There will also, likely be, a preference
given to those living in Salem, so the odds are better for those that are living at Lifebridge will get a spot in housing. The
maximum the state will allow for preference is 70% but that doesn’t mean that the other 30% comes from outside of Salem; it
just means they won’t get the preference. There is no mandate that requires to keep the local preference at 70% over time
though. There is some movement in another gateway city to get the preference % increased so it might be something that
Salem wants to get involved with to see if you can get that number increased.
Watson-Felt -C. Harvey asked the question that I had but I know that the type of government funding that you get will allow
you to give local preference, does that mean that that is the type of funding that you are trying to get?
DeFranza – No. The local funding is what will designate the local preference which would be included in the local funding
agreement and then you get state funding as well, but that funding is based on what you have in place at the local level.
Watson-Felt – Are you seeking federal funding?
DeFranza – Yes, but we are watching what is happening with HUD and the market to see if that will be possible.
Watson-Felt – If you were unable to get federal funding, would that preclude you from completing this project at any point?
DeFranza – No, but it could affect the timing. I think we could still get the project funded but it might just take longer to get
there.
Watson-Felt – I would like to echo C. Morsillo’s comments about connecting services and ensuring that with more people in
the system, that those services are expanded. I think it will be necessary to see 2-3 more people on staff to be able to offer
more services. Is there any reason why you can’t expand services now? I know the physical space might be an issue but is
there any way to start scaling up the services even before the project starts?
Etheridge – We have a lot of robust services already and we meet folks where they are at and work with them to get them to
where they want to be. Our case managers handle about 15 clients each and that is one on one service so we already have
that staff working at Lifebridge. What could increase are our supportive services that people would be doing in groups, but we
need more room to add more staff. Our administration has been forced to lease office space outside of Lifebridge because we
don’t have the office space for them in the building.
Watson-Felt – Does that include peer to peer support?
Etheridge – We just purchased the Christopher Columbus Club, and we renovated the upstairs and we will be adding more
peer to peer support in that building in the next couple of weeks.
Cohen – Can you talk about the process and how you are able to transition people to more permanent housing?
Etheridge – It is different for everyone. We are proud to say that we meet people where they are at. This may be their first
time experiencing homelessness, we’ve been seeing a lot more of that lately. In that situation, there is a lot of one on one with
a case manager. Sitting down and talking about their situation and how best to support them and what programs will work
best given their current situation. So, in the beginning it is a lot of one on one and it is complimented with working with a
licensed clinical social worker. Last year we were able to help 150 people secure accessible housing. I think that number
would be greater if we had more housing and not because we have more services. The barrier right now is that there isn’t
enough accessible housing, and this is the purpose of this project. Sometimes just giving a meal to someone who hasn’t eaten
in two days is a great start.
Cohen – Regarding collaborations, I know you work closely with the police, the department of mental health and the hospital.
In my ward, I have a lot of unhoused people in different neighborhoods and having Harbor Light and Lifebridge on the same
campus is the fit that I see that will make a difference. I am really excited about this project.
Etheridge – It’s no secret that having housing available with supportive services is wildly successful. We have seen it at Boston
Street Crossing as well as at other facilities so that is what we are aiming to do.
Merkl – You have said that there are a lot more woman that need your services and I know that you have an excellent
women’s shelter in Beverly. Will the non-congregate units be a draw to get more women to accept services at Lifebridge?
Etheridge – A lot of the women that we service as Lifebridge have been through extensive trauma although many of them
don’t identify as being victims of domestic violence but just about 80% of them have been in the past or are currently. The
women that we service tend to be in a more difficult situation than the men that come to Lifebridge because of the abuse and
women tend to wait longer to get help so when they come to Lifebridge they are in a very difficult and vulnerable state. Our
job is to give them a safe place to live and support them. Some of that support comes from other organizations that we work
with as well. We are seeing an increase in homeless young, single women and that is why we made the decision to make our
all male shelter in Beverly into an all female shelter. At one point we were turning away 25-30 women a day and that has
decreased slightly but that is a warning sign that this is a real problem. We are doing a lot of advocacies for homeless women
because they are a hidden group that did not get the attention that they needed. Under the HUD guidelines of
subpopulations, women is not one of the subcategories of homelessness like veterans, youth, etc. We have been working on
the federal level to get women included as a subpopulation which could open funding and some of benefits. A non-congregant
shelter would allow women to have the privacy and dignity that they deserve, and we would probably see some women that
wouldn’t stay in the current shelter be involved with the newly renovated shelter.
Varela – I appreciate that you are willing to work with the neighbors on their concerns, but I am disappointed at how much the
project has changed.
Harvey – What is the timeline for the project and what are you going to do for current services during the construction
process. Will you do the project in phases so you can keep services going?
DeFranza – For funding, the state has what they call a supportive housing round which is usually in the fall but we have to have
the local funding and permitting in place to do that so we could submit to the state this year, but that is a little optimistic. If
we make it this year, then the announcement will be in 2026, then we break ground in 2027 and occupancy in 2028. That is
the fastest timeline. Anything that slows things down could add a year or more to that timeline. Lifebridge is not going to be
funded with any public funding so that part of the project will be completed first then the rest of the project will be done in
phases. The most difficult part of the project is the building on the corner with the 12 SROs and we will have to find temporary
housing for the folks that live there, and that part of the project will take longer because of the necessary funding of that part
of the project.
Watson-Felt – Are the other 10 Seeds of Hope housing units going to be renovated during this project?
Etheridge – No, they are not part of this project.
Jerzylo – I am asked this question a lot by constituents, did you consider other locations for this project?
Etheridge – Yes, we looked at different locations, but we have determined that this is the best location for this project. We
have been working on this for a long time and the property that we currently own, is definitely the best option for this project.
Public Comment:
Opposed: Here are some of the comments from those opposed to the project. If you build/renovate the facility, more
homeless people will come to Salem. Project is too large. They don’t want a shelter in downtown Salem. There are other
locations in Salem that would be away from downtown and more appropriate for the size. Not enough outdoor space so
people congregate in Riley Plaza. The Lifebridge board of directors is supposed to include at least one Salem resident, but it
doesn’t. One resident claimed there are 2 sex offenders living at Lifebridge and wanted to know what the vetting process is for
allowing them to live there. Against 40R zoning (see above for reg). Not safe for women to walk in the area. People are
moving out of the neighborhood and the houses are selling for a lot of money so therefore the city is losing affordable housing.
A lot of promises made by Lifebidge that have been broken. Allowing more homeless to come to Salem is not fair to the rest of
the residents. Needs to be 100% local preference instead of just 70%.
In Favor: Here are some of the comments from those in favor of the project. Need the space since the camping ordinance was
put in place. Housing is a human right. Project is critical to combat the housing crisis. The camping ordinance was passed
partly because the Lifebridge was planning for a new/renovated facility. If you build it, they will be housed. The residents of
Agenda
City of Salem, Massachusetts
Office of the City Clerk
Ilene Simons
City Clerk
March 5, 2025
MEETING NOTICE AND AGENDA
The City Council Committee of the Whole will meet in person on Monday March 10 at
6:00 PM for the purpose of meeting with Andrew Defranzia and Jason Etheridge to
discuss the project at Margin St – Life Bridge. This meeting will be held in the City
Council Chambers. 93 Washington St., Salem, MA, 2nd Floor.
Back up Information Link:
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In-Person shall be the primary method of public access to such meetings. A secondary
method of public access may be provided, if technologically feasible through Salem
Access Television, and or remotely through Zoom. See below for remote access and
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City of Salem City Council Committee of the Whole
Agenda, March 10, 2025
Page 2 of 2
“Persons requiring auxiliary aids and services for effective communication such as sign
language interpreter, an assistive listening device, or print material in digital format or a
reasonable modification in programs, services, policies, or activities, may contact the
City of Salem ADA Coordinator at (978-619-5630) as soon as possible and no less than 2
business days before the meeting, program, or event.”
AGENDA
• Meeting with Andrew Defranzia and Jason Etheridge to discuss the project at
Margin St – Life Bridge.
Very truly yours,
ATTEST: ILENE SIMONS
CITY CLERK
“Know Your Rights Under the Open Meeting Law, M.G.L. c. 30A ss. 18-25, and
City Ordinance Sections 2-2028 through 2-2033.”
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