Pree TIAL COURT OF WASSACHUSETTS (CIVIL ACTION COVER SHEET SUPERIOR COURT DEPARTMENT IDOCKET No. COUNTY OF SUFFOLK PLAINTIFF(S) DEFENDANT(S) MASSACHUSETTS GAMING COMMISSION, STEPHEN CROSBY, in capacity, GAYLE lin her official capacity, [Type Defendant's Attorey Name City of Somerville Plaintiff Aty [Jason D. Grossfeld, Esq, Francis X. Wright, Jr, Esa, Detendantatyl sd ‘Address. [City of Somervile, City Hall 93 Highland Avenue Address city [Somervile_] state [MA] zip code [02474 city ] state [__] zipcode TYPE OF ACTION AND TRACK DESIGNATION (See reverse side) cope No, ‘TYPE OF ACTION Gpecify) TRACK IS THIS A JURY CASE? CL 1Yes 1 No [E02 Appeal From Admi istrative Agency G Lc 30A- X Track to determine [The following is a full, itemized and detailed statement of the facts on which plaintiff r lmoney damages. For this form, disregard double or treble damage claims; indicate single damages only. ‘ORT CLAIMS (Attach additional sheets as necessary) Documented medical expenses to date: 1. Total hospital expenses 2. Total doctor expenses 3. Total chiropractic expenses 4 Total physical therapy expenses 3. Total ther expenses (describe) Subtotal Documented lost wages and compensation to date Documented property damages to date Reasonably anticipated future medical expenses _ ¥ Reasonably anticipated lost wages and compensation to date s Other doctmented items of damages (deseribe) \cluding nature and extent of injury (deseribe) s Fy Sl —— a —— ——— — =REOF |G. Brief description of pl Total §, ‘TRACT CLAIMS : : (Attach additional sheets as necessary) Provide a detailed description of claim(s): TOTAL, PLEASE IDENTIFY, BY CASE NUMBER, NAME AND COUNTY, ANY RELATED ACTION PENDING IN THE SUPERIOR COURT DEPARTMENT Revere v. Mass, Gaming Cmsn., Suffok Superior Court No, 14-32 [i'kereby certify that T have complied withthe requirements of Rule Sof the Supreme Judicial Court Uniform Rules on Dispate Resolution (SIC [Rule 1:18) requiring that I provide my clients with information about court-connected dispute resolution services and discuss vith them the antages and disadvantages ofthe various methods. [Signature of Attorney of Record. Date: Dec 4, 2014 NOS.C. 32007COMMONWEALTH OF MASSACHUSETTS SUFFOLK, ss. SUPERIOR COURT DEPARTMENT C.A. No. CITY OF SOMERVILLE, Plaintiff v. MASSACHUSETTS GAMING COMMISSION, STEPHEN CROSBY, in his official capacity, GAYLE CAMERON, in her official capacity, ENRIQUE ZUNIGA, in his official capacity, JAMES F. McHUGH, in his official capacity, BRUCE STEBBINS, in his official capacity Defendants INTRODUCTORY STATEMENT 1. The City of Somerville (“Somerville”) hereby challenges the Massachusetts Gaming ‘Commission's (“Commission”) decision to award a Category 1 gaming license in Region A to Wynn MA, LLC to build and operate a gaming establishment in Massachusetts. In voting to award a license to Wynn, the Commission acted arbitrarily and capriciously, abused its discretion, and violated provisions of the Gaming Act. 2. The Commission voted to award a gaming license to Wynn MA, LLC (“Wynn”) that permits a gaming establishment, on land in or about Everett, Massachusetts,; without requiring compliance with substantive and procedural aspects of the Gaming Act, Commission regulations, and the Commission’s Enhanced Code of Ethics, and appears to enrich individuals who are the subject of federal and state indictments.3. The Commission’s violates the Gaming Act, the purposes behind the Gaming Act, the Commission's own regulations and procedures, and provisions of the Massachusetts, Constitution, JURISDICTION 4. Plaintiff City of Somerville brings this complaint pursuant to G.L. ¢. 30A (Count 1), G.L. ¢, 249 § 4 (Count II) and G.L. c. 231A § 1 (Counts III and [V). This Court has subject matter jurisdiction over the claims asserted herein pursuant to G.L. ¢. 30A, G.L. ¢. 249 § 4, G.L.c. 2B1A § Land GL. ¢. 212 § 4. 5. ‘Venue is proper in this Court pursuant to G.L. c. 223 § 1 and G.L. c. 30A, s. 14. PARTIES 6. The plaintiff, the City of Somerville ("Somerville"), is a municipality in the ‘Commonwealth of Massachusetts, located at 93 Highland Avenue, Somerville, MA, 7. The defendant, the Massachusetts Gaming Commission (the "Commission"), is a Massachusetts agency created pursuant to G.L. c. 23K § 3. The Commission has sole authority for awarding gaming licenses in Massachusetts. The Commission consists of five Commissioners. 8. The defendant, Stephen Crosby ("Crosby"), is a Massachusetts resident. Crosby has been Chairman of the Commission since 2012. 9, ‘The defendant, Gayle Cameron ("Cameron"), is a Massachusetts resident, Cameron has been a member of the Commission since 2012. 10. The defendant, Enrique Zuniga ("Zuniga"), is a Massachusetts resident, Zuniga has been a member of the Commission since 2012. 11. The defendant, James F. McHugh ("McHugh"), is a Massachusetts resident