West Easton Sends Threat To File Charges For Pig Ownership

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BRIAN J. PANELLA † STEVEN N. GOUDSOUZIAN* CHAD M.

DIFELICE†
[email protected] [email protected] [email protected]

NICOLE M. THOMAS† ROBERT EYER MATTHEW C. POTTS


[email protected] [email protected] OF COUNSEL

October 15, 2018

VIA EMAIL ONLY TO [email protected]


Tricia Mezzacappa
817 Ridge Street
West Easton, PA 18042

Re: Borough of West Easton


Our File No. 2016-05-02

Dear Ms. Mezzacappa:

It has come to my attention that you recently spoke with representatives of


the Borough of West Easton and indicated that you may be obtaining a pig and/or
you have already obtained a pig.

As you are aware, there is an ordinance which specifically addresses this


issue. In fact, this was an exhibit that you introduced at the non-jury trial on
October 9, 2018. The purpose of this correspondence is to advise you as to the
ordinance (which you already know). Further, the purpose of this correspondence
is to information you that you are not permitted to have a pig, and, if you violate
the ordinance, the Borough will be forced to enforce the ordinance.

On behalf of West Easton, it is unclear why you would knowingly violate an


ordinance. Furthermore, it appears that you are doing this to instigate litigation. I
note that you have posted to the West Easton Facebook page the following:

“TriciaJenn Too little too late pals...had one for 15 years


here on Ridge Street, and just got myself another one.
What are you going to do about it?”
It is as if you want to continue to litigate with the Borough.

†Also admitted in NJ 2940 William Penn Highway, Easton, Pennsylvania, 18045-5227 *Also admitted in MA
t: (610) 253-9171 f: (610) 559-9281 www.SNG-LAW.com
Tricia Mezzacappa
October 15, 2018
Page 2

Accordingly, in light of the ordinance, please do not take steps to violate the
ordinance. Thank you.

Respectfully yours,

GOUDSOUZIAN & ASSOCIATES

Steven N. Goudsouzian
SNG:sa
cc: Joan Heebner, Borough Manager (via email)
X:\Transfer\clients (server08)\2016\West Easton Borough(Solicitor).05\Mezzacappa Litigation\Mezzacappa 10.15.18 ordinance re pig.docx

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