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May 10, 2014

Letter from Gil Medeiros' attorney

Chairman Henry Richenburg

Salisbury Board of Selectmen

Town of Salisbury

5 Beach Road

Salisbury, MA 01952

RE:	Gilbert Medeiros

Dear Mr. Richenburg:

I, along with the American Civil Liberties Union Foundation of Massachusetts (the "ACLUM"), represent Mr. Gilbert Medeiros. I am writing with regard to the August 27, 2013 decision by the Town of Salisbury Board of Selectmen (the "Board") to remove Mr. Medeiros from his appointed position on the Town of Salisbury Liquor License Commission (the "Liquor Commission"). The Board's conduct in removing Mr. Medeiros and its refusal to reinstate him violates Mr. Medeiros' civil rights, including his rights under the First Amendment. Mr. Medeiros is entitled to immediate reinstatement.

Mr. Medeiros is a longtime Salisbury resident and active participant in the community. Among other things, he was a voluntary, appointed member of the Liquor Commission for seven years. Though he was not paid for his services, Mr. Medeiros devoted his time, energy and expertise to that position for several hours each week.

As you are aware, the Board has asserted that it removed Mr. Medeiros based on comments he made during a public meeting conducted by the Board on July 1, 2013 concerning, among other things, a proposal to build a casino in Salisbury. During that meeting, the Board resolved by a three-to-two vote to cease nonbinding negotiations with the development company that presented the casino plan. As he was leaving the meeting, Mr. Medeiros (among others) expressed frustration over the Board's resolution. He indicated that that decision would deprive the town of potential opportunities and that more exploration into options was warranted. He also stated that he would "put a petition together to recall" certain Board members.

A video recording of the meeting shows that Mr. Medeiros' statements, while impassioned, were civil. He said nothing inappropriate in the context of the meeting, much less that he intended to harm anyone. Indeed, neither you nor the other Board members attempted to "gavel" or otherwise silence Mr. Medeiros' comments, and no Board members left the meeting.

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