JURISDICTION

14' This Court has subject matter

jurisdiction
over this action pursuant to Chapter
212,

4.
15' Jurisdiction over the defendants is proper pursuant to Massachusetts General
Laws Chaptet 223A,
$
3, and Chapter 223,

8, in that this action arises from the conduct of
defendants transacting business within the Commonwealth of Massachusetts.
16. Venue is proper pursuant to Massachusetts General Laws Chapter 223,
$
8, in
that the defendants have their usual places of business andlor reside in Hampshire County.
FACTS
17. Mr. Ryder was a licensed Funeral Director and Embalmer in the
Commonwealth
of Massachusetts under License Number 6028 until his suspension on or
about May 30, 2014.
i8. At all relevant times, Ryder was a duly licensed funeral home in
Massachusetts,
operating under Funeral Establishment Certificate Number 46.
19. Mr. Czelusniak is and was at all relevant times a Funeral Director and
Embalmer in the Commonwealth of Massachusetts under License Number 6588.
20. Czelusniak Funeral Home of Northampton, Inc. is and was at all relevant times
a duly licensed funeral home in Massachusetts.
Tlte Ll/ake nd Funeral Arrangements of Mr. V4tte, Sr.
21. On or about May 4,2014, Mr. V/hite, Sr. passed away.
22' Mr. White had served in the Navy in the Korean War and was a decorated war
hero.
23. Mrs. White predeceased
Mr. White, Sr. in 2011.
24. Pursuant to the wishes of Mr. white, sr. and the white Family, Ryder
preserved
some of the cremated remains from Mrs. White's cremation in2}ll.
25' From 2011 to May 5,2074, Ms. White's cremated rernains were in the
possession
of the White Family.
26. The White Family had promised Mr. White, Sr., that they would bury his
cremated remains mixed with those of his wife, Mrs. White.
27. On or about May 5, 2014, the White Family met with Mr. Ryder at Ryder to
make affangements
for funeral services for Mr. White, Sr.
28- The White Family paid
$5,935.00 for the agreed upon wake, funeral and burial
of Mr. White, Sr. ("Funeral
Services,,).
29. The agreed upon Funeral Services included military honors by the Navy,
cremation, and mixing and burial of the cremated remains of Mr. White, Sr. with the cremated
remains of Mrs. White.
30. On or about May 5, 2014, Ms. Sapowsky gave Mr. Ryder the retained portion
of Mrs. White's cremated remains for the purpose of mixing the cremated remains with Mr.
White, Sr.'s cremated remains.
31. Mrs. White's cremated remains were packaged in two white envelopes, which
in turn were contained in a white, rectangular box and placed in a yellow plastic bag.
32. Mr. Ryder agreed that the Funeral Services would include Ryder's arangement
for the obituary of Mr. White, Sr., to be published in three newspapers: The Republican, Cape
Cod Times, and Turley Publications.
33. Mr. Ryder agreed that the Funeral Services would include Ryder's arrangement
for the family's church pastor to be present at the wake to offer the final prayer.
34. Mr. Ryder agreed that the Funeral Services would include a wake on May 9,
2014, and the funeral on May 10,2014.
35. In the days following the White Family's meeting with Mr. Ryder on May 5,
2014, the White Family attempted to contact Mr. Ryder several times by telephone calls and
visits to Ryder.
36. Between the May 5,2074 meeting and the wake on May 9,2014, Mr. Ryder
did not speak to the white Family in person or on the telephone.
37. On or about }/:ay 7,2014, Mr. White, Jr., went to Ryder looking for Mr. Ryder
and discovered dead bodies in or about the garage, but did not find Mr. Ryder.
38. on or about May 8, 2014, the body of Mr. white, sr., was cremated at
Springfi eld Cemetery and Crematory (.,Crematory,,).
39. Mr. Ryder did not make affangements to publish Mr. White, Sr.'s obituary in
the Cape Cod Times and the Turley
publications.
40. Mr.'White, Sr.'s obituary was published
on May 8,2074 in The Republican.
41. The White Family had to pay
$1,800 for Mr. White, Sr.'s obituary in the
Republican because of Ryder's delay in submitting the obituary to the newspaper.
The Wke of Mr. Whte, Sr.
42- On or about May 9,2014, the White Family arrived at Ryder before the
planned 4:00 p.m. wake of Mr. White, Sr.
43. The only Ryder staff present for the wake was an unidentified elderly man
tending the entrance.
44. The door attendant at Ryder was not able to tell the White Family where Mr.
Ryder was or whether he would be present for the wake.
45. The premises at Ryder were in a state of disarray in that paper files relating to
other deceased persons
were scattered around public areas of the funeral home.
46. On or about Mray 9,2014, Ryder had not set up properly the flowers and
pictures
at the funeral home for the wake of Mr. White, Sr.
47
'
The White Family had to search the funeral home for easels and stands for the
flowers and pictures and had to arrange the flowers and pictures.
48. As visitors arrived for the wake, Ms. Sapowsky noticed the yellow bag
containing the boxed envelopes of her mother's cremated remains on the floor in the back of
the room where the wake was taking place.
49. Mr. Ryder had not mixed Mrs. White's and Mr. White, Sr.'s cremated remains
in the urn for the wake.
50. At some point during the wake, Mr. Ryder arrived at Ryder, but never attended
the wake itself.
51 . The White Family confronted Mr. Ryder about the discovery of their mother's
cremated rernains on the floor of Ryder.
52. Mr. Ryder responded to these concerns by saying, "Oh, is that what that is?"
53' Mr. Ryder promised that he would mix the cremated remains of the White
Family's parents in the um in time for the funerai.
54. Ryder did not alrange for Navy officials to be present to salute the urn.
55. Ryder did not affange for the White Family's church pastor to be present to
offer a final prayer.
56' The White Family arranged for one of the guests to give apaye and another
to perform
a military salute of the urn.
57. After the wake, the man attending the door told the White Family to remove
the flowers, pictures
and personal items, as the funeral home had another wake planned.
58. On the morning of May 70,20l4,the White Family arrived at Church of Christ
in Granby for the funeral.
59. Before the start of the funeral, Mr. Ryder assured Ms. Sapowsky that her
mother's cremated remains were mixed in the urn with her father's cremated remains.
60. Mr. Ryder's representation that the cremated remains of Mr. White, Sr. and
Mrs. White had been mixed was false.
61' As of May 10,2014, the remains of Mr. White, Sr. had yet to be collected from
the Crematory.
62. After the funeral, while the family and others mingled outside the church, Mr.
Ryder approached the family and told them, "You guys can stay here, but I'm going to the
cemetery.
"
63. Ryder did not provide a funeral procession to West Street Cemetery in Granby,
Massachusetts ("Cemetery").
64. At the Cemetery, Mr. Ryder let the White Family believe that the urn being
buried that day contained the cremated remains of their father and mother.
Dscoverv of the
falure to inter Mn White, Sr., the misrepresentutons, and the loss of the
remins
65. The Crematory records reflect that on }y'ray 12,2074, an "R. Fulton," who was
identified as a Ryder employee, collected the remains of Mr. White, Sr. from the Crematory.
66. A true and accurate copy of the referenced Crematory record is attached hereto
as Exhibit A.
;
I
67. On or about May 28,2074, the Board of Registration of Funeral Directors and
Embalmers ("the Board") conducted an inspection of Ryder and found eight decedents on the
property, improperly
stored, as well as other violations.
68. On or about May 30, 2014, the Board issued an order addressed to Mr. Ryder
temporarily suspending his license as a Funeral Director and Embalmer.
69- On or about May 30, 2014,the White Family learned of a story online in the
Daily Hampshire Gazette about Ryder's mishandling of dead bodies and the Commonwealth
of Massachusetts Division of Professional Licensure's suspension of Mr. Ryder as a Funeral
Director and Embalmer.
10. On or about May 30, 2014, upon learning of Mr. Ryder's suspension of his
license as a Funeral Director and Embalmer, Ms. sapowsky went to Ryder.
71. When Ms. Sapowsky arrived at Ryder, she was met by Mr. Czelusniak.
72. Czelusniak and St. Pierre-Phaneuf Funeral Chapels of Chicopee and
Springfield had taken over Ryder's operations after Mr. Ryder's Funeral Director and
Embalmer license was suspended.
73. Mr. Czelusniak remained involved in the operations of Ryder for some time
following the suspension of Mr. Ryder,s license.
74. On or about May 30, 2014, Mr. Czelusniak brought Ms. Sapowsky into the
funeral home office.
75. In the office, Ms. Sapowsky saw that sitting on top of a folder on an end table
was a picture
of her father.
76. Ms. Sapowsky asked Mr. Czelusniak why her father's picture was in the Ryder
ofice.
77. When Ms. Sapowsky told him her father's name, Mr. Czelusniak said, "I guess
we had the wrong person."
78- Mr. Czelusniak told Ms. Sapowsky that he had a
"mess" on his hands
-
that
there were bodies in the garage and in the basement that he could not identify and he was
tryrng to match up name with the ums.
79. Mr. Czelusniak asked Ms. Sapowsky to look at the ums in the room to see if
any were her father's um.
80' Ms' Sapowsky told Mr. Czelusniak that none of the ums were her father's and
pleaded
with him to check the bodies in the garage and basement to see if her father's body
was there, which upon information and belie{ he did not do.
81. Mr. Czelusniak represented that none of the bodies in the garage or basement
were Ms. Sapowsky's father.
82. Upon information and belief, Mr. Czelusniak did not have any support or
explanation for that representation.
83' Mr. Czelusniak suggestecl that Ms. Sapowsky fill out a police repofi.
84. Ms. Sapowsky gave Mr. Czelusniak a written statement to give to the police
and left Ryder.
85. Ms. Sapowsky informed her siblings of the disturbing information she learned
from the May 30, 2014 visit to Ryder.
8. The White Farnily was shocked, emotionally distraught, and sick with the
thought that their father's body might be lying in Ryder's basement and the remaining portion
of their mother's cremated remains might be missing.
87 . In early June 2014, Ms. Felper contacted the attorney for Ryder, Paul
Boudreau, who, on Mr. Ryder's behalf; assured Ms. Felper, that her father was cremated, that
his cremated remains were buried at the Cemetery, and that her father's cremated remains
were mixed with the cremated remains of her mother.
88. In early June2014, Ms. Sapowsky called Mr. Czelusniak to have him check
the arms of the deceased bodies in the garage and basement to see if any had the distinct Navy
tattoo that was on her father's arm.
89. Upon information and belief, Mr. Czelusniak never checked the arms of the
bodies.
90. In early June2014, Mr. White, Jr. went to Ryder and met with Mr. Czelusniak
and requested to see the cremation paperwork for his father.
91' Mr- Czelusniak represented that the cremation documentation was not at Ryder.
92. In the presence of Mr. White, Jr., Mr. Czelusniak called the Crematory and
inquired about the cremation of Mr. White, Sr.
93. In the presence of Mr. White, Jr., Mr. Czelusniak repeated back out loud three
dates as he listened to the person from the Crematory: May 8,2074, May I 2,2074,and May
L7,2014.
94- After Mr. Czelusniak ended the call with the Crematory, he represented to Mr.
White, Jr. that his father was cremated on May 8, 2014, and that his remains were buried in
the Cemetery.
95. Mr. Czelusniak told Mr. White, Jr. that cremated remains return frorn the
Crematory with a unique identification number that is also on brass tags which are placed in
the um.
10
96. Upon information and belief, the Crematory's paperwork and the brass tags
were at Ryder at a time when it was under the operation and control of the Czelusniak
Defendants.
97. On or about June26,2074, Ms. Felper called the Crematory, which confirmed
that Mr. White, Sr. was cremated on May 8,2014,but that the cremated remains of her father
were not picked
up until May 12,2014, three days after the wake and two days after the
funeral and burial.
98. Ms. Felper called Mr. Czelusniak and told him that the Crematory confirmed
that her father's cremated remains were not picked up until Mray 72,2014.
99. On or about June26,2014, with the involvement of both the local and State
Police, Mr. White, Sr.'s grave was exhumed.
100. Upon information ancl belief, Mr. Czelusniak had attempted to have the
cremated remains of Mr. White, Sr. exhumed without police or family involvement.
I 01 . The White Family had not authorized the exhumation of the grave of Mr.
White, Sr.
102- The State Police called Ms. Sapowsky to tell her that Mr. White's Sr.'s grave
was being exhumed.
103. on or about June26,2074, at different times, Mr. white, Jr. and Ms.
Sapowsky arrived at the Cemetery.
104. When Mr. White, Jr. arrived at the Cemetery for the exhumation, present were
state and local police,
Mr. Czelusniak, and Mr. Powers of St. Pierre-phaneuf Funeral Chapels.
105. Prior to the ar:rival of Mr. White, Jr. at the Cemetery, the grave of his father
had been dug up.
lt
106. Sitting on the ground
next to Mr. White, Sr.'s grave was an urn, a clear plastic
bag containing the created remains of a stranger, ancl two brown envelopes contaning an
unknown substance.
107. The brown envelopes were not the white envelopes that held Mrs. White's
cremated remains and that had been given to Mr. Ryder on or about May 5, 2014 and seen at
Ryder during the wake on or about May 9,2014.
108. Upon information and belief, prior to Mr. White,, Jr. arrival at the Cemetery,
Mr. Czelusniak had gone back to Ryder, retrieved Mr. White, Sr.'s cremation tags and placed
them at the graveside.
109. At the exhumation, Mr. Czelusniak showed Mr. White, Jr. the paperwork from
the Crematory indicating the date of the cremation was May 8,2014 and the date when the
cremated remains were picked up was May 12,2014.
110. At the exhumation, Mr. Czelusniak showed Mr. White, Jr. the brass tags from
the Crematory.
1 I 1. Mr. Czelusniak told Mr. White, Jr. that he dicl not know where Mr. White, Sr.'s
cremated remains were and that discovering the whereabouts was unlikely.
112. when Ms. Sapowsky arrived at the cemetery after Mr. white, Jr., she
confirmed that the brown envelopes present at Mr. White, Sr.'s grave were not the envelopes
containing her mother's cremated remains.
113' Mr. Czelusniak tried to convince Ms. Sapowsky, without any support or
explanation, that the brown envelopes could contain Ms. White's created remains because Mr.
Ryder could have repackaged them.
t2
ll4. Upon information and belief, while Czelusniak was assisting with operations at
Ryder, Czelusniak, or an affiliate, sought to purchase Ryder.
115. As a result of the loss of her parents' cremated remains and the actions of the
defendants, Ms. Sapowsky has suffered and continues to suffer severe emotional distress.
116. As a result of the loss of her parents' cremated remains and the actions of the
defendants, Ms. Felper has suffered and continues to suffer severe emotional distress.
lI7. As a result of the loss of his parents' cremated remains and the actions of the
defendants, Mr. White, Jr. has suffered and continues to suffer severe emotional distress.
THE WHITE FAMILY'S CLAIMS AGAINST THE RYDER DEFENDANTS
COUNT I
Intentional Infliction of Emotional Distress
1 18. Plaintiffs reassert and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
119- The Ryder Defendants engaged in extreme and outrageous conduct towards the
White Family.
120- The Ryder Defendants knew or should have known that their conduct would
cause the White Family severe emotional distress.
121. The White Family has suffered severe emotional distress as a result of the
Ryder Defendants' conduct.
122. Ryder is vicariously liable for the conduct of Mr. Ryder and other Ryder
employees.
13
COUNT II
Negligent Infliction of Emotional Distress
123. Plaintiffs reasseft and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
124. The Ryder Defendants owed a duty of care to the white Family.
125. The Ryder Defendants breached that duty of care.
126. As a proximate
cause of the Ryder Defendants' negligence, the White Family
has suffered emotional distress.
127. As a result of their emotional distress, each of the members of the White
Family has suffered physical harm, as manifested by objective symptomalogy.
128' A reasonable person would have suffered emotional distress under the
circumstances
and facts described above.
129- Ryder is vicariously liable for the negligent acts and omissions of Mr. Ryder
and other Ryder employees.
COUNT III
Interference with a Dead Body
130. Plaintiffs reassert and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set fofih fully in this count of the Complaint.
131. The Ryder Defendants' conduct constitutes intentional interference with dead
human bodies.
132. The Ryder Defendants' intentional interference with dead human bodies has
caused the White Family to suffer emotional distress.
14
COUNT IV
Reckless Interference with a Dead Body
133' Plaintiffs reassert and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
134. The Ryder Defendants' conduct constitutes reckless interference with dead
human bodies.
135. The Ryder Defendant's reckless interference with dead human bodies has
caused the White Family to suffer emotional distress.
COUNT V
Negligent Interference with a Dead Body
136. Plaintiffs reassert and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
137. The Ryder Defendants' conduct constitutes negligent interference with dead
human bodies.
138. The Ryder Defendant's negligent interference with clead human bodies has
caused the White Family to suffer emotional distress.
139. As a proximate cause of the Ryder Defendants' negligence, each of the
members of the White Family has suffered physical harm, as manifested by objective
symptomalogy.
COUNT VI
Negligence
140. Plaintiffs reassert and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
15
141. The Ryder Defendants owed duties of care to the White Family and the Estate
of Mr. White, Sr.
142. The Ryder Defendants breached those duties by failing to act in a professional
and comme rcially reasonabl e manner.
143. These failures included violations of the Code of Massachusetts Regulations
regarding the Funeral Services, including but not limited to violations of 239 C.M.R. 3.09 and
239 C.M.R.3.13.
144. As a proximate
cause of the Ryder Defendants' negligence, the White Family
has suffered damages.
145' Ryder is vicariously liable for negligence of Mr. Ryder and other Ryder
employees.
COUNT VII
Fraud
146' Plaintiffs reassert and incorporate herein each and every allegation in the
preceding paragraphs
of this Cornplaint as if set forth fully in this count of the Complaint.
147
'
The Ryder Defendants knowingly misrepresented material facts to the White
Family.
148. The White Family was induced by the Ryder Defendants to rely on and did
rely on the misrepresentations
by the Ryder Defendants.
149. As a result of the Ryder Defendants' misrepresentations and the V/hite Family
reliance on those misrepresentations,
the White Family has suffered damages.
I6
COUNT VIII
Iniunctive and Other Pre-Judgment Relief
150. Plaintif restate and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
151. Plaintif have a strong likelihood of success on the merits of this action.
152. Upon information and belief, the Ryder Defendants are planning to seli their
business, property,
and other assets in the near future.
153. Plaintiffs are
justifiably
concerned that the Ryder Defendants will alienate,
dissipate, or otherwise dispose of their assets.
154. Therefore, Plaintif seek an injunction prohibiting the Ryder Defendants from
transferring, alienating, dissipating, or otherwise disposing of any assets.
WHEREFORE,
the Plaintif, the White Family, demand that Judgment enter against
the Ryder Defendants on the above claims to such parties and order that the following
damages be awarded:
a. compensatory damages including emotional distress damages;
b. Injunctive relief;
c. Reasonable attorneys' fees and costs;
d. Interest; and
e. Such other relief as the Court may deem appropriate.
THE ESTATE'S CLAIM AGAINST THE RYDER DEFENDANTS
COUNT IX
Breach of Contract
155. Plaintiffs reassert and incorporate herein each and every allegation in the
t7
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
156. Ryder and the Estate of Mr. White, Sr., entered into a contract for the Funeral
Services for which the estate made in full pazment of $5,935.
157. The Ryder Defendants breached the contract by acts and omissions, including
but not limited to failing to provide promised services in advance of the Funeral Services for
Mr. White, Sr. as well as at his wake, failing to inter the cremated remains of Mr. White, Sr.,
misrepresenting its actions to the family of Mr. White, Sr., and causing the remains of Mr.
White, Sr., and Mrs. White to be lost.
158. As a result of Ryder Defendants' breach of contract, the estate of Mr. White,
Sr. has suffered damages.
WHEREFORE,
tl-re Plaintiff, the Estate of Mr. White, Sr., demand that Judgment enter
against the Ryder Defendants on the above claims to such parlies and order that the following
damages be awarded:
a. compensatory damages including emotional distress damages;
b. Injunctive relief;
c. Reasonable attorneys' fees and costs;
d. Interest; and
e. Such other relief as the Court may deem appropriate.
THE WIIITE FAMILY'S CLAIMS AGAINST THE CZELUSNIAKDEFFNDANTS
COUNT X
Intentional Infliction of Emotional Distress
159. Plaintiffs reassert and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
18
160. The Czelusniak Defendants engaged in extreme and outrageous conduct.
161. The Czelusniak Defendants knew or should have known that their conduct
would cause the White Family severe emotional distress.
162' The White Family has suffered severe emotional distress as a result of the
Czelusniak Defendants' conduct.
163. Czelusniak Funeral Home is vicariously liable for Mr. Czelusniak's conduct.
COUNT XI
Neglisent Infliction of Emotional Distress
164. Plaintiffs reassert and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
165. The Czelusniak Defendants owed a duty of care to the White Family.
166' The czelusniak Defendants breached that duty of care.
167
'
As a proximate result of the Czelusniak Defendants' negligence, the White
Family has suffered emotional distress.
168. As a result of their emotional distress, each of the members of the White
Family has suffered physical harm, as manifested by objective symptomalogy.
169. A reasonable person would have suffered emotional distress under the
circumstances
and facts described above.
110. Czelusniak Funeral Homes is vicariously liable for the negligent acts and
omissions of Mr. Czelusniak.
COUNT XII
Negligence
171. Plantiffs reassert and incorporate herein each and every allegation in the
I9
preceding paragaphs
of this Complaint as if set forth fully in this count of the Complaint.
172. The Czelusniak Defendants owed duties of care to the White Family and the
Estate of Mr. White, Sr.
173. The Czelusniak Defendants breached those duties by failing to act in a
professional
and commercially reasonable manner.
114. These failures included violations of the Code of Massachusetts Regulations
regarding funeral services, including but not limited to violations of 239 C.M.R. 3.13.
175' As a proximate
cause of the Czelusniak Defendants' negligence, the White
Family has suffered damages.
176. Czelusniak Funeral Home is vicariously liable for the negligence of Mr.
Czelusniak.
COUNT XII
Fraud
177. Plaintiffs reassert and incorporate herein each and every allegation in the
preceding paragraphs
of this Complaint as if set forth fully in this count of the Complaint.
178. The Czelusniak Defendants knowingly misrepresented material facts to the
White Family.
179. The White Farnily was induced by the Czelusnak Defendants to rely on and
did rely on the misrepresentations
by the czelusniak Defendants.
180. As a result of the Czelusniak Defendants' misrepresentations ancl the White
Family's reliance on those misrepresentations,
the White Family has suffered damages.
181 . Czelusniak Funeral Home is vicariously liable for the fraud by Mr. Czelusniak.
20
WHEREFORE,
the Plaintif, the White Family, demand that Judgment enter against
the Czelusniak Defendants
on the above claims applicable to such parties and order that the
following damages be awarded:
Compensatory
damages including emotional distress damages;
Injunctive relief;
Reasonable attorneys' fees and costs;
d. Interest; and
e. Such other relief as the Court may deem appropriate.
THE PLAINTIFFS
DEMAND A TRIAL BY JURY ON ALL CLAIMS SO TRIABLE.
The Plaintif
LINCOLN WHITE, JR., ANN
MARIE SAPOWSKY and KIMBERLEE
FELPER, each individually and as personal
representatives of the ESTATE OF
LINCOLN V/HITE, SR.
By Their Attomeys:
Dated: September / 7.ZOt+
BBO No. 552345
Jeffrey E. Poindexter
BBO No. 631922
Elizabeth S. Zuckerman
BBO No. 673190
Bulkley, Richardson and Gelinas, LLP
1500 Main Street
-
Suite 2700
Springfield, MA 01115
Tel: (413) 272-6242
Fax: (413) 272-6803
a.
b.
c.
21
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Received from the Proprietors of The Springfieid Cernetery the crernated
remains of the body of the late:
L
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lot
fu,
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cremated at the Crematory of the Proprietors of The Springfield Cemeterl',
171 Maple St., Springfield, Mass. 01105 Tel.413-732-0712.
lu,tun
g
PLEASE SIGN ACCORDINGLY
of person picking up crematd remains at Springfielcl Cemetery
Name
Final Disposition if known
If shipped via U.S. Maii - please sign and retllrn form immediately - even if
disposition unknown - in the SASE enclosed.
Date
EXFIIBIT A
Funeral Home