Lawsuit Against BCH

On this page, you will find all filings and other associated documents related to the Ten Taxpayer Plaintiff Group's lawsuit challenging Boston Children's Hospital's proposed $1 billion expansion.  Please click the links on the left to see the full document.


Lynch Affidavit Signed with Exhibits


Complaint Signed with Exhibits


Complete Filing to the Health Facilities Appeal Board


Signed Memorandum of law in opposition Children's Hospital Corporation motion to dismiss amended complaint.


Plaintiff's opposition to Children's Hospital Corporation's motion to dismiss amended complaint.


Cover letter for 11.10.16


This is a complaint for declaratory and injunctive relief on account of Defendant Children's Hospital Corporation's, doing business as Boston Children's Hospital, commencement and continuation of construction of a $1.068 billion dollar expansion project without obtaining a Determination of Need from the Massachusetts DPH.


Plaintiff's opposition to defendant Boston Children's Hospital's emergency motion to transfer venue to the business litigation session


Affidavit's of Christine Barensfeld, James E. Coutre, Elliot B. Martin, JR., M.D., Olympia Bowker, Michael J. O'Neill and Plaintiffs' Memorandum of Law in Support of Motion for Preliminary Injunction


Memorandum and Order Denying Request for Preliminary Injunction


Plaintiff's first request for the production of documents from defendant Suffolk Construction Company, INC.


Plaintiff's first request for the production of documents from defendant Children's Hospital Corporation, doing business as Boston Children's Hospital


Letter to Christian Young, Ropes and Gray


Plaintiff's memorandum of law in opposition to defendant Children's Hospital Corporation's motion to dismiss


Plaintiff's opposition to defendant Suffolk Construction Company INC.'s motion to dismiss plaintiff's complaint


Plaintiff's motion to file sur-reply to defendant Boston Children's Hospital's reply memorandum in support of its motion to dismiss


Plaintiff's memorandum of law in opposition to defendant Turner Construction Company's motion for judgment of the pleadings


Plaintiff's opposition to motion for judgment on the pleadings on all counts against Turner Construction Company


Plaintiff's sur-reply to Boston Children's Hospital's reply memorandum in support of its motion to dismiss


Plaintiff's opposition to defendant commissioner, Massachusetts Department of Public Health's emergency motion to dismiss pursuant to rule 12(b) (1)


Memorandum and order on motions to dismiss


Plaintiff's motion to amend complaint


Plaintiff's reply to Boston Children's Hospital's opposition to plaintiff's motion to amend complaint


Notice Clerk's Office Amend Complaint


Rule 9A Plainitiff Motion to Compel Defense to Appear at Deposition - 10.4.16


Plaintiff's motion to compel production of documents from defendant Children's Hospital Corporation