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    <h3 class="title"><a name="top"></a>Update-September 23, 2005</h3>
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    <p class="title">As indicated in previous updates, I am presenting recent 
      complaints I have filed with the State Board of Registration of Funeral 
      Directors and Embalmers against co-conspirators in a vial attempt to make 
      vicious and malicious accusations and allegations against me in order to 
      deprive me of my license to practice as a funeral director and ability to 
      be of service to you. In so doing, the conspirators can, and have thus far 
      been successful in, taking families and business I have served for years 
      away from me.</p>
    <p>The following complaint was filed on September 12, 2005 against Kevin L. 
      Mercadante, Mercadante Funeral Home &amp; Chapel, 370 Plantation Street, 
      Worcester, MA with the State Board of Registration of Funeral directors 
      and Embalmers.</p>
    <div class="insert">
	  <p><strong>COMPLAINT</strong></p>
    <p>This complaint is being filed against Kevin L. Mercadante, owner of Mercadante 
      Funeral Home and Chapel, 370 Plantation Street, Worcester Massachusetts, 
      based upon information provided in Order to Show Cause issued to Philip 
      G. Haddad, Jr., 9 Kenwood Avenue, Worcester, Massachusetts by Ms. Kathy 
      Cartmell-Sirrico, Chairperson, Board of Registration of Funeral Directors 
      and Embalmers dated June 29, 2004.</p>
    <p>I allege Mr. Kevin L. Mercadante, (license # 5985) made false, malicious, 
      and intentional defaming statements, known to be lies and distortions at 
      the time and to this day, in a desperate effort to secure funeral business 
      that typically was funeral business served by Philip G. Haddad, Jr. for 
      more than 23 years to investigator, John Bresnahan.</p>
    <p>The specific complaint issued is based upon item number 12, EM-04-124, 
      page 2 of the Order to Show Cause which reads:</p>
      <p><strong>&#8220;On at least one occasion after your termination from Nordgren 
        Chapel you attempted to enter into a financial arrangement with a licensed 
        funeral home for the purpose of referring pre-need customers to the funeral 
        home in return for a portion of the revenue from the pre-need accounts&#8221;</strong></p>
    <p>After more than nine (9) + months of &#8220;shadow boxing&#8221; with the 
      State Board and the Division of Professional Licensure, in an attempt to 
      obtain the name, address, date, time, and a copy of the signed statement(s) 
      made by the funeral director alleging the aforementioned accusation, the 
      name of Kevin Mercadante, owner of Mercadante Funeral Home was finally released 
      to Daniel Flynn, Esq., Bowditch &amp; Dewey, LLP, representing Philip G. 
      Haddad, Jr.</p>
    <p>Ms. Helen Peveri, Executive Director, reluctantly released Mr. Mercadante&#8217;s 
      name, but nothing more on April 14, 2005; almost ten (10) months after the 
      Order to Show Cause was issued to Philip G. Haddad, Jr. Further information 
      as to date, time, who was present at the time Mr. Mercadante is alleged 
      to have made the statements, and a signed copy of the statement made by 
      Mr. Mercadante, alleged to be factual by Ms. Cartmell-Sirrico&#8217;s Order 
      to Show Cause dated June 29, 2004 does not exist. (See Exhibit # 1 dated 
      April 25, 2005 and Exhibit # 2 dated May 27, 2005).</p>
    <p>In conversations with Leslie D. Alexander, Esq., Counsel, Division of Professional 
      Licensure, Daniel Flynn, Esq., Counsel to Mr. Haddad was told by Atty. Alexander 
      that if Mr. Haddad wished to obtain the statement made by Mr. Mercadante, 
      he could interview Mr. Mercadante himself. (See Exhibit # 3 from Daniel 
      Flynn, Esq. to Anne E. Colleton, Administrative Hearings Counsel, Subject: 
      Philip G. Haddad, Jr.&#8217;s Opposition to Prosecuting Counsel&#8217;s 
      Cross-Motion to Compel Discovery dated July 5, 2005). Ms. Anne E. Colleton 
      denied the motion to release statements made by Mr. Mercadante, since no 
      statements apparently exist. (See Exhibit # 4 dated July 5, 2005).</p>
    <p>It is my contention, and I will prove it factual when I cross-examine Mr. 
      Mercadante in the presence of and also when I examine the Very Rev. Fr. 
      Michael Abdelahad, pastor St. George Orthodox Cathedral, 30 Anna Street, 
      Worcester, Massachusetts at the Show Cause Hearing, that Mr. Mercadante 
      made the false and misleading statement(s) to Mr. Bresnahan in, what has 
      been, a successful attempt to capture families within the Orthodox Community 
      served by Philip G. Haddad, Jr. for more than 23 years by defaming Philip 
      G. Haddad, Jr. to the State Board investigator.</p>
    <p>I believe, and shall prove, Mr. Mercadante to be one of several willing 
      participants to this charade, but for the purposes of this complaint, I 
      state the following premise from the regulations upon which the aforementioned 
      complaint is filed.</p>
    <p>I believe Mr. Mercadante violated Code of Conduct and Professional Ethics 
      according to paragraph 3.13 (20), &#8220;Persons registered with the Board 
      (Mr. Mercadante is registered with the Board # 5985) and persons who hold 
      an ownership interest in or are employed by any funeral establishment licensed 
      by the Board, shall &#8230; refrain from disparaging or defaming competitors 
      with respect to &#8230; professional reputation.&#8221;</p>
    <p>Respectfully,</p>
    <p>Philip G. Haddad, Jr.<br>
      9 Kenwood Avenue<br>
      Worcester, MA 01605</p>
    <p>c.c. Governor Romney<br>
      Lt. Governor Healey<br>
      Attorney General Reilly<br>
      Gregory Sullivan, I.G.</p>
	</div>
    <p>The following is a list of exhibits that were included along with the complaint 
      and for the purposes of this presentation are incorporated as references.</p>
    <ul>
	<li>Exhibit # 1. April 25, 2005 Correspondence &#8211; Daniel Flynn, Esq. 
      to Leslie Alexander, Esq.<br>
    <li>Exhibit # 2. May 27, 2005 Correspondence &#8211; Daniel Flynn, Esq. to 
      Leslie Alexander, Esq.<br>
    <li>Exhibit # 3. July 5, 2005 Correspondence &#8211; &#8220;Philip G. Haddad, 
      Jr.&#8217;s Opposition to Prosecuting Counsel&#8217;s Cross-Motion to Compel 
	  Discovery&#8221; from Daniel Flynn, Esq. to Anne E. Colleton<br>
      <li>Exhibit # 4. July 5, 2005 Correspondence &#8211; &#8220;Board ruling on 
        Philip G. Haddad, Jr.&#8217;s Motion for Order Compelling Answer to Interrogatory 
        # 11.&#8221; From Anne E. Colleton to Daniel Flynn, Esq.
</ul>
    <p><strong>The next update, scheduled for September 30, 2005, will include 
      complaint # 3. along with additional information presently being compiled.</strong></p>
    <p>Philip G. Haddad, Jr.</p>
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