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    <h3 class="title">"Motive & Opportunity"</h3>
    <h4 class="titlesmall">UPDATE: October 25, 2008 </h4>
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<p>I must apologize for the delay in presenting information concerning the "Motive & Opportunity" - of the Mangsen�s and their attorney, Scott S. Sinrich prior to their sudden, unexpected, and deliberate termination of my employment without notice on November 19, 2003. The reason for the delay and change of date for this submission was the surprising (or not so surprising) events of Thursday, October 16, 2008. I shall explain.</p>
<p>While at my residence cleaning the living room in anticipation of the return of my wife, Carolyn, from visiting our daughter and grandchildren in Amsterdam on Friday, October 17, 2008, I heard the front doorbell ring at approximately 4:30PM. As I approached the front door, I said to myself, "What could this be now?" For I have come to expect whenever the doorbell rings unexpectedly, it is either the Massachusetts State Police investigators coming to investigate a frivolous and baseless Criminal Complaint initiated by Atty. Sinrich with the Worcester District Attorney�s Office or just another subpoena (also of a frivolous nature) initiated by the Mangsen�s and Atty. Sinrich in an attempt to limit my First Amendment Right to Free Speech under the U.S. Constitution - thereby necessitating a visit to the Worcester Superior Court.</p>
<p>Well, I was not disappointed for immediately upon greeting a very respectful gentleman, who identified himself as an officer of the court and presented to me his badge of authority, I put out my hand in order to accept a subpoena to appear at the Worcester Superior Court on Monday, October 20, 2008 at 2:00PM. I stated to the Court Officer that I had travel plans on Monday, October 20, 2008; to which he pointed to a phone number to call. Figuring it easier to change my plans rather than disrupt the court system, I opted to appear according to the directive in the subpoena.</p>
<p>Wishing to learn more about the subject matter of this Emergency Preliminary Injunction, I decided to finish vacuuming before sitting down to review and document the essence of the subpoena and its content. About a half hour later as I was having my self prepared evening meal, I read the contents of the subpoena - continuing to shake my head in disbelief as I read each paragraph (some paragraphs more than once) as I made notes as I went along. "Was Atty. Sinrich for real? How could he draw the conclusions he was making from reading the contents of the October 10, 2008 Update on this web site - www.justiceatwhatprice.com? How could the Superior Court, as busy as it must be, feed into the continued shenanigans of Atty. Sinrich and the Mangsen�s?"</p>
<p>Suffice it to say, and without explaining further, the Emergency Preliminary Injunction filed by Atty. Sinrich (Law Offices of Phillips, Silver, Talman, Aframe, & Sinrich, P.C. in Worcester) was denied on Monday, October 20, 2008.</p>
<p>As I now address the subject of this update, <strong>"Motive & Opportunity"</strong>, as it relates to the Mangsen�s and their attorney (Scott S. Sinrich), the information I shall present is clearly in the Public Record of the complete Administrative Proceedings initiated as a result of complaints filed by Katherine Mangsen. (<strong>Please note</strong> - Kurt J. Mangsen, owner and President of Nordgren Memorial Chapel, did not sign the complaints filed by his wife, Katherine, nor did he even read the complaints for accuracy for many months after they were submitted to the Division of Professional Licensure. The complaints were thereby filed by the wife of the owner (Katherine Mangsen); not licensed as a funeral director; not trained or educated in any way in funeral service at the time; and yet she took action in filing three (3) complaints and made statements of fact without verifying the accuracy of the allegations, accusations, or statements).</p>
<p>Frightening as this is (and it is frightening when it comes to unjustly affecting ones livelihood as guaranteed under the U.S. Constitution), it is even more frightening to know the allegations, accusations, and statements made by Mrs. Mangsen had the blessing and concurrence of Nordgren�s corporate attorney, Scott S. Sinrich.</p>
<p>I shall now explain - <strong>"Motive & Opportunity"</strong> as it relates to the Mangsen�s actions leading up to the aforementioned termination stated above. On June 14, 2006 for the 1st time in 937 days since I was personally and viciously verbally attacked before the full State Funeral Board (and in my absence) by the Funeral Board� s former Chairman at the time (John J. Kazlauskas), I testified to the following veritable facts having prepared and displayed charts, securing them to the walls of the Administrative Hearings Conference Room - charts referred to during my day long testimony on June 14, 2006 before Administrative Hearings Counsel  (Colleton), Prosecution Attorneys (Read & Alexander), Nordgren�s Legal Counsel (Godfrey), numerous legal interns at the Division of Professional Licensure, and my wife (Carolyn). </p>
<p>As such, what I am about to share with you is on the public record, in the public record, and available to be seen in explicit detail in the Division of Professional Licensure�s Public Records at 239 Causeway Street, Boston, MA 02114.</p>
<p>Kurt Mangsen, owner of 50% of Nordgren Memorial Chapel�s Class A stock upon the untimely passing of his dad, (Harry Mangsen), became president of Nordgren Memorial Chapel in 1996. It was a well known fact by everyone in funeral service in the Worcester, Massachusetts area that prior to the passing of Kurt�s dad, Kurt had not made funeral arrangements with any family for a variety of reasons. Harry Mangsen, realizing his illness was terminal, confided in me and asked that I educate, protect, and be supportive of Kurt in every way possible. Kurt and I become extremely close as I educated him in dealing with families - continually stressing the point that a family does not get a second chance to say good-bye to a loved one - and as such what we do in support of a family at their time of loss must be nothing short of our very best efforts at all times. So pleased with the association between Kurt and me that Kurt and Katherine Mangsen asked my wife, Carolyn, and me to be God Parents to their newly born son. So comfortable were Kurt and Katherine Mangsen with our association that they asked me to invest $50,000 to help them with the financing of the financial buy-out with their former business partners - the Carrigan�s. So committed to being of assistance to Kurt (and to honor my pledge to Harry Mangsen) that I refinanced my personal residence to generate the $50,000 to give to the Mangsen�s. And as Atty. Sinrich will attest (if he is willing to be truthful), once the $50,000 was in my hands, I couldn�t get it to Kurt and Katherine Mangsen soon enough in order to see the financial transaction to completion.</p> 
<p>Just prior to this period of time, Betty Sander, secretary / bookkeeper / receptionist at Nordgren Memorial Chapel for many years decided to retire. Katherine Mangsen, who now became active in the funeral home as treasurer, with no experience in business, no experience or education in funeral service, decided she wanted to hire a friend, Gail Wiles to replace Betty Sander. Katherine Mangsen asked me to interview Ms. Wiles, which I did having had a fair amount of experience in interviewing and hiring in my prior position in federal service. Although I found Ms. Wiles to be well educated and likeable, I recommended she not be hired for the position as I felt her association and friendship with Katherine Mangsen would compromise and potentially jeopardize that association in day to day workings of the funeral home. Irrespective of my advice, Katherine Mangsen decided to hire Ms. Wiles, which was certainly her prerogative.</p>
<p>Circumstances too numerous to mention in specific detail on this web site, but clearly incorporated in the public record, Ms. Wiles chose totally on her own to modify methods of operation and make policy decisions - all in the name of Kurt Mangsen. When Kurt Mangsen was confronted by me asking for clarification of the policy changes, he expressed no knowledge of the circumstances or changes. Ms. Wiles even went so far as to routinely open mail addressed specifically to me at Nordgren Memorial Chapel time and time again even after I asked her not to - as it had always been the policy at Nordgren Memorial Chapel NOT to open mail specifically addressed to any director. (Testimony of Betty Sander, former secretary / bookkeeper / receptionist - Nordgren Memorial Chapel - August 9, 2006).</p>
<p>As was her prerogative, Mrs. Mangsen continued to come to Ms. Wiles defense in all instances. Soon Ms. Wiles was faxing correspondences to my Westland office against my direction - correspondences that had no association or bearing to Westland. Asked as politely as I knew how, Ms. Wiles chose to ignore my requests and continued to fax documents and correspondences that often would be mixed with confidential correspondences coming to Westland. Suffice it to say there are many more instances wherein Ms. Wiles chose to modify policies and send bills to families within a day or two of the funeral without allowing me as the director to review the bill for completeness and accuracy before sending it out - which had always been the policy of the funeral home for the nine years I had been employed at Nordgren Memorial Chapel. (Testimony of Betty Sander, former secretary / bookkeeper / receptionist - Nordgren Memorial Chapel - August 9, 2006). More on Ms. Wiles later in this update.</p>
<p>With tensions rising, it became evident Katherine Mangsen (and apparently Kurt Mangsen as well) wanted to terminate my employment - at least this is what Mrs. Mangsen testified to during her appearance at the Administrative Hearing at the Division of Professional Licensure - and was attested to by inspector / investigator Bresnahan during his testimony on May 2, 2006. Cautioned by Atty. Sinrich that the Mangsen�s needed to be careful in terminating an employee (testimony of Mrs. Mangsen), there needed to be a valid reason in which to fire an employee.</p>
<p>On July 23, 2003 I received correspondence from Kurt Mangsen (dated July 22, 2003) indicating I needed to sit with Nordgren Memorial Chapel�s accountant, Johanna Higham of Westborough, to discuss my compensation; as it appeared the business I had generated was less than supportive of my salary. I indicated I was going to be on travel, but would get back to Ms. Higham upon my return. On July 25, 2003 (two days later) I was informed by Ms. Higham that my salary was to be stopped immediately based upon her analysis of business I generated. Several weeks later, I presented to Ms. Higham a valid assessment of the business I generated and was able to validate the inaccuracy of her assessment and the unjust decision to terminate by salary with two days notice.</p>
<p>It wasn�t until September 28, 2003 (9 weeks after my salary was stopped without a legal basis upon which to do so) that Ms. Higham, the accountant, admitted her mistake, and I received the 9 weeks pay for which I was entitled. During this 9 week period I worked overtime to the tune of approximately $1,900 - all of which I donated to charities associated with the Orthodox Churches of Central Massachusetts and Holy Trinity Nursing Home of which I was its initial president and founder.</p>
<p>On September 30, 2003 I met with Katherine Mangsen and Ronald Johnson at the request of Mrs. Mangsen. At that time, Katherine Mangsen presented me with an employment agreement that in effect cut my salary by 40%. Obviously, I rejected it on the spot and Mrs. Mangsen indicated if I didn�t like the agreement I could resign at any time.</p>
<p>Immediately, Mrs. Mangsen decided not to renew the Orthodox Calendars and notified the Orthodox Clergy of this fact without first informing me. Mrs. Mangsen, in separate correspondences to me (both dated November 8, 2003) discontinued my cell phone coverage and dental insurance - all in a vein attempt to force me to quit. Because of my commitment and obligation to the Orthodox Community, I would not allow Mrs. Mangsen (or her husband, Kurt) to push me aside.</p>
<p>One would have to be blinded not to see the motive behind the aforementioned actions of the Mangsen�s and their corporate accountant (Ms. Higham). The Mangsen�s <strong>"Motives"</strong> were clear. What was lacking until now was the <strong>"Opportunity"</strong> to make it happen. </p>
<p>What was to happen on November 19, 2003 is purported to have been an unannounced inspection of a half a dozen pre-need funeral arrangement folders at Nordgren Memorial Chapel and other funeral homes in the Worcester area. Ordinarily, this would not be an area of contention; but what was to happen prior to, at, and during a scheduled meeting of the Massachusetts Funeral Board on December 9, 2003 at the Offices of the Division of Professional Licensure in Boston (available for all to hear) would lead a fair minded, impartial, and objective person to question whether or not the so-called unannounced inspection was truly unannounced. Allow me to explain.</p>
<p>On November 19, 2003 John Bresnahan, a former funeral home owner from Northampton, MA and now a six month employee and inspector for the Division of Professional Licensure, visited Nordgren Memorial Chapel, 300 Lincoln Street, Worcester, walked the premises, and asked Gail Wiles, Nordgren�s secretary / receptionist (referenced earlier in this update) for six (6) pre-need corporate funeral arrangement files housed on the premises of the funeral home and under the control of the corporation. One would expect Ms. Wiles would go to the pre-need funeral arrangement file (totally separate from files for funerals that had already been completed), remove six file folders and give them to Mr. Bresnahan as he requested. But not in this case.</p>
<p>Ms. Wiles gave Inspector Bresnahan five - that�s right 5 (not six) pre-need folders, and one (1) completed funeral arrangement file for Mrs. Bahavioulos, a member of the Greek Community in Worcester. Two (2) of the files given to Inspector Bresnahan by Ms. Wiles were families for whom I had made the arrangements, but only one being a pre-need file. The other was the completed funeral file referenced above. </p>
<p><em>(It is important to note at this point that I was not at the funeral home during the inspection on November 19, 2003). </em></p>
<p>The single pre-need funeral file I had arranged for Cynthia Eliopoulos many years earlier, with the funds readily deposited and accurately noted accordingly with Columbian Life Insurance company, was suspiciously missing the Cost of Goods and Services Form; its whereabouts supposedly unknown to the Mangsen�s and Nordgren Memorial Chapel. The remainder of the file was complete.</p>
<p>The other funeral file reviewed by Inspector Bresnahan was the completed funeral file referenced above, which would have had to have been taken from another file cabinet wherein the completed funeral files were located. Here again, suspiciously, the Cost of Goods & Services Form was missing. What is shocking about this revelation was the fact that the family had a refund of $800+ due back to them and the Mangsen�s were attempting to retain for themselves and their funeral home the $800+ owed back to the family after Nordgren Memorial Chapel had been paid their full and complete costs for their service fees, merchandise fees, and cash disbursements. </p>
<p>When a funeral is completed, the completed funeral file is given to the secretary / bookkeeper (in this case Ms. Wiles) with directions clearly marked on the Cost of Goods and Services Form for actions required, payments remaining to be made, and billing as appropriate. For the Cost of Goods and Services Form to be missing - as in the case of Mrs. Bahaviolos (referenced above) is a corporate matter to be resolved at the corporate level - or one would think this would be the case.</p>
<p>Seizing on this supposed unexpected <strong>"Opportunity"</strong>, with the <strong>"Motive"</strong> perfectly clear as alluded to above, Atty. Sinrich swung into action, prepared a letter of termination of "Yours Truly" (Haddad), delivered the letter of termination to Kurt Mangsen for signature, presented it to Constable William George (a life-long friend of mine), who served me with the Letter of Termination - all happening within 5 hours after Inspector Bresnahan supposedly performed an unannounced inspection at Nordgren Memorial Chapel. </p>
<p>As a director, investor, and a minority owner of the funeral home (Nordgren Memorial Chapel), one would expect corporate counsel for the funeral home to seek answers to the suspicious circumstances concerning the missing paperwork from everyone who had access to the files; culminating in a written response and explanation to the inspector and Massachusetts Funeral Board by the Nordgren Memorial Chapel corporation- especially in light of the fact that ultimate responsibility for the retention and maintenance of the files resides with the corporation.  </p>
<p>Not in this case, for we had parties with a <strong>"Motive"</strong> - <u>the Mangsen�s!</u>   Not in this case, for the Mangsen�s now had the <strong>"Opportunity"</strong> they were looking for (whether known to the Mangsen�s and their attorney in advance or not - although what I shall share with you in a subsequent update will add even more doubt as to whether the supposed inspection was truly unknown to the Mangsen�s in advance). Not in this case, for the Mangsen�s had an attorney (Scott S. Sinrich) ready, able, and certainly willing to participate in focusing attention away from his corporate clients for the failings of their corporation and casting "Yours Truly" (Haddad) as the villain.</p>
<p>An impartial, fair, objective, non-biased, and non-prejudiced inspector and Funeral Board would have seen through this charade with blinders on; but when you are part and parcel of/to the conspiracy, you act with perceived powers believing you can get away with anything and certainly not be held accountable for your actions.</p>
<p>Hence, the <strong>"Motive"</strong> was clear. The Mangsen�s and their attorney were prepared to do anything and say anything - so long as the end result saw "Yours Truly" (Haddad) denied the opportunity to practice as a funeral director - even during the 19 months from the date of the Order to Show Cause to the commencement of the Administrative Hearings.</p>
<p><strong>"Motive & Opportunity!"</strong></p>
<p><strong>"Denial of Due Process!"</strong></p>
<p><strong>"Violation of my Constitution Rights!" -</strong></p>
<p>and I have barely scratched the surface of what I shall be sharing with you and the thousands of visitors to the web site www.justiceatwhatprice.com. </p>
<p><strong><u>Next Update</u> - November 3, 2008: Subject-John J. Kazlauskas, Chairman, Massachusetts Funeral Board - 2003 ("Neutral & Detached" or "Co-Conspirator") His "Motive" & Created "Opportunity"</strong></p>


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