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    <h3 class="title"><a name="top"></a>Update-September 16, 2005</h3>
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    <p class="title">As promised in the September 6, 2005 Update, the following 
      is the first of many complaints to be filed with the State Board of Registration 
      of Funeral directors and Embalmers and with the Commonwealth of Massachusetts. 
      It is a fact the complaints are and will be ugly and offensive to many as 
      you read them, BUT let me assure you, each and every complaint is true, 
      factual, and supportive by documents in my possession. The documents referred 
      to have been referenced in updates dating back to April 2005 in web site 
      www.justiceatwhatprice.com., and shall soon be shared with the media as 
      appropriate for &#8220;Justice to be Served&#8221;.</p>
    <p>What I present today and will continue to present weekly for as long as 
      it takes to air the truth in its totality is that which has been presented 
      and disregarded as &#8220;irrelevant&#8221; by a prejudiced, biased, and 
      corrupt group of individuals posing as guardians of the public trust. I 
      realize these are very profound words, but so to is the blatant disregard 
      for a fair and open investigation of malicious allegations that have their 
      foundation in corrupt remarks and statements made by funeral directors in 
      central Massachusetts with personal agenda&#8217;s lacking professional 
      ethics and yet using their sphere of influence for their personal gain. 
      Add to this a series of statements and actions by State appointed officials 
      that have been instrumental in corrupting &#8220;The Process&#8221; and 
      you have the issues presented on this web site in past updates and which 
      now shall be read and stated publicly in the media.</p>
    <p>As I have stated from the outset, &#8220;Character Assassins&#8221; need 
      be identified for who and what they are, rooted out, and held accountable. 
      To this result, I am committed.</p>
    <p>The following complaint was filed with the State Board on Tuesday, September 
      6, 2005 and is a public document. The attachments are referenced here, but 
      were presented in total with the complaint. A second complaint was filed 
      with the State Board on Tuesday, September 13, 2005 and will be presented 
      on this site as the next update on September 23, 2005.</p>
    <div class="insert">
	  <p><strong>COMPLAINT</strong></p>
    <p>This complaint is filed against Kurt J. Mangsen, president, Nordgren Memorial 
      Chapel, 300 Lincoln Street, Worcester, MA and Katherine Mangsen, Treasurer, 
      Nordgren Memorial Chapel for attempting to intentionally defraud Mrs. Katherine 
      Ganias, daughter of Mrs. Bahaviolos who passed away on November 9, 2003 
      of a refund promised to her by Philip G. Haddad, Jr., the funeral director 
      making the pre-arrangements and the funeral director, who directed the funeral 
      and also an owner of Nordgren Memorial Chapel.</p>
    <p>The circumstances: Mrs. Ganias, the only child of the late Mrs. Bahaviolos 
      (mother and daughter were extremely close), made pre-need funeral arrangements 
      for her mother on October 2, 2003. Previously, Mr. Haddad had arranged for 
      and directed Mr. Bahaviolos&#8217;s funeral at Caswell-King Funeral Home, 
      where he was employed at the time. Mrs. Ganias wished to have the same casket 
      for her mother that she had selected for her father, with the only change 
      potentially being the interior being velvet instead of a crape material. 
      Mrs. Ganias wanted to make the final decision at the time of the passing 
      of her mother with her daughters present. As the director, I estimated the 
      cost of the casket with the velvet interior and indicated to Mrs. Ganias 
      that if she chose not to select the casket with the velvet interior at the 
      time mom passed, I would refund to her the balance in full. At that time, 
      I indicated to Mrs. Ganias that if mom was not on Medicaid, she could use 
      the refunded monies to pay toward the Mercy Meal &#8211; a tradition in 
      the Orthodox Community. Mrs. Ganias paid in full for the pre-need funeral 
      the sum of $9,669.75 on October 3, 2003.</p>
    <p>Mrs. Bahaviolos passed unexpectedly 37 days later. The visiting hours and 
      funeral went perfectly as planned. Mrs. Ganias, with the assistance of her 
      children, chose the very same casket as was used for her father years earlier; 
      necessitating a refund to Mrs. Ganias of $800.00. Mrs. Ganias chose not 
      to utilize the limousine she had originally selected, since the Mercy Meal 
      was going to be held in Sutton, Massachusetts &#8211; a good distance from 
      where the burial was to take place. Mrs. Ganias did ask me to arrange for 
      the marking of the monument with the proper inscription for her mother. 
      This was completed and all paperwork was signed by Mrs. Ganias the morning 
      of the funeral and given to Mrs. Gail Wiles, secretary and bookkeeper at 
      Nordgren Memorial Chapel in the presence of Mrs. Ganias. On the Cost of 
      Goods and Services Form was attached a breakdown of the actual expenses 
      and the total adjustments with a refund due Mrs. Ganias at this point of 
      $867.98, with the comment to verify the final amount received from Columbian 
      Life Insurance Company before issuing the refund.</p>
    <p>On November 19, 2003, Mr. John Bresnahan, investigator, State Board visited 
      Nordgren Memorial Chapel and was given the completed Bahaviolos file to 
      review. At that time, the Cost of Goods and Services Form was &#8220;strangely&#8221; 
      missing. Six (6) hours later I was abruptly terminated without notice by 
      Kurt Mangsen, president, Nordgren Memorial Chapel.</p>
    <p>Weeks passed and Mrs. Ganias did not receive the refund due her. Mrs. Ganias 
      contacted me on Tuesday, December 30, 2003 at 8:00 PM, and I indicated to 
      Mrs. Ganias I was terminated by Nordgren&#8217;s unexpectedly and that she 
      should contact Mrs. Wiles and Kurt Mangsen, if necessary, and demand the 
      refund due her. This was done without a resolution, and Mrs. Ganias contacted 
      me once again on January 17, 2004 at 4:30 PM; this time extremely emotional. 
      She had just lost her mother. She was the only child and life long care 
      giver to her mother. She paid handsomely for the funeral services of her 
      dad years ago and now her mom, and she was being deprived of the refund 
      she was promised and rightfully due her. I had no satisfactory answer for 
      her, and I indicated I would contact Nordgren&#8217;s attorney. (see attachment 
      dated January 19, 2004).</p>
    <p>Nordgren Memorial Chapel had received their FULL SERVICE CHARGE, the handsome 
      profit from the mark up of the casket and vault, and all cash disbursements, 
      and still attempted to retain that which had been promised to the family 
      by me &#8211; the funeral director, an owner, and extremely close friend 
      to this wonderful family. The priest at St. Spyridon Greek Orthodox Cathedral, 
      also a close friend of the Ganias Family and the clergyman conducting the 
      funeral, offered to intervene. I indicated to Fr. Dean Paleologos, I would 
      handle the matter, and if unsuccessful, I would get back to him for assistance.</p>
    <p>Greed has consumed the Mangsen&#8217;s and Nordgren Memorial Chapel, and 
      since my abrupt departure, the Bahaviolos Family is but one of several families 
      that have been mistreated by Nordgren Memorial Chapel in an attempt to defraud 
      the family of monies due them.</p>
    <p>I contacted the Attorney General&#8217;s Office of Consumer Affairs on 
      behalf of Mrs. Ganias and was advised to contact the Better Business Bureau 
      with all the facts and a statement from me as the funeral director of record. 
      I was also advised that if the BBB was unable to resolve the matter, that 
      Mrs. Ganias and I should return to the A.G.&#8217;s office and that they 
      would actively deal with the matter. (see attachments).</p>
    <p>The matter was resolved almost two &amp; one-half months after the passing 
      of Mrs. Bahaviolos, but the pain and hurt experienced by Mrs. Ganias and 
      her family, in addition to the loss experienced by the passing of her mother, 
      will never ever completely go away. Neither will the distain the family 
      has for Nordgren Memorial Chapel and the funeral industry as a whole. The 
      Ganias Family is extremely well known in the Greek Orthodox Community and 
      the damage done by the greed of the Mangsen&#8217;s will prominently remain 
      for years to come.</p>
    <p>One can only be suspect to find the Cost of Goods &amp; Services Form missing 
      from the completed funeral file of Mrs. Bahaviolos; while the Mangsen&#8217;s 
      and Nordgren Memorial Chapel attempted to defraud the family of that which 
      was due them and promised to them. HOW VERY SAD!</p>
    <p>Respectfully,</p>
    <p>Philip G. Haddad, Jr.<br>
      9 Kenwood Avenue<br>
      Worcester, MA 01605-1321</p>
    <p>Exhibits Attached:</p>
    <ul>
	<li>1. December 31, 2003 Correspondence &#8211; Mrs. Ganias to Mrs. 
      Mangsen<br>
    <li># 2. January 19, 2004 Correspondence &#8211; Philip G. Haddad, 
      Jr. to Nordgren Memorial Chapel thru Legal Counsel<br>
    <li># 3. January 31, 2004 Correspondence &#8211; Mrs. Ganias to Better 
      Business Bureau of Central Massachusetts<br>
    <li># 4. January 31, 2004 Correspondence &#8211; &#8220;To Whom It 
      May Concern&#8221; from Philip G. Haddad, Jr. to Better Business Bureau 
      of Central Massachusetts<br>
	</ul>
    <p>* c.c.<br>
      Governor Romney Lt. Governor Healey<br>
      Atty. General Reilly Gregory Sullivan, I.G.</p>
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    <p><strong>Next Update &#8211; Friday, September 23, 2005</strong></p>
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