YOUR NAME
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In Pro Per

COMMONWEALTH OF MASSACHUSETTS

TRIAL COURT

NAME OF PLAINTIFF,
Plaintiff,
vs.
NAME OF DEFENDANT(s),
Defendant(s)

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Case No.:
MEMORANDUM IN SUPPORT OF
APPELLANT’S MOTION TO WAIVE
APPEAL BOND AND OTHER COSTS

NOW COMES Appellant, and files this Memorandum in Support of Appellant’s Motion to Waive
Appeal Bond and Other Costs, and for cause would show this Honorable Court as follows:

A. APPELLANT HAS A MERITORIOUS CLAIM AGAINST APPELLEE
Fraudulent eviction, in the context of this case, pertains to the wrongful or unlawful
dispossession of a tenant from their premises through deceptive or fraudulent means. Appellee engaged
in misconduct by failing to follow proper legal procedures, namely the filing of the codicil, to justify the
eviction.
In the eviction process, adherence to legal procedures is paramount to ensure justice, fairness,
and the protection of tenants’ rights. The codicil, in particular, serves as a critical document that outlines
the reasons and justifications for eviction, and its omission can lead to unjust consequences.

MEMORANDUM IN SUPPORT OF APPELLANT’S MOTION TO WAIVE APPEAL BOND AND

OTHER COSTS – 2

It is incumbent upon landlords, such as the Appellee, to provide tenants with a codicil that details
the grounds for eviction. This codicil must be filed to ensure transparency and accountability in the
eviction process.
Appellee failed in their legal obligation to file the codicil. The absence of the codicil not only
deprives the tenant of crucial information but also raises questions about the Appellee’s intent and the
validity of the eviction.
The failure to file the codicil denies the Appellant due process of law, a fundamental right
enshrined in our legal system. It deprives the Appellant of the opportunity to understand the grounds for
eviction and to prepare a proper defense.
The absence of the codicil also raises suspicions of fraudulent conduct by the Appellee. It opens
the door to the possibility that the eviction may be motivated by ulterior motives rather than legitimate
reasons, thus casting doubt on the Appellee’s actions.
Allowing the eviction to stand without the proper filing of the codicil would result in manifest
injustice and inequity. It would set a dangerous precedent, signaling that landlords can act with
impunity, disregarding essential legal safeguards.
In light of the Appellee’s failure to file the codicil, a clear violation of legal obligations, the
Appellant possesses meritorious grounds for their appeal. This failure not only undermines due process
but also raises serious questions about the legitimacy of the eviction. It is incumbent upon this honorable
court to uphold the principles of justice and fairness by granting the appeal and affording the Appellant
the opportunity to contest their eviction on proper legal grounds.

B. APPELLANT IS UNABLE TO PAY THE APPEAL BOND AND OTHER COSTS
Appellant has been compelled to file this Motion to Waive the Appeal Bond due to his profound
financial hardship. At the core of this issue lies Appellant’s undeniable inability to pay the appeal bond
and other associated fees.
Appellant is facing an extraordinary financial predicament. This hardship is not a product of
negligence or financial mismanagement but stems from the fact that he does not have funds to pay the
appeal bond and other costs.

MEMORANDUM IN SUPPORT OF APPELLANT’S MOTION TO WAIVE APPEAL BOND AND

OTHER COSTS – 3

The appeal bond, as well as the myriad of associated fees, represents a substantial financial
burden that Appellant is simply unable to bear. The appeal bond, in particular, is often a significant sum,
and the cumulative costs of attorney fees, court fees, transcript fees, and other legal expenses only
compound this burden.
Crucially, Appellant lacks the financial cushion or extra income that could be tapped into to
fulfill these obligations. His current financial resources are wholly insufficient, not only to cover the
appeal bond and associated costs but also to meet his basic living expenses and obligations.
It is essential to recognize the profound injustice that would befall Appellant if he were
compelled to pay the appeal bond and related fees despite his inability to do so. Such a situation would
effectively deny him access to justice, as he would be excluded from pursuing his appeal solely due to
financial constraints.
While the legal system rightly imposes certain financial obligations to protect the interests of all
parties involved, it must also acknowledge and address cases where individuals, like Appellant, find
themselves in a position of genuine financial distress, making compliance with these obligations an
insurmountable challenge.

C. THERE IS A RISK OF INJUSTICE TO APPELLANT IS THE REQUESTED WAIVER IS

NOT GRANTED

The risk of injustice looms large in this case should the waiver of the appeal bond not be granted
to Appellant.
Fundamental principles of due process are at stake if Appellant is unable to pursue his appeal.
Due process is a cornerstone of our legal system, ensuring that individuals have a fair opportunity to
present their case and be heard. Denying Appellant this opportunity solely due to financial hardship
would be a grave miscarriage of justice.
The denial of a waiver based on financial constraints alone would ignore the merits of
Appellant’s case. Regardless of the strength or weakness of his appeal, justice demands that it be heard
and evaluated on its own merits rather than impeded by financial barriers.

MEMORANDUM IN SUPPORT OF APPELLANT’S MOTION TO WAIVE APPEAL BOND AND

OTHER COSTS – 4

Justice must be blind to one’s financial status. Denying Appellant the waiver would create a
disturbing inequity in access to justice, suggesting that the ability to pay takes precedence over the
principles of fairness and equal treatment under the law.
Granting the waiver of the appeal bond is not merely a matter of individual justice; it serves the
broader public interest. It upholds the integrity of our legal system and ensures that it remains accessible
to all, irrespective of their financial means.

D. APPELLANT WILL COMPLY WITH ALL WAIVER CONDITIONS IMPOSED BY THE

COURT AS WELL AS ALL OTHER DEADLINES

Appellant emphasizes his unwavering commitment to comply with any conditions or
requirements set by the court upon the grant of the waiver of the appeal bond. This commitment
underscores his seriousness and respect for the legal process.
Appellant fully comprehends the importance of compliance with any conditions imposed by the
court. He is aware that these conditions are designed to safeguard the interests of all parties involved and
maintain the integrity of the legal process.
He pledges to diligently adhere to all conditions and requirements, ensuring that he meets all
deadlines and obligations in a timely manner. Appellant is committed to respecting the court’s schedule
and deadlines.
Appellant acknowledges the court’s authority to impose conditions and trusts the court’s
judgment in determining the necessary measures to ensure fairness and justice in this case.
Appellant wants to assure the court that he will promptly file all necessary documents and
responses related to the appeal. This commitment reflects his dedication to upholding the legal process.
He recognizes that it is his responsibility to submit all required documents and responses in a timely
manner. Appellant is committed to fulfilling this responsibility diligently.
Appellant has great respect for the legal procedures and the court’s expectations regarding the
timely filing of documents and responses. He will do everything within his power to adhere to these
procedures and meet all deadlines.

MEMORANDUM IN SUPPORT OF APPELLANT’S MOTION TO WAIVE APPEAL BOND AND

OTHER COSTS – 5

Should there be any uncertainties or questions regarding the submission of documents or
responses, Appellant is open to seeking guidance from the court or legal counsel to ensure compliance
with all requirements.

E. PRAYER FOR RELIEF

In light of Appellant’s inability to pay the appeal bond and associated fees, the grave risk of
injustice that he faces, his unwavering commitment to comply with court conditions, and his dedication
to timely filing all necessary documents and responses related to the appeal, this court is respectfully
urged to grant the waiver of the appeal bond. Doing so would not only uphold the principles of justice
and fairness but also ensure that the legal process remains accessible to all, regardless of their financial
means.
Appellant earnestly requests that this honorable court consider the compelling circumstances he
faces and grant the waiver as an act of justice and equity.

ssssssssssssssssssssssss
Dated this 12 th day of September, 2023.

Respectfully Submitted,

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Appellant in pro per

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