March 20, 2018

“After consultation with counsel, I submitted an amicus brief to the Supreme Judicial Court of Suffolk County in the proceedings related to the Berkshire Museum case held this afternoon. I thought I would share the contents as this is now part of the court record.”


March 10, 2018

Response of the trustees of the Berkshire Museum to BRIEFS OF AMICI CURIAE


March 6, 2018

Response of the Commonwealth of Massachusetts Office of the Attorney General to BRIEFS OF AMICI CURIAE

February 28, 2018

Keating Amicus Curiae Brief. 


February 26, 2018

Brief of Amici Curiae James Hatt, Kristin Hatt, and Elizabeth Weinberg. Nicholas O’Donnell, lawyer for the Hatt party, has filed a brilliant brief to the MA Supreme Judicial Court. It’s a scathing, well-documented indictment of the Museum’s actions and critical of the proposed agreement. It makes a final plea for the Supreme Court: “The AGO specifically promised that, notwithstanding the Museum’s obligation to inform the AGO ahead of time of which other artworks it will sell, it will do nothing about it. Only this Court can stop it now.”  


February 20, 2018

Amicus Brief to the Supreme Judicial Court. The James Hatt party (through their attorney, Nicholas O’Donnell) filed a request to submit an amicus brief by February 27, with the assent of the other parties (the Museum and AGO).


February 15, 2018

Supreme Judicial Court/Motion for leave to file brief in Intervention or,
in the alternative, as amicus curiae


February 9, 2018

Attorney General Maura Healey / Berkshire Museum Final Settlement Summary


January 16, 2018

Attorney General Maura Healey / Commonwealth of Massachusetts
Appeals Court / Appellant Brief


January 16, 2018

Brief of Plaintiffs – Appellants

Please note, relief sought on page 49

V. RELIEF SOUGHT The Museum Members respectfully request that this Court:

1. Reverse the Berkshire Superior Court’s decision dismissing their action;

2. Reverse the Berkshire Superior Court’s denial of the Museum Members’ motion for a preliminary injunction, and enjoin the Museum from any sale or other conveyance of its artwork; and

3. Remand this case to the BLS where it was filed.


January 3, 2018

Berkshire Museum / Attorney General Appellate Brief

​This filing addresses the Berkshire Museum’s challenge that the single appeals court justice cannot grant a delay in the injunction. Attorney General’s Office argues that appellate judge has the right to make the decision.


November 20, 2017

Sullivan and Worcester Filing of Appeal

Members of the Berkshire Museum Appeal Ruling
on Planned Sale of Critical Pieces of its Collection


November 10, 2017

William Lee Opposition to Motion for Injunction Pending Appeal.


November 10, 2017

On Appeal from Berkshire Superior Court Motion for Injunction Pending Appeal