Eric B.

Batista City of Worcester

City Manager

May 27. 2025

VIA HAND SERVICE

Mr. David Webb

458 Park Avenue
Worcester, MA 01610

NO TRESPASS ORDER - CITY HALL

Dear Mr. Webb:

It has been brought to my attention that you have repeatedly engaged in behavior which
constitutes a violation of the Worcester City Hall Conduct Policy (“Conduct Policy”), attached
hereto. You have also consistently visited several City Hall offices, making employees feel
uneasy and fearful.
On an ongoing basis you have approached individuals within City Hall, including in the non-public
workspace of employees, in an intrusive and aggressive manner, and you persist in this behavior
in spite of these individuals’ requests that you stop. On multiple occasions over the past several
months you have engaged in inappropriate behavior directed at City Hall employees including
intimidating behavior such as following employees around with a camera and phone inches away
from their face asking them for “comments”; repeatedly going to the Human Resources
Department asking for a copy of the Conduct Policy, even though you have been given a copy,
interrupting employees and districting them from working; jumping in front of an employee’s
vehicle prohibiting them from moving their vehicle and exiting the garage while shouting at them
and recording the employee and their vehicle: repeatedly visit certain departments,’ such as the
Clerk’s Department where you shout from the customer service counter in an intimidating manner
so that the Clerk or Deputy Clerk conic out and speak to you, disrupting the workplace
environment and interfering with City employees’ ability to perform their job duties.
City Hall staff have repeatedly requested that you refrain from these behaviors and after multiple
requests, you have not complied. You have been advised of the behavioral expectations and the
Conduct Policy, and in fact you have been given the full Conduct Policy in response to a public
records request you made on April 11. 2025. attached hereto; however, you have continued to
engage in such disruptive and intimidating behavior continuously requesting records you have

Human Resources, Law Department, CiEy Manager’s Office, and Clerk’s Office
City of Worcester • 455 Main Street . Worcester, MA 01608-1892
Office: 508—799-1175 Fax: 508—799-1208 . WorcesterMa.gov
 Eric B. Batisla City of Worcester
City Manager

Webb
No Trespass Order
Page 2 of 5

already received, in bad faith.2 You have also continuously emailed several City offices, including
individual employees, repeating the same requests/content and continue to engage in ulmecessary,
and at times vulgar, conversation when you receive a response, so much that you have made
employees uneasy and fearful and have severely hindered them from performing their job duties
as a result of the constant barrage of email communications.
You are aware of the proper methods to request information, make public records requests, and
file open meeting law complaints, however you continue to send repetitive and frivolous email
communications, including in the email communication several City employees, many of whom
have no involvement in the subject matter of your email.3 This repetitive, frivolous behavior has
amounted to harassment. In the last tweLve (12) months you have sent 502 emails directly to the
City Solicitor; 478 cmaiLs directly to the City Manager’s Chief of Staff; 370 emails directly to
the City Clerk; 209 emails directly to the Deputy City Clerk; 1071 to the Public Records Access
Officer; and 912 emails to the Assistant City Solicitor Supervisor of Records.4 The
—

departments of the aforementioned employees all have general email accounts which are
intended to be used by the public for any inquiries. The direct contact, blind copying, and
copying of several employees on most matters has become harassment and is severely hindering
the ability of City employees to provide efficient services and perform job duties.

2
MGi. Chapter 66. Section IO(c)
For example, you blind copy the City Solicitor on every email, including emails to the State regarding the
repossession of your car. You include the Director of Administration & Operations of the Law Department on many
emails as you do the Deputy City Clerks and the Chief of Staff for the City Manager’s Office, none of whom have
control over the subject matter of your email, rather the hundreds of emails sent by you are clogging the inbox of
these employees severely hindering the performance of theirjob duties.
‘A search of the Department of Innovation and Technology yielded the following results:
City Solicitor, Alexandra Kalkounis Kalkounisa@worcesterma.gov -502
Chief of Staff, Amy Peterson Petersona@worcesterma.gov -478
City Clerk, Nikolin Vangjeli Vangielin@worcesterma.gov -370
Deputy City Clerk A.) Pottle Pottlea@worcesterma.gov -209
Deputy City Clerk Clare Robbins Robbinsc@worcesterma.gov -60
Assistant Commissioner Robert Antonelli AntonelliRworcesterma.gov -100
Records Access Officer, Michael Vigneux VigneuxMworcesterrna.gov -1071
Assistant City Solicitor, Janice Thompson thompsonjworcesterma.gov -912

City of Worcester • 455 Main Street Worcester, MA 01608-1892

Office: 508—799-1175 . Fax: 508—799-1208 • WorcesterMa.gov
 Eric B. Batista City of Worcester
City Manager

Webb
No Trespass Order
Page 3 of 5

In the last twelve (12) months you have filed 305 public records requests. The City’s Public
Records Division has closed out 278 of those requests, with 27 current open requests, resulting in
91% of your requests being resolved and closed. Yet, you continue to email and physically
appear at City Hall to intimidate and threaten employees. These requests, individually and “as
part of a series of requests” are “frivolous or intended to harass or intimidate the agency or
municipality.” M.G.L. c. 66 § I 0(c)(v). Moreover, you continue to appeal the City responses
irrespective of the legality and/or appropriateness of such an appeal.
You have filed at least twelve (12) Open Meeting Law complaints pursuant to M.G. L. chapter
30A, § 20, many of them frivolous and not within the parameters of the Open Meeting Law. You
have filed such complaints alleging violations of the law even after having been informed they
are not appropriate as Open Meeting Law complaints. Each complaint must go before the public
body in an open meeting and requires an investigation by City staff and response by the Law
Department, taking considerable time and effort.

You continuously target your behavior at individual employees, such as fraudulently signing up
the City Clerk and City Councilor for anti-discrimination training provided by the City of Boston
for its employees, email communication attached hereto. You target individual employees by
putting their email on social media and directing the public to flood email inboxes.5 You follow
city employees around during the workday and take pictures of them with the purpose of public
shaming, targeting and intimidation.6

Your outrageous behavior has disrupted the orderly proceedings of boards and commission
meetings and City Council meetings and caused anxiety for City Councilors and the City
employees and members of the public attending such meetings. You have disrupted several City
Council meetings and violated the Conduct Policy by taping signs on the interior of the Esther
Howland Chambers. In April, the Chair of the Public Works Committee had to abruptly end the
public meeting due to your disruption and refusal to leave. Most recently, at a Board of Elections
Commission meeting, you approached the table where City employees were sitting, shining the
flash of your camera inches away from an employee’s eye and installing your camera on the
table within inches of the City employee. This behavior has caused employees to feel uneasy and
fearful.

While not the basis of this letter, it should be noted that you also recently put a Worcester Police Officer’s home
address and cell phone number on social media due to his response to the Eureka Street incident.
6
You have followed the Assistant Commissioner of Parks and Recreation around on the weekends and then sent a
barrage of ernails related to his city vehicle.
City of Worcester • 455 Main Street . Worcester, MA 01608-1892
Office: 508—799-1175 . Fax: 508—799-1208 • WorcesterMa.gov
 Eric B. Batista City ofWorcester
City Manager

Webb
No Trespass Order
Page 4 of 5

This is to advise you that you must cease this obsessively harassing behavior. This pattern of
behavior is unacceptable. It creates a disquieting and unsafe environment for individuals in and
around City Hall. As a result, I am compelled to serve you this NO TRESPASS ORDER, under
the authority of G.L. c. 266, § 120, for a period of one year beginning on May 27, 2025. During
that time, you are banned from using Worcester City Hall building, and any offices therein, and
areas immediately adjacent thereto, including the garage, porticos, entryways, paths of ingress and
egress including exterior stairways, the front and rear plazas, and sidewalks surrounding the
building and designated for City Hall purposes.
You are hereby further ORDERED TO CEASE AND DESIST emailing individual City
employees. You shall hereby communicate any inquiries, needs, requests, through each
department’s general email intended for such inquiries; such as, Lav@worcesterma.ov;
CitvManager(dworcestermajov; Clerk(äworcesterma.gov, publicrecords(worcesterma.gov;
elections(?Zworcesterma.gov; parksdworcesterma.gov. For a complete list of department emails
please visit the City’s website here: Departments City of Worcester

The behavior described above is also prohibited by G.L. c.265, §43A, the criminal harassment
statute. If the above-referenced behavior continues, the City of Worcester reserves the right to seek
enforcement of the statute as an alternative or in addition to seeking a civil restraining order.

Sincerely,

Eric D. Batista
City Manager

If you believe this order has been issued in error and you wish to appeal this order, you must submit
a written appeal within 10 days after you receive this letter. Any written appeal should include
your name, address, date of this notice, and the information you wish to have considered, and
should be addressed to the Worcester City Manager, Attn: No Trespass Appeal, 455 Main Street,
Worcester, MA 01608.

cc: Worcester Police Department

City of Worcester Law Department

City of Worcester • 455 Main Street Worcester, MA 01608-1892

Office: 508—799-1175 Fax: 508—799-1208 • WorcesterMa.gov
 _____

Edward M. Augustus, Jr.

City Manager
Gin OF WORCESTER

Worcester City Hall Conduct Policy

Whereas the city manager has care, custody and control of City Hall pursuant to the
order of the city council adopted on November 12, 2002, now therefore, to ensure the
safety and rights of all persons who utilize City Hal?, the city manager has established
the following guidelines for behavior and conduct at City Hall.

For purposes of this policy, City Hall includes all spaces within the building located at
455 Main Street, and the outdoor spaces immediately adjacent thereto, including
porticos, entryways, paths of ingress and egress including exterior stairways; as well as
the front and rear plazas and sidewalks surrounding the building and designated for City
Hall purposes.

THE FOLLOWING CONDUCT IS PROHIBITED IN CITY HALL:

• Engaging in any activity in violation of Federal, state, or local law is prohibited.

• Threatening behavior including but not limited to violence, threats of violence.

and possession of weapons (M.G.L., c. 269 § 10).

• Fighting or challenging to fight; pushing or shoving a person, or throwing objects.

• Being under the influence of alcohol and or illegal drugs and selling, using, or
possessing alcohol and or illegal drugs.

• Sexually, verbally, or physically harassing, intimidating, or threatening others; this

includes, but is not limited to, behavior such as stalking, staring, or lurking with
intent to annoy, offensive touching, obscene acts, and indecent exposure. This
also may include, but is not limited to, the use of obscene or abusive language or
gestures.

• Smoking of any kind, including but not limited to the lighting of a cigar, cigarette,
pipe, or other tobacco product or possessing a lighted cigar, cigarette, pipe or
other tobacco or non-tobacco product designed to be combusted and inhaled
(M.G.L. c.270, § 22), chewing and other tobacco use in the building, including
use of all e-cigarettes or any other nicotine delivery devices. Smoking of any

Qfl OFFICE OF THE CiTY MANAGER, CiTY HALL, WORCESTER, MA 01608

TELEPHONE (508) 799-1175 I FAX (508) 799-1208 ti_Ill
Li,
QH EMAiL: ciLymanagerwcrcesterrna.gov
,
 kind, including but not limited to tobacco or non-tobacco products, shall be
prohibited within fifty (50) feet of all municipal building entrance and exit ways,
per City of Worcester Revised Ordinances of 2008, Part One, Chapter 8, Section
3 Tobacco Products Control Ordinance.

• Creating a disturbance by making noise, yelling, or engaging in other disruptive

conduct which could reasonably be expected to disturb other persons.

• Using offensive, obscene or abusive language and or gestures.

• Gambling or group activities that are so disruptive as to interfere with the use and
enjoyment of the facilities by others.

• Stealing, damaging, altering, or inappropriately or illegally using City Hall

property (including furniture, computer hardware and software, printers, copiers,
phones and other equipment); damaging, vandalizing, or defacing City Hall
property, including interior or exterior of the building, in any way, including but not
limited to graffiti.

Rearranging furniture, putting feet up on chairs or tables, sitting on tables and

other inappropriate use of furniture and facilities.

• Entering the building without a shirt or other covering of the upper body or
without shoes or other footwear. Persons whose bodily hygiene is offensive so as
to constitute a nuisance to other persons shall be required to leave the building.

• Bringing animals into the building except those needed to assist persons with
disabilities (M.G.L. c. 272, § 98A)

• Misusing the rest rooms, including using as a laundry, grooming or bathing

facility. Flushing of any materials other than waste and toilet paper is strictly
prohibited.

• Running

• Sleeping

• Littering

• Blocking aisles, hallways, exits, entrances or stairwells

• Spitting (M.G.L. c. 270, § 14)

• Soliciting or canvassing of any kind if conducted in an aggressive or obtrusive

manner. Begging, panhandling or soliciting in an aggressive manner per City of
 Worcester Revised Ordinances of 2008, Part One, Chapter 9, Section 16,
Aggressive Begging, Soliciting and Panhandling.

• Presence in City Hall without legitimate city business or related reason to be in

the facility (as defined below).

• Entering areas posted “Staff Only” without permission, trespassing in nonpublic

areas, or camping on City Hall grounds.

• Using or storing wheeled devices in City Hall, or on City Hall property except in
designated areas, including bicycles, self-propelled tricycles or scooters,
skateboards, roller skates, rollerblades and shopping carts. All bicycles must be
left outside of the building. Wheelchairs, walkers and strollers are welcome.

• Otherwise interfering with another person’s right to use or work at City Hall.

IN ADDITION:

• Use of City Hall is limited to persons having legitimate reason to be present in the
facility. Persons visiting a city department or a tenant of the city located within
City Hall for official business, or attending a public meeting, are examples of
persons presumed to have legitimate reason to be present.

• Those who damage or deface City Hall property will be prosecuted.

• Parents are responsible for the behavior and supervision of their young children.
Parents may be held liable for damage done by a child under 18 (M.G.L. c. 231,
§85G).

• Unattended items (such as bags, backpacks or laptops) may be regarded as

suspicious and removed.

• The city is not responsible for any lost or stolen item.

• All persons must leave promptly when the building is closed. When the building
is open for limited purposes, such as open meetings held after business hours,
persons shall only remain in the building for purposes related to such limited use.

ENFORCEMENT:

Please note the items listed above are not an exhaustive list. City Hall staff or security
may address any other behaviors which interfere with the use and enjoyment of the
facilities by other persons and/or interfere with City Hall staff in the performance of their
duties. Failure to comply with these rules, regulations, and policies may result in
expulsion from City Hall for a period of time, and/or in arrest and prosecution when
applicable. Determinations regarding expulsion will be made based on the severity of
the violation. In addition, law enforcement may be called and appropriate legal action
may follow.

APPEALS:

An individual who has been banned from City I-fall shall have the right to file a written
appeal to the City Manager or designee. The appeal must be filed within ten (10)
calendar days of the date that the individual is notified that the individual is barred from
the premises. The decision of the City Manager shall be final and conclusive.

APPROVED BY THE CITY MANAGER: April

5127/25, 3:50 PM GovOA WORCSTLRMA Marts Wasiewicz
- -

City Pu bNc’Records Request

‘
City Public Records Request Details

Department requesting records

from:

Date/Date Range: current

Describe the Record(s) The unabridged version of city hail rules as referenced at the top of the abridged rules currently posted
Requested: at city hail

Preferred Method to Receive Electronic via Records Center

Records:

“ Clarifications

Enter Clarifications here to be merged into the Clarification Prepared Response.

Clarifications Requested:
Cut & Paste any Clarifications here so they can be viewed on the 1-2-3 Activity

Clarifications Received:

> Department Activity Routing

> Payment Information

> Legal Review Information

> Exemptions

> Notes

V Message History

Date

On 4/11/20252:21:14 PM, David Webb wrote:

TO: “Worcester Public Records[worcesterma@govqa.us], “Vigneux, Michael”[VigneuxM@worcesterma.govj, “thompsonj@worcesterma.gov”
[Thompsonj@worcesterma.gov], [Titelbaumm@worcesterma.gov]
CC: “City Manager”[citymanager@worcesterma.govj

Hello,
The provided document is not ‘The unabridged version of city hail rules as referenced at the top of the abridged rules currently posted at city
hall” as requested in Public Records Request W068826-041 125, as it is in fact the same the abridged set of rules as posted at city hall.
Please confirm if you are able to locate any records responsive to this request,
thank you
David Webb

On Friday, April 11th, 2025 at 1:47PM, Worcester Public Records wrote:

https://worcesterma.govqaus/W5APP/ZAdmin/ServiceRequests/Print,aspx?id=68826&newWin=1&nosidna
5/27125, 3:50 PM G0vQA - WORCESTERMA - Marta Wasiewicz

Date

On 4/11/2025 1:47:00 PM, Janice Thompson wrote:

Subject: [Records Center] City Public Records Request:: W068826-041 125
Body:
The requested record is available at the following link:

çJy Public Records Request W068826041 125

-

City of Worcester Public Records

On 4/11/2025 11:34:21 AM, System Generated Message:

Subject: City Public Records Request:: W068826041 125
Body:

Dear David Webb:

Thank you for your public records request. Your request has been received by City of Worcester and is being processed in accordance
with the Massachusetts Public Records Law. Your request was created on 4/11/2025 and given the reference number W068826-041 125
for tracking purposes.

Records Requested: The unabridged version of city hail rules as referenced at the top of the abridged rules currently posted at city hail

Your request will be forwarded to the relevant department(s) to locate and provide the document(s) you seek. If there are any necessary
costs associated with your request, you will be contacted with a cost breakdown; payment is required prior to commencing the work
required to fulfill your request Please note that the duty to comply with requests for records extends to those records that exist and are
in the possession, custody, or control of the custodian of records at the time of the request. See M.G.L. c. 66, section 1 0(a)(iii In addition,
32 Op. Au’ y Gen 157, 165 (May 18, 1977) held that a custodian is not obligated to create a record in response to a request for
information.

You can monitor the progress of your request at the link below and you’ll receive an email when your request has been completed.
Again, thank you for using the Public Records Center.

City of Worcester

To monitor the progress or update this request please log into the Public Records Center

Powered by

(SovQA
On 4/11/2025 11:34:21 AM, David Webb wrote:
Request Created on Public Portal

V Request Details

Reference No: W068826-041 125

Create Date: 4/11/2025 11:34 AM

Update Date: 4/11/20253:05 PM

Completed/Closed: Yes

Close Date: 4/11/2025 1:36PM

https://worcesterma.govqa.usJWEBAPP/ZAdmin/Serviceftequests/Print.aspx?id=68826&newWinl &nosidna 2/.

5127125. 3:50 PM GovQA WORCESTERMA Mona Waslewlcz
- -

Status: Full Release without Redactions

Priority: Low

Assigned Dept: Law

Assigned Staff: Janice Thompson

Customer Name: David Webb

Email Address: d@vidwebb.com

Phone: 7743149322

Source: Web

https://worcesterma.govqa.usMEBAPP/ZAdmirifServiceRequests/Print.aspx?id=68826&newWin=1 &nosid=na 3/:

 Comments V
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MAYOR’S OFFICE OF LGBTQIA2S+

ADVANCEMENT & MASSACHUSETTS
COMMISSION AGAINST DISCRIMINATION

MASSACH USETTS
LGBTQ+
EMPLOYMENT
- 1 PROTECTIONS
.t.
FEBRUARY 25,2025 @12PM EST
MARCH 20, 2025 @12PM EST

•0

Join us for a virtual training to deepen your

understanding of Massachusetts’ anti-discrimination /

employment prolections. This session will specifically

focus on issues aliecting the l.GBTQ÷ community.

RSVP required to receive the Zoom link.

‘l’ogether, let’s empower our community through

knowledge. Don’t miss this chance to learn, ask
ciuestions. and engage!
MOLA and MCAD Massachusetts LGBTQ+
Employment Protections Training
The Mayor’s Office of LGBTQ+ Advancement (MOLA) is hosting a training with the Massachusetts Commission
Against Discrimination (MOAD) on Massachusetts’ Employment Protections and what they mean for LGBTQIA2S÷
workers and beyond. This informative session will take place on two separate occasions: February 25, 2025 and
March 20, 2025 from 12:00-1:ODPM. A Zoom link will be provided upon registration.

Participants will gain valuable insights into their rights under Massachusetts anti-discrimination employment
protections.

This session is open to individuals and community groups across the Commonwealth. In addition to discussing the
basics of anti-discrimination employment laws, we will cover all protected categories, with a specific emphasis
on sexual orientation and gender identity.

If you would like to schedule a private training for your organization email MCADTraininci©mass.gov or call 617-
994-6072.

To ensure a safe and supportive environment, please RSVP below with your email to receive the Zoom link.
Completing the optional pre-training survey will help us tailor the session to your needs.

We look forward to empowering our community together through knowledge—don’t miss this opportunity to learn
and engage!

If you would like to schedule a private training for your organization email MCADTrainingmass.gov or call 617-
994-6072

*
Email

clerkworcesterma.gov

Which training would you like to attend? *

February 25, 2025 @1 2PM

5
 March20, 2025 @12PM

How knowledgeable do you feel about MA anti-discrimination employment law?

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How knowledgeable are you with the process of filing a complaint to MCAD?

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Do you have any specific questions about MA employment protections that you’d like the presenters
to answer?

Do we have an obligation as a city to stand against transphobia and bigotry

Thank you! If you have any questions please contact, kimberIy.rhotenboston.gov

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