Preview
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
Docket Number
03/11/2024
COMMONWEALTH OF MASSACHUSETTS
HAMPDEN, SS. SUPERIOR COURT DEPT.
IN RE:
CIVIL ACTION NO.:
24CV144
APPLICATION OF JOSHUA ROBINSON
FOR AN ORDER PURSUANT TO
M.G.L. CH. 223A, § 11
APPLICATION FOR ORDER FOR ISSUANCE OF SUBPOENA
INSIDE COMMONWEALTH FOR PROCEEEDING IN TRIBUNAL
QUTSIDE COMMONWEALTH PURSUANT TO M.G.L. CH. 223A, § 11
Joshua Robinson hereby applies to this Court pursuant to the provisions of M.G.L
Ch. 223A, § 11 for an Order allowing the service of subpoenas upon the following:
Andrew Christensen
8 North Street
East Longmeadow, MA 01028
Joshua Robinson, by and through his attorneys, hereby applies for an order
directing Andrew Christensen to produce documents and appear for deposition and give
testimony for use in the proceedings now pending in the Circuit Court of Faulkner
County, Arkansas, entitled Rebecca Rice v. Joshua Robinson., bearing Case No, 23CV-
22-1316 (the “Arkansas Action”). The documents and testimony sought are relevant,
material, and necessary to the issues involved in the Arkansas Action.
As grounds for this application, Joshua Robinson states as follows:
1 Andrew Christensen holds records and knowledge relevant to the matter
at hand and has been named as a fact witness in the Arkansas Action.
2 Mr. Robinson requests that this honorable Court order Andrew
Christensen to appear for deposition and produce relevant documents at 2:00 PM on April
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
Docket Number
12, 2024, at the Worcester Law Library, 4"" Floor, 184 Main Street, Worcester, MA 01608.
3 In support of this application, the undersigned states that Mr. Robinson
has obtained an Order Authorizing Discovery in Foreign Jurisdiction (the “Arkansas
Order”). A copy of the Arkansas Order is attached hereto as Exhibit A.
4 A copy of the proposed subpoena is attached as Exhibit B.
5 For the Court’s convenience, a copy of a Proposed Order is attached
hereto as Exhibit C.
WHEREFORE, the undersigned applicant respectfully requests that this Court:
1 Issue an Order authorizing the undersigned (a) to issue a subpoena to
Andrew Christensen in accordance with the procedure of Mass. R. Civ.
P. 30(b)(6) and 45, to compel the deposition and production of
documents as specified in the Arkansas Order, and (b) to have said
subpoena served on Andrew Christensen.
Authorize any Notary Public of the Commonwealth of Massachusetts
to issue the subpoena.
3. Take any other action it deems appropriate.
RESPECTFULLY SUBMITTED,
Joshua Robinson,
By his attorneys,
Chan Davee
Ethan Z. Davis (BBO #668973)
TYMANN, DAvIs & DUFFY LLP
45 Bromfield Street, 6th Floor
Boston, MA 02108
(617) 933-9490
edavis@tddlegal.com
Dated: March 11, 2024
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
Docket Number
EXHIBIT A
Date Filed 3/11/2024 11:42 AM
‘Superior Court - Hampden
Docket Number ELECTRONICALLY FILED
Faulkner County Circuit Court
Nancy Eastham, Circuit Clerk
2024-Feb-06 16:11:35
23CV-22-1316
C20D03 : 3 Pages
COUNTY, ARKANSAS
IN THE CIRCUIT C OURT OF FAULKNER
THIRD DIVISION - DO IMESTIC RELATIONS
PLAINTIFF
REBECCA RICE
vS. NO. 23CV-22-1316
DEFENDANT
JOSHUA ROBINSON
THIRD-PARTY
and/or JROB, INC. COUNTERCLAIMAINT
ORDER AUTH NG DIS' VERY
T T. N T UNIFORM
PTED
IN FORE IGN JUR ISD ICT ION
NS AND DISCOVERY ACT (UIDDA)
INTERSTATE DEPOSITIO
ws:
Comes now the Court, finding and ruling as follo
ct matter, and venue is
1 The Court has jurisdiction over the parties and subje
proper.
in discovery, and desires to
2 Defendant has named the following fact witnesses
depositions to be conducted i in their various
issue subpoenas to require the witnesses to attend
ents in the foreign jurisdictions:
states of residency, and/or to compel | the production of docum
Cara Drew
29 Patricia Dr.
Tyngsboro, MA 01879
Kellie Waters
Andrew Christensen
2 Olde Woode Rd.
8 North St.
Salem, NH 03079
East Longmeadow, MA 01028
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden
Docket Number
the attendance
3 This Court hereby authorizes the issuance of subpoenas to compel
the production of
of the witnesses at depositions to be scheduled by the parties, and/or to compel
Civil Procedure.
documents from the witnesses, pursuant to the Arkansas Rules of
s and New
4 Further, this Court authorizes and/or requests that the Massachusett
witnesses reside, take such
Hampshire courts, in each of the respective jurisdictions where the
ary to compel the
actions, in accordance with their applicable state law, as may be necess
ding to the date/time/place listed
attendance of the witnesses at their scheduled depositions (accor
dings), and accordingly,
on each of their Notice of Deposition to be filed of record in these procee
on each domestic subpoena
to compel the production of documents pursuant to the wording
duces tecum.
IT IS SO ORDERED.
[electronic signature on attached signature page|
HON. CHUCK CLAWSON
Circuit Court Judge - Third Division
Faulkner Co. Cireuit Court
20th Judicial District
Approved as to form:
TAM BARGAR
he
as metalized
ee =
N
D Ss bo Dylan JAMES BARGAR
Attorney for Plaintiff Attorne
otts
2/624
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
Docket Number
Case Title: REBECCA RICE V JOSHUA ROBINSON
Case Number: 23CV-22-1316
Type: ORDER OTHER
So Ordered
Loox
Judge Charles E. Clawson III
Electronically signed by CECLAWSONS on 2024-02-06 page 3 of 3
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
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EXHIBIT B
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
Docket Number
COMMONWEALTH OF MASSACHUSETTS
HAMPDEN, SS. SUPERIOR COURT DEPT.
IN RE:
CIVIL ACTION NO.:
APPLICATION OF JOSHUA ROBINSON
FOR AN ORDER PURSUANT TO
M.G.L. CH. 223A, § 11
SUBPOENA DUCES TECUM
To. Andrew Christensen
8 North Street
East Longmeadow, MA 01028
Pursuant to Mass. R. Civ. P. Rules 30(b)(6) and 45, and this Court’s Order dated March
__, 2024, YOU ARE HEREBY COMMANDED, in the name of the Commonwealth of
Massachusetts, to produce the documents identified in Exhibit A, attached hereto, and to appear
for deposition at the Worcester Law Library, 4" Floor, 184 Main Street, Worcester, MA 01608,
on April 12, 2024, at 1:00 p.m., and from day to day thereafter, until the deposition is completed.
You are to bring with you the following:
HEREOF FAIL NOT, as your failure to appear as required will subject you to such pains
and penalties as the law provides.
Dated: March __, 2024
Ethan Z. Davis, BBO #668973
TYMANN, Davis & DUFFY LLP Notary Public
45 Bromfield Street, Sixth Floor My Commission expires:
Boston, MA. 02108
(617) 933-9490
edavis@tddleglal.com
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
Docket Number
EXHIBIT A
DEFINITIONS AND INSTRUCTIONS
1. The definitions set forth in Superior Court Rule 30A apply and are incorporated by
reference herein, including, but not limited to, the definitions of: “communication,” “document,”
“identify” (with respect to documents and persons), “person,” and “concerning.” As used herein,
“relating to” and “pertaining to” (as well as any derivative forms thereof) have the same meaning
as the uniform definition of the term “concerning” as set forth in Superior Court Rule 30A.
2. “Document” means all forms of documents and electronically stored information
(“ESI”) — including writings, emails, correspondence, memoranda, notices, drawings, graphs,
charts, photographs, audio recordings, images, and other data or data compilations — stored in
any medium from which information can be obtained either directly or, if necessary, after
translation into a usable form.
3. As used herein, “relating to” and “pertaining to” have the same meaning as the
uniform definition of the term “concerning” as set forth in Superior Court Rule 30A.
4, “And” as well as “ shall be construed either conjunctively or disjunctively, the
singular as well as the plural shall be construed as either singular or plural, and the feminine as
well as the masculine gender shall be construed as either feminine or masculine as necessary to
bring within the scope of these document requests all subjects which might otherwise be outside
their scope.
5. The term “person” as used herein shall mean any natural person and/or any
corporation, company, partnership, joint venture, association, or other entity.
6. YOU”, “YOUR”, or “YOURS” means Andrew Christensen and his attorneys,
employees, representatives, or anyone else acting on his behalf.
7. “WE” or “the SUBPOENAING PARTY” means Joshua Robinson, or his counsel
or other representatives.
8. “ACTION” means the case Rebecca Rice v. Joshua Robinson, Civil Action No.
23CV-22-1316 now pending in the Circuit Court of Faulkner County, Arkansas.
9. These requests require supplemental responses to the fullest extent required by Rule
26 and 45 of the Massachusetts Rules of Civil Procedure.
10. If any requested document is unavailable because it has been lost, discarded, or
destroyed, please identify such document, and state the circumstances in which it was lost,
discarded or destroyed, and identify each person having knowledge of the circumstances in which
it was lost, discarded, or destroyed. For any document with an unknown location, identify all
persons that might possess or know the location of that document.
11. If there are no documents in existence that are requested in a particular paragraph
of the Subpoena, Mr. Christensen’s response must include a statement to that effect.
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
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12. All documents produced for inspection shall be produced as they are kept in the
usual course of business or shall be organized and labeled to correspond with the paragraphs of
the Document Requests.
DOCU ‘S REQUESTED
1 All documents concerning sales made, or contracts entered into by Joshua Robinson
(in his individual capacity or through Mr. Robinson’s corporate entity JRob Inc.), including but
not limited to all documents created, generated, or acknowledged during or subsequent to any date
in which Mr. Robinson was transacting business with Concord Wealth Management or Penn
Mutual Life Insurance Company (whether individually or through JRob Inc.).
2 All documents concerning sales made, or contracts entered into by Rebecca Rice
(in her individual capacity or through her corporate entity Rebecca Rice and Associates), including
but not limited to all documents created, generated, or acknowledged during or subsequent to any
date in which Ms. Rice was transacting business with Concord Wealth Management or Penn
Mutual Life Insurance Company (whether individually or through Rebecca Rice and Associates).
3 All documents concerning any commissions earned by Joshua Robinson, including
but not limited to documents concerning the underlying sales data leading to the payment of any
commissions, as well as any documents relating to the performance of Joshua Robinson in
performing his duties during the aforementioned timeframe, including but not limited to bonuses,
trips, awards, or other "perks" associated with the sales of Penn Mutual Life Insurance Company
products or any other products.
4 All documents concerning any commissions earned by Rebecca Rice, including but
not limited to documents concerning the underlying sales data leading to the payment of any
commissions, as well as any documents relating to the performance of Rebecca Rice in performing
her duties during the aforementioned timeframe, including but not limited to bonuses, trips,
awards, or other "perks" associated with the sales of Penn Mutual Life Insurance Company
products or any other products.
5 Any and all policies, guidelines, rules, or other matter (of any kind) regarding
commissions, the earning of commissions or the sharing of commissions that were in force,
whether formally or informally, by the parties to the Action (or their respective corporate
entities) on or after any date in which both of the parties to this lawsuit were transacting business
with Concord Wealth Management or Penn Mutual Life Insurance Company (whether
individually or through their respective business entities (the “Time Period”).
6. Any and all emails, text messages (business or personal), interoffice memoranda,
or other documents of any kind or nature (business or personal) between Rebecca Rice
(individually or through her corporate entity Rebecca Rice and Associates) and you (individually
or as an agent of Concorde Wealth Management or Penn Mutual Life Insurance Company)
during the Time Period that named, referenced, or in any way concerned Joshua Robinson
(individually or through his corporate entity JRob Inc.).
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
Docket Number
7
Any and all emails, text messages (business or personal), interoffice memoranda,
or other documents of any kind or nature (business or personal) between Cara Drew
(individuality or as an agent of Concorde Wealth Management or Penn Mutual Life Insurance
Company) and you (individually or as an agent of Concorde Wealth Management or Penn
Mutual Life Insurance Company) during the Time Period that named, referenced, or in any way
concerned Joshua Robinson (individually or through his corporate entity JRob Inc.).
8 Any and all other emails, text messages (business or personal), interoffice
memoranda, or other documents of any kind or nature (business or personal) maintained by you
individually, or as an agent of Concord Wealth Management or Penn Mutual Life Insurance
Company), naming, referencing, or in any way concerning Joshua Robinson (or his corporate
entity JRob Inc.) during the Time Period, other than what you have already provided as
responsive to the previous requests in this subpoena.
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
Docket Number
EXHIBIT C
Date Filed 3/11/2024 11:42 AM
Superior Court - Hampden.
Docket Number
COMMONWEALTH OF MASSACHUSETTS
HAMPDEN, SS. SUPERIOR COURT DEPT.
IN RE:
CIVIL ACTION NO.:
APPLICATION OF JOSHUA ROBINSON
FOR AN ORDER PURSUANT TO
M.G.L. CH. 223A, § 11
[PROPOSED] ORDER FOR ISSUANCE OF SUBPOENAS
INSIDE COMMONWEALTH FOR PROCEEEDING IN TRIBUNAL
QUTSIDE COMMONWEALTH PURSUANT TO M.G.L. CH. 223A, § 11
This Court, having considered the application of Joshua Robinson pursuant to
M.G.L. ch. 223A, § 11 for an order allowing the service of a subpoena to Andrew
Christensen to appear for deposition and produce documents, hereby ORDERS as follows:
qd) Tymann, Davis & Duffy LLP is authorized to (a) issue a subpoena to
Andrew Christensen that is substantially consistent with Exhibit B to the
application, and (b) have said subpoena served upon Andrew Christensen;
and
Q) Andrew Christensen is ordered to appear for deposition and produce
documents by 4:00 PM on April 12, 2024, at the Worcester Law Library,
4" Floor, 184 Main Street, Worcester, MA 01608.
SO ORDERED
Hon.
Justice of the Superior Court
Dated: , 2024
Preview
Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number 03/11/2024 COMMONWEALTH OF MASSACHUSETTS HAMPDEN, SS. SUPERIOR COURT DEPT. IN RE: CIVIL ACTION NO.: 24CV144 APPLICATION OF JOSHUA ROBINSON FOR AN ORDER PURSUANT TO M.G.L. CH. 223A, § 11 APPLICATION FOR ORDER FOR ISSUANCE OF SUBPOENA INSIDE COMMONWEALTH FOR PROCEEEDING IN TRIBUNAL QUTSIDE COMMONWEALTH PURSUANT TO M.G.L. CH. 223A, § 11 Joshua Robinson hereby applies to this Court pursuant to the provisions of M.G.L Ch. 223A, § 11 for an Order allowing the service of subpoenas upon the following: Andrew Christensen 8 North Street East Longmeadow, MA 01028 Joshua Robinson, by and through his attorneys, hereby applies for an order directing Andrew Christensen to produce documents and appear for deposition and give testimony for use in the proceedings now pending in the Circuit Court of Faulkner County, Arkansas, entitled Rebecca Rice v. Joshua Robinson., bearing Case No, 23CV- 22-1316 (the “Arkansas Action”). The documents and testimony sought are relevant, material, and necessary to the issues involved in the Arkansas Action. As grounds for this application, Joshua Robinson states as follows: 1 Andrew Christensen holds records and knowledge relevant to the matter at hand and has been named as a fact witness in the Arkansas Action. 2 Mr. Robinson requests that this honorable Court order Andrew Christensen to appear for deposition and produce relevant documents at 2:00 PM on April Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number 12, 2024, at the Worcester Law Library, 4"" Floor, 184 Main Street, Worcester, MA 01608. 3 In support of this application, the undersigned states that Mr. Robinson has obtained an Order Authorizing Discovery in Foreign Jurisdiction (the “Arkansas Order”). A copy of the Arkansas Order is attached hereto as Exhibit A. 4 A copy of the proposed subpoena is attached as Exhibit B. 5 For the Court’s convenience, a copy of a Proposed Order is attached hereto as Exhibit C. WHEREFORE, the undersigned applicant respectfully requests that this Court: 1 Issue an Order authorizing the undersigned (a) to issue a subpoena to Andrew Christensen in accordance with the procedure of Mass. R. Civ. P. 30(b)(6) and 45, to compel the deposition and production of documents as specified in the Arkansas Order, and (b) to have said subpoena served on Andrew Christensen. Authorize any Notary Public of the Commonwealth of Massachusetts to issue the subpoena. 3. Take any other action it deems appropriate. RESPECTFULLY SUBMITTED, Joshua Robinson, By his attorneys, Chan Davee Ethan Z. Davis (BBO #668973) TYMANN, DAvIs & DUFFY LLP 45 Bromfield Street, 6th Floor Boston, MA 02108 (617) 933-9490 edavis@tddlegal.com Dated: March 11, 2024 Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number EXHIBIT A Date Filed 3/11/2024 11:42 AM ‘Superior Court - Hampden Docket Number ELECTRONICALLY FILED Faulkner County Circuit Court Nancy Eastham, Circuit Clerk 2024-Feb-06 16:11:35 23CV-22-1316 C20D03 : 3 Pages COUNTY, ARKANSAS IN THE CIRCUIT C OURT OF FAULKNER THIRD DIVISION - DO IMESTIC RELATIONS PLAINTIFF REBECCA RICE vS. NO. 23CV-22-1316 DEFENDANT JOSHUA ROBINSON THIRD-PARTY and/or JROB, INC. COUNTERCLAIMAINT ORDER AUTH NG DIS' VERY T T. N T UNIFORM PTED IN FORE IGN JUR ISD ICT ION NS AND DISCOVERY ACT (UIDDA) INTERSTATE DEPOSITIO ws: Comes now the Court, finding and ruling as follo ct matter, and venue is 1 The Court has jurisdiction over the parties and subje proper. in discovery, and desires to 2 Defendant has named the following fact witnesses depositions to be conducted i in their various issue subpoenas to require the witnesses to attend ents in the foreign jurisdictions: states of residency, and/or to compel | the production of docum Cara Drew 29 Patricia Dr. Tyngsboro, MA 01879 Kellie Waters Andrew Christensen 2 Olde Woode Rd. 8 North St. Salem, NH 03079 East Longmeadow, MA 01028 Date Filed 3/11/2024 11:42 AM Superior Court - Hampden Docket Number the attendance 3 This Court hereby authorizes the issuance of subpoenas to compel the production of of the witnesses at depositions to be scheduled by the parties, and/or to compel Civil Procedure. documents from the witnesses, pursuant to the Arkansas Rules of s and New 4 Further, this Court authorizes and/or requests that the Massachusett witnesses reside, take such Hampshire courts, in each of the respective jurisdictions where the ary to compel the actions, in accordance with their applicable state law, as may be necess ding to the date/time/place listed attendance of the witnesses at their scheduled depositions (accor dings), and accordingly, on each of their Notice of Deposition to be filed of record in these procee on each domestic subpoena to compel the production of documents pursuant to the wording duces tecum. IT IS SO ORDERED. [electronic signature on attached signature page| HON. CHUCK CLAWSON Circuit Court Judge - Third Division Faulkner Co. Cireuit Court 20th Judicial District Approved as to form: TAM BARGAR he as metalized ee = N D Ss bo Dylan JAMES BARGAR Attorney for Plaintiff Attorne otts 2/624 Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number Case Title: REBECCA RICE V JOSHUA ROBINSON Case Number: 23CV-22-1316 Type: ORDER OTHER So Ordered Loox Judge Charles E. Clawson III Electronically signed by CECLAWSONS on 2024-02-06 page 3 of 3 Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number EXHIBIT B Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number COMMONWEALTH OF MASSACHUSETTS HAMPDEN, SS. SUPERIOR COURT DEPT. IN RE: CIVIL ACTION NO.: APPLICATION OF JOSHUA ROBINSON FOR AN ORDER PURSUANT TO M.G.L. CH. 223A, § 11 SUBPOENA DUCES TECUM To. Andrew Christensen 8 North Street East Longmeadow, MA 01028 Pursuant to Mass. R. Civ. P. Rules 30(b)(6) and 45, and this Court’s Order dated March __, 2024, YOU ARE HEREBY COMMANDED, in the name of the Commonwealth of Massachusetts, to produce the documents identified in Exhibit A, attached hereto, and to appear for deposition at the Worcester Law Library, 4" Floor, 184 Main Street, Worcester, MA 01608, on April 12, 2024, at 1:00 p.m., and from day to day thereafter, until the deposition is completed. You are to bring with you the following: HEREOF FAIL NOT, as your failure to appear as required will subject you to such pains and penalties as the law provides. Dated: March __, 2024 Ethan Z. Davis, BBO #668973 TYMANN, Davis & DUFFY LLP Notary Public 45 Bromfield Street, Sixth Floor My Commission expires: Boston, MA. 02108 (617) 933-9490 edavis@tddleglal.com Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number EXHIBIT A DEFINITIONS AND INSTRUCTIONS 1. The definitions set forth in Superior Court Rule 30A apply and are incorporated by reference herein, including, but not limited to, the definitions of: “communication,” “document,” “identify” (with respect to documents and persons), “person,” and “concerning.” As used herein, “relating to” and “pertaining to” (as well as any derivative forms thereof) have the same meaning as the uniform definition of the term “concerning” as set forth in Superior Court Rule 30A. 2. “Document” means all forms of documents and electronically stored information (“ESI”) — including writings, emails, correspondence, memoranda, notices, drawings, graphs, charts, photographs, audio recordings, images, and other data or data compilations — stored in any medium from which information can be obtained either directly or, if necessary, after translation into a usable form. 3. As used herein, “relating to” and “pertaining to” have the same meaning as the uniform definition of the term “concerning” as set forth in Superior Court Rule 30A. 4, “And” as well as “ shall be construed either conjunctively or disjunctively, the singular as well as the plural shall be construed as either singular or plural, and the feminine as well as the masculine gender shall be construed as either feminine or masculine as necessary to bring within the scope of these document requests all subjects which might otherwise be outside their scope. 5. The term “person” as used herein shall mean any natural person and/or any corporation, company, partnership, joint venture, association, or other entity. 6. YOU”, “YOUR”, or “YOURS” means Andrew Christensen and his attorneys, employees, representatives, or anyone else acting on his behalf. 7. “WE” or “the SUBPOENAING PARTY” means Joshua Robinson, or his counsel or other representatives. 8. “ACTION” means the case Rebecca Rice v. Joshua Robinson, Civil Action No. 23CV-22-1316 now pending in the Circuit Court of Faulkner County, Arkansas. 9. These requests require supplemental responses to the fullest extent required by Rule 26 and 45 of the Massachusetts Rules of Civil Procedure. 10. If any requested document is unavailable because it has been lost, discarded, or destroyed, please identify such document, and state the circumstances in which it was lost, discarded or destroyed, and identify each person having knowledge of the circumstances in which it was lost, discarded, or destroyed. For any document with an unknown location, identify all persons that might possess or know the location of that document. 11. If there are no documents in existence that are requested in a particular paragraph of the Subpoena, Mr. Christensen’s response must include a statement to that effect. Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number 12. All documents produced for inspection shall be produced as they are kept in the usual course of business or shall be organized and labeled to correspond with the paragraphs of the Document Requests. DOCU ‘S REQUESTED 1 All documents concerning sales made, or contracts entered into by Joshua Robinson (in his individual capacity or through Mr. Robinson’s corporate entity JRob Inc.), including but not limited to all documents created, generated, or acknowledged during or subsequent to any date in which Mr. Robinson was transacting business with Concord Wealth Management or Penn Mutual Life Insurance Company (whether individually or through JRob Inc.). 2 All documents concerning sales made, or contracts entered into by Rebecca Rice (in her individual capacity or through her corporate entity Rebecca Rice and Associates), including but not limited to all documents created, generated, or acknowledged during or subsequent to any date in which Ms. Rice was transacting business with Concord Wealth Management or Penn Mutual Life Insurance Company (whether individually or through Rebecca Rice and Associates). 3 All documents concerning any commissions earned by Joshua Robinson, including but not limited to documents concerning the underlying sales data leading to the payment of any commissions, as well as any documents relating to the performance of Joshua Robinson in performing his duties during the aforementioned timeframe, including but not limited to bonuses, trips, awards, or other "perks" associated with the sales of Penn Mutual Life Insurance Company products or any other products. 4 All documents concerning any commissions earned by Rebecca Rice, including but not limited to documents concerning the underlying sales data leading to the payment of any commissions, as well as any documents relating to the performance of Rebecca Rice in performing her duties during the aforementioned timeframe, including but not limited to bonuses, trips, awards, or other "perks" associated with the sales of Penn Mutual Life Insurance Company products or any other products. 5 Any and all policies, guidelines, rules, or other matter (of any kind) regarding commissions, the earning of commissions or the sharing of commissions that were in force, whether formally or informally, by the parties to the Action (or their respective corporate entities) on or after any date in which both of the parties to this lawsuit were transacting business with Concord Wealth Management or Penn Mutual Life Insurance Company (whether individually or through their respective business entities (the “Time Period”). 6. Any and all emails, text messages (business or personal), interoffice memoranda, or other documents of any kind or nature (business or personal) between Rebecca Rice (individually or through her corporate entity Rebecca Rice and Associates) and you (individually or as an agent of Concorde Wealth Management or Penn Mutual Life Insurance Company) during the Time Period that named, referenced, or in any way concerned Joshua Robinson (individually or through his corporate entity JRob Inc.). Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number 7 Any and all emails, text messages (business or personal), interoffice memoranda, or other documents of any kind or nature (business or personal) between Cara Drew (individuality or as an agent of Concorde Wealth Management or Penn Mutual Life Insurance Company) and you (individually or as an agent of Concorde Wealth Management or Penn Mutual Life Insurance Company) during the Time Period that named, referenced, or in any way concerned Joshua Robinson (individually or through his corporate entity JRob Inc.). 8 Any and all other emails, text messages (business or personal), interoffice memoranda, or other documents of any kind or nature (business or personal) maintained by you individually, or as an agent of Concord Wealth Management or Penn Mutual Life Insurance Company), naming, referencing, or in any way concerning Joshua Robinson (or his corporate entity JRob Inc.) during the Time Period, other than what you have already provided as responsive to the previous requests in this subpoena. Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number EXHIBIT C Date Filed 3/11/2024 11:42 AM Superior Court - Hampden. Docket Number COMMONWEALTH OF MASSACHUSETTS HAMPDEN, SS. SUPERIOR COURT DEPT. IN RE: CIVIL ACTION NO.: APPLICATION OF JOSHUA ROBINSON FOR AN ORDER PURSUANT TO M.G.L. CH. 223A, § 11 [PROPOSED] ORDER FOR ISSUANCE OF SUBPOENAS INSIDE COMMONWEALTH FOR PROCEEEDING IN TRIBUNAL QUTSIDE COMMONWEALTH PURSUANT TO M.G.L. CH. 223A, § 11 This Court, having considered the application of Joshua Robinson pursuant to M.G.L. ch. 223A, § 11 for an order allowing the service of a subpoena to Andrew Christensen to appear for deposition and produce documents, hereby ORDERS as follows: qd) Tymann, Davis & Duffy LLP is authorized to (a) issue a subpoena to Andrew Christensen that is substantially consistent with Exhibit B to the application, and (b) have said subpoena served upon Andrew Christensen; and Q) Andrew Christensen is ordered to appear for deposition and produce documents by 4:00 PM on April 12, 2024, at the Worcester Law Library, 4" Floor, 184 Main Street, Worcester, MA 01608. SO ORDERED Hon. Justice of the Superior Court Dated: , 2024