Motion to Extend or Shorten Time in Sholds, Patricia vs. Pinaski, Edward| Trellis.Law

On September 19, 2022 a Motion,Ex Parte was filed involving a dispute between Sholds, Patricia, and Pinaski, Edward, for Torts in the District Court of Essex County.

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Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887 16

RECEIVED
COMMONWEALTH OF MASSACHUSETTS

ESSEX, SS. SUPERIOR COURT

PATRICIA SHOLDS,
Plaintiff

Vv. CIVIL ACTION NO. 227CV00887

EDWARD PINASKI,
Defendant

PLAINTIFF’S 2"? EMERGENCY MOTION TO EXTEND TIME TO DISCLOSE
EXPERTS PURSUANT TO SUPERIOR COURT RULE 30

Now comes the plaintiff, Patricia Sholds, and respectfully moves this Honorable Court to
extend time for the plaintiff to disclose experts pursuant to Rule 30, for an additional 60 days, up
to and including, June 15, 2024. Plaintiff bases her motion on the fact that diligent efforts to

obtain the defendant’s full medical records, which must be supplied to plaintiffs experts in order
for them to complete their review and provide their reports, have not resulted in acquisition of
his records to date. Defendant’s medical providers asked for plaintiff to provide the complete
power of attorney document, in order for those providers to release Defendant’s records. On
January 31, 2024, plaintiffs counsel asked Defendant’s counsel for the full document.
Defendant’s counsel sent a redacted version to plaintiffs counsel on Thursday, April 11, 2024.
As grounds therefore, and for further information and chronology of this issue, the
plaintiff refers this Honorable Court to her Memorandum of Law, filed contemporaneously
herewith.
Respectfully submitted,
Plaintiff by his Attorney,

/s/ Joseph M. Orlando Jr.
JOSEPH M. ORLANDO, JR., ESQ.
BBO # 680995
Orlando & Associates
One Western Avenue
Gloucester, MA 01930
Phone: (978) 283-8100
Fax: (978) 283-8507
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

Email: jmorlandojr@orlandoassociates.com

CERTIFICATE OF SERVICE

I, Joseph M. Orlando, Jr. certify that this document was served upon counsel for the
defendant by mailing a copy there of via electronic and regular mail, postage prepaid, to
Christopher J. O’Rourke, Esq., Law Office of Christopher J. O’Rourke, 1 Hollis Street, Suite
220, Wellesley, MA 02482 this 12 day of April, 2024.

4s/ Joseph M. Orlando Jr.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

COMMONWEALTH OF MASSACHUSETTS

ESSEX, SS. SUPERIOR COURT

PATRICIA SHOLDS,
Plaintiff

Vv. CIVIL ACTION NO. 227CV00887

EDWARD PINASKI,
Defendant

PLAINTIFF’S MEMORANDUM OF LAW IN SUPPORT OF HER 2™ EMERGENCY
MOTION TO EXTEND TIME TO DISCLOSE EXPERTS PURSUANT TO SUPERIOR
COURT RULE 30

Now comes the plaintiff, Patricia Sholds, and submits the within Memorandum of Law.

Factual Background

The Plaintiff filed her Complaint on 9/19/2022 (Doc. 1).
Defendant Filed his answer to the Complaint on 11/21/2022 (Doc. 4) and included an
affirmative defense (#12), citing an emergent medical issue.
On March 30, 2023, plaintiff served 2nd Request for Production of Documents upon
defense counsel, via email.

On June 12, 2023, plaintiffs counsel’s office requested that defense counsel provide a
date upon which he would tender the requested material.
On June 22, 2023, plaintiff served her Motion to Compel.
In response, defendant’s counsel served a draft Motion for Protective Order on July 3,

2023 regarding the production of the defendant’s medical records.
The matter was conferenced several times between counsel.
Plaintiffs counsel attempted to work on a compromise solution with defendant’s counsel
on this issue, but defendant’s counsel has not been willing to resolve it by producing any
of the defendant’s medical records.
On September 13, 2023, Defendant served the Motion for Protective Order via email to
the Plaintiff while the parties were continuing to work on a compromise.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

10. The parties had no further discussions regarding a compromise however, on September
29, 2023, the Defendant filed the Motion for Protective Order (Doc. 8).

11. The Plaintiff opposed this motion(Doc. 10).
12. The court denied Defendant’s Motion on 10/3/2024.
13. On December 4, 2023, Defendant’s counsel agreed to provide signed authorizations from
the defendant for the plaintiff to obtain a full set of Defendant’s medical records (Exhibit
A: Email from O’ Rourke to Orlando 12/4/2024);
14 On December 5, 2023, the parties submitted a Joint Pre-Trial Memorandum(Doc. 11);
15 The Joint Pre-Trial Memorandum stated that the parties had agreed that Plaintiff would
designate her experts by February 15, 2024;
16. On December 22, 2023, Defendant’s counsel provided a signed signature page for
authorizations, and a copy of the Acceptance of Power of Attorney, for the Defendant’s
designated representative (Exhibit B: Email from O’Rourke to Orlando 12/22/2023).
17 On December 28, 2023, plaintiff sent requests to all of the Defendant’s medical providers
with the signed authorizations and Acceptance of Power of Attorney document (Exhibit
C: Letters Requesting Medical Records of defendant).
18 On January 31, 2024 Lahey, the entity which houses the vast majority of Defendant’s
medical records, contacted plaintiffs counsel by telephone and advised that it would
need the full document Power of Attorney in order to release Defendant’s records
(Exhibit D: See voicemail transcription from Lahey to Orlando’s office).
19, On January 31, 2024, plaintiff contacted Defendant’s counsel to advise that she would
need the full Power of Attorney Document (Exhibit E: Email from Orlando to
O’Rourke dated 1/31/2024, and O’Rourke Response).
20. On February 1, 2024, Defendant’s counsel responded that he would discuss providing
same with his client (Exhibit E).
21 On February 15, 2024, the plaintiff disclosed her orthopedic expert.
22. On February 28, 2024, plaintiff filed an unopposed emergency motion to extend time to
designate her expert(Doc. 14).
23. The Court allowed the motion on 3/11/2024.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

24. On Friday, April 5, 2024, plaintiffs counsel requested that Defendant’s counsel assent to
a motion to extend time to disclose plaintiffs experts(Exhibit F: Email from Orlando
to O’Rourke, 4/5/2024).
25. On 4/9/2024, having heard nothing from Defendant’s counsel, Plaintiff's counsel again
requested Defendant’s counsel to send the remainder of the document or assent to this
motion, and Defendant’s counsel refused(Exhibit G: Email O’Rourke to Orlando
4/9/2024).
26. On April 11, 2024, Defendant’s counsel supplied a redacted version of the Power of
Attorney Document(Exhibit H: Email from O’Rourke to Orlando, 4/11/2024).

Legal Standard
The Court has the discretion to extend discovery deadlines: "The conduct and scope of
discovery is within the sound discretion of the judge.” Solimene v. B. Grauel & Co., KG, 399
Mass. 790, 799, 507 N.E.2d 662 (1987). Premier Capital. Inc. v. Wooster, 2011 Mass. App.
Unpub. LEXIS 1099, *2
Argument
This litigation centers on the issue of whether the Defendant experienced an anticipated,
or unanticipated, medical event, causing the collision which was the cause of plaintiff's injuries.
It is a question of liability, for which the plaintiff seeks a liability expert who may review the
Defendant’s medical records and provide an expert opinion.
Plaintiff has identified two experts on the issue, and will be disclosing the expert’s
identities to Defendant’s counsel and to the court by the 4/15/2024 deadline, however, the
experts cannot complete their reports without the Defendant’s records. Defendant supplied a
redacted version to plaintiffs counsel on 4/11/2024. This will be sent to the medical providers,
and hopefully they will accept same and provide the records. Once the records are received by
plaintiffs counsel, he will supply same to the identified experts so that they may complete their
reports and plaintiff may supplement her disclosure.
Wherefore, the plaintiff seeks an additional 90 days, up to and including July 15, 2024,
for which to disclose her experts pursuant to Superior Court Rule 30, in an abundance of caution,
should the medical providers insist on an unredacted version of the Power of Attorney document,
and the plaintiff's counsel will then have to work with Defendant’s counsel to obtain same.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

Respectfully submitted,
Plaintiff by his Attorney,

/s/ Joseph M. Orlando Jr.
JOSEPH M. ORLANDO, JR., ESQ.
BBO # 680995
Orlando & Associates
One Western Avenue
Gloucester, MA 01930
Phone: (978) 283-8100
Fax: (978) 283-8507
Email: jmorlandojr@orlandoassociates.com

CERTIFICATE OF SERVICE

4s/ Joseph M. Orlando Jr.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

EXHIBIT A
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

Cathy Arnold

From: Chris O'Rourke
Sent: Monday, December 4, 2023 2:55 PM
To: Amanda Orlando
Ce: Joseph Orlando Jr
Subject: Re: Regarding: Sholds, Patricia v Ed Pinanski

Amanda - | have no availability this week and will be on vacation next week. | have some availability during
the last week of December if that works for Joe's schedule.

! will request my client to sign the Authorizations.

Chris

ChristopherJ. O'Rourke
Law Office of Christopher J. O'Rourke
1 Hollis Street, Suite 220
Wellesley, MA 02482
(Ph) 781-235-8022
(Fax) 781-235-9440
chris@orourkelawoffice.com

NOTICE: This email and any attachments may contain privileged and confidential information and is intended
for the sole use of the named recipient. If you are not the intended recipient, please notify the sender
by
reply email and delete this email and any attachments from your system. Thank you.

oe -
ener eet rn eee eeecei snr iene nate
From: Amanda Orlando
Sent: Thursday, November 30, 2023 11:21 AM
To: Chris O'Rourke
Cc: Joseph Orlando Jr
Subject: Regarding: Sholds, Patricia v Ed Pinanski

Counsel,
Please see attached authorizations for Mr. Pinanski to sign for all records from providers we are aware of. |
also
included a blank authorization, should there be a provider that you and he are aware of that we are not. Please
have
him execute these, so that we can send them out.

Additionally, the other driver’s attorney has advised that the next two weeks his client is available for a deposition.
|
don’t know what your availability is, but Attorney Orlando could do 12/5, 12/8, 12/11, or 12/12. Please let me
know if
those work so we can move ahead with scheduling.

Thanks,
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

EXHIBIT B
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

Cathy Arnold

From: Amanda Orlando
Sent: Friday, December 22, 2023 9:56 AM
To: Chris O'Rourke
Ce: Joseph Orlando Jr
Subject: RE: Sholds

Counsel,
Can you please send us the POA for Mr. Pinanski, per Attorney Orlando’s email, and please get back to us on availability
for the deposition of Mr. Ross-Lyons.

Thanks, and merry Christmas!

Amanda Orlando
Office Manager
Orlando & Associates, P.C.
One Western Avenue
Gloucester, MA 01930
Ph: 978-283-8100 ext. 3
Fx: 978-283-8507

From: Chris O'Rourke
Sent: Friday, December 15, 2023 2:23 PM
To: Joseph Orlando Jr
Subject: Re: Sholds

Joe - | am out of the office on vacation until Wednesday.

Chris

ChristopherJ. O'Rourke
Law Office of Christopher J. O'Rourke
1 Hollis Street, Suite 220
Wellesley, MA 02482
(Ph) 781-235-8022
(Fax) 781-235-9440
chris@orourkelawoffice.com

NOTICE: This email and any attachments may contain privileged and confidential information and is intended
for the sole use of the named recipient. If you are not the intended recipient, please notify the sender by
reply email and delete this email and any attachments from your system. Thank you.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

EXHIBIT C
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

ORLANDO
x ASS OCTATES
JosephM. Orlando, Jr., Esq
JosephM. Orlando, Esq.

ale
Brian S. McCormick, Esq
Nolan R. Young, Esq.

HP THE SCALES IN YOUR AOR"

December 28, 2023

Conant Street Beverly
152 Conant Street
Beverly, MA 01915

Re Edward Pinanski
DOB: 1/26/1950

Dear Sir/Madam

Please forward CERTIFIED copies of all medical records of treatment to the above-referenced patient from
8/22/2001 -present.

Very Truly Yours.

/s/ Joseph M. Orlando Jr.

JOSEPHM. ORLANDO JR. ESQ
JMOJR/ao

One Western Avenue @ Gloucester, Massachusetts 01930 Ph: (978) 283-8100 ® Fx (978) 283-8507
firm@orlandoassociates.com ® www.orlandoassociates.com
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

ORLANDO
& ASSOCIATES
Joseph M. Orlando, Jr., Esq
Joseph M. Orlando, Esq.
Brian S. McCormick, Esq
Nolan R. Young, Esq.

“HO-THE SCALES IX YOER EAvOR™

December 28, 2023

Portsmouth Regional Hospital
333 Borthwick Avenue
Portsmouth, NH 03801

Re: Edward Pinanski
DOB: 1/26/1950

Dear Sir/Madam:

Please forward CERTIFIED copies of all medical records of treatm
ent to the above-referenced patient from
8/22/2001-present.

Very Truly Yours,

/s/ Joseph M. Orlando Jr.

JOSEPH M. ORLANDO JR. ESQ.
JMOJR/ao

One Western Avenue @ Gloucester, Massachusetts 01930 ® Ph: (978) 283-8100 ® Fx: (978)
283-8507
firm@orlandoassociates.com ® www.orlandoassociates.com
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

ORLANDO
& ASSOCIATES
Joseph M. Orlando, Jr., Esq
Joseph M. Orlando, Esq.

le
Brian S. McCormick, Esq.

} Nolan R. Young, Esq.

“TH THLE SCALES
IN YOUR FAVOR

December 28, 2023

North Shore Neurology
83 Herrick Street
Beverly, MA 01915

Re: Edward Pinanski
DOB: 1/26/1950

Dear Sir/Madam:

Please forward CERTIFIED cop’ ies of all medical records of treatment to the above-re
ferenced patient from
8/22/2001-present.

Very Truly Yours,

/s/ Joseph M. Orlando Jr.

JOSEPH M. ORLANDO JR. ESQ.
JMOJR/ao

One Western Avenue @ Gloucester, Massachusetts 01930 ® Ph: (978) 283-8100
© Fx: (978) 283-8507
firm@orlandoassociates.com @ www.orlandoassociates.com
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

ORLANDO
& ASSOCIATES Joseph M. Orlando, Jr., Esq.
sy Joseph M. Orlando, Esq.

« |
Brian S. McCormick, Esq.
Nolan R. Young, Esq.
Y €

“HIT THE SAL ES IX YORR FAVOR

December 28, 2023

New England Coastal
152 Conant Street
Beverly, MA 01915

Re: Edward Pinanski
DOB: 1/26/1950

Dear Sir/Madam:

Please forward CERTIFIED copies of all medical records of treatment to the above-referenced patient from
8/22/2001-present.

Very Truly Yours,

4s/ Joseph M. Orlando Jr.

JOSEPH M. ORLANDO JR. ESQ.
JMOJR/ao

One Western Avenue ® Gloucester, Massachusetts 01930 ® Ph: (978) 283-8100 ® Fx: (978) 283-8507
firm@orlandoassociates.com @ www.orlandoassociates.com
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

ORLANDO
& ASSOCIATES
Joseph M. Orlando, Jr., Esq
wr Joseph M. Orlando, Esq.

@ Le
Brian S. McCormick, Esq.
Nolan R. Young, Esq.

OTP THE SCALES IX YOUR FAVOR

December 28, 2023

Beth Israel Lahey
41 Mall Road
Burlington, MA 01805

Departments:
Otolaryngology
Internal Medicine
Gastroenterology
Urology
Allergy and Immunology
Sleep Lab
Pulmonary
Orthopedics
9 Radiology
10. Neurosurgery
11. Opthamology

Re: Edward Pinanski
DOB: 1/26/1950

Dear Sir/Madam:

Please forward CERTIFIED co pies of all medical records of treatment to the above-referenced
patient from
8/22/2001-present.

Very Truly Yours,

/s/ Joseph M. Orlando Jr.

JOSEPH M. ORLANDO JR. ESQ.
JMOJR/ao

One Western Avenue @ Gloucester, Massachusetts 01930 ® Ph: (978) 283-8100 ® Fx: (978) 283-8507
firm@orlandoassociates.com # www.orlandoassociates.com
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

EXHIBIT D
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

Cathy Arnold

From: noreply-tpbus.mobility@bl.comcast.net
Sent: Wednesday, January 31, 2024 1:44 PM
To: Amanda Orlando
Subject: Comcast Business voicemail from 7817441000 - LAHEY,HOSPITAL

Comcast Business Voicemail from 7817441000 -
LAHEY,HOSPITAL.
35 seconds

Hi this is Laura calling from Lahey Medical Records just calling you back in
regard to the power of attorney for Edward penske. | did check with our
legal department and we would need a copy of that power of attorney the
acceptance of the attorney in fact says that the power of attorney was
June 2 of 17. We would just need a copy of that we need to just ensure
that it allows the release of medical records. If you wanna give me a call
back my number is 781-744-1578. Thank you.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

EXHIBIT E
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

Cathy Arnold

From: Chris O'Rourke
Sent: Thursday, February 1, 2024 4:17 PM
To: Amanda Orlando
Cc: Joseph Orlando Jr
Subject: Re: Comcast Business voicemail from 7817441000 - LAHEY,HOSPITAL

Amanda - | will discuss this with my client and let you know.

Also, the plaintiff's Answers to Interrogatories list medical expenses from North East Medical Practice as
$322,706.66. | am unable to locate a bill from them. Please let me know if that figure is accurate and forward
a copy of the bill, as the insurers need to clarify the amount of medical expenses. Thanks.

Chris

Christopher J. O'Rourke
Law Office of Christopher J. O'Rourke
1 Hollis Street, Suite 220
Wellesley, MA 02482
(Ph) 781-235-8022
(Fax) 781-235-9440
chris@orourkelawoffice.com

NOTICE: This email and any attachments may contain privileged and confidential information and is intended
for the sole use of the named recipient. If you are not the intended recipient, please notify the sender by
reply email and delete this email and any attachments from your system. Thank you.

tr nner ene et nneneetee enn ne ne renee one tae
From: Amanda Orlando
Sent: Wednesday, January 31, 2024 1:50 PM
To: Chris O'Rourke
Ce: Joseph Orlando Jr
Subject: FW: Comcast Business voicemail from 7817441000 - LAHEY,HOSPITAL

Mr. O'Rourke,
Lahey is telling us that they will need the actual power of attorney(not the Acceptance of the Power of Attorney), in
order to release the medical records of Mr. Pinanski to us. Please see voicemail below from Laura in medical records at
Lahey. Please send over the Power of Attorney.

Thanks,

Amanda Orlando, J.D.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

EXHIBIT F
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

Amanda Orlando

From: Joseph Orlando Jr
Sent: Friday, April 5, 2024 5:36 PM
To: ‘chris@orourkelawoffice.com'
Ce: Amanda Orlando
Subject: Regarding: Sholds, Patricia v Ed Pinanski - Power of Attorney Still Missing

Chris:

| hope this email already finds you having a good weekend.

Unfortunately, we still don’t have the POA that you’ve promised and another deadline is upon us. | hope you'll
assent to our motion for another extension on the issue, as your client has really caused this delay.

Let’s talk about it on Monday.

Regards,

Joseph M. Orlando, Jr., Esq.
Orlando & Associates, P.C.
One Western Avenue
Gloucester, MA 01930
Ph. (978) 283-8100
Fx. (978) 283-8507
www.orlandoassociates.com

d | , ORLANDO
@e& ASSOCIATES.
CONFIDENTIALITY NOTICE:
This email message is for the sole use of the intended recipient(s) and may contain privileged and
confidential information. Any unauthorized review, use, disclosure or distribution is prohibited. If
you received this email in error, please notify me immediately by return email.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

EXHIBIT G
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

Amanda Orlando

From: Chris O'Rourke
Sent: Tuesday, April 9, 2024 3:22 PM
To: Joseph Orlando Jr
Cc: Amanda Orlando
Subject: Re: Regarding: Sholds, Patricia v Ed Pinanski - Power of Attorney Still Missing

Joe - according to my records, | provided you with the POA Acceptance Form on 12/22. On 1/31 you
requested the entire POA form, which | agreed to discuss with my client. We haven't communicated
about it since then and | don't recall promising anything. If you want to forward your Motion, | will let you
know my position. | will not be able to assent to it, but | will let you know whether | will be submitting an
Opposition or taking no position.

Chris

Christopher J. O'Rourke
Law Office of Christopher J. O'Rourke
1 Hollis Street, Suite 220
Wellesley, MA 02482
(Ph) 781-235-8022
(Fax) 781-235-9440
chris@orourkelawoffice.com

NOTICE: This email and any attachments may contain privileged and confidential information and is intended
for the sole use of the named recipient. If you are not the intended recipient, please notify the sender by
reply email and delete this email and any attachments from your system. Thank you.

et a nn een tne enn inner
From: Joseph Orlando ir
Sent: Friday, April 5, 2024 5:36 PM
To: Chris O'Rourke
Cc: Amanda Orlando
Subject: Regarding: Sholds, Patricia v Ed Pinanski - Power of Attorney Still Missing

Chris:

| hope this email already finds you having a good weekend.

Unfortunately, we still don’t have the POA that you’ve promised and another deadline is upon us. | hope you’
assent to our motion for another extension on the issue, as your client has really caused this delay.

Let’s talk about it on Monday.
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

EXHIBIT H
Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887

Amanda Orlando

From: Chris O'Rourke
Sent: Thursday, April 11, 2024 11:36 AM
To: Joseph Orlando Jr
Ce: Amanda Orlando
Subject: Re: Regarding: Sholds, Patricia v Ed Pinanski - Power of Attorney Still Missing
Attachments: POA Redacted.pdf

Joe - attached is a redacted POA, which contains the provisions that the provider should need. | am not
authorized to provide you with the entire POA, which is private and primarily consists of provisions
entirely unrelated to this case.

Chris

Christopher J. O'Rourke
Law Office of Christopher J. O'Rourke
1 Hollis Street, Suite 220
Wellesley, MA 02482
(Ph) 781-235-8022
(Fax) 781-235-9440
chris@orourkelawoffice.com

NOTICE: This email and any attachments may contain privileged and confidential information and is intended
for the sole use of the named recipient. If you are not the intended recipient, please notify the sender by
reply email and delete this email and any attachments from your system. Thank you.

ee cannes sinennrinentienr rennin
Fro Joseph Orlando Jr
Sent: Tuesday, April 9, 2024 6:56 PM
To: Chris O'Rourke
Cc: Amanda Orlando
Subject: Re: Regarding: Sholds, Patricia v Ed Pinanski - Power of Attorney Still Missing

Chris:
We can’t get the records without the full poa, which you know. Your client has been ordered to produce
the requested records over your objection and protective order. We agreed to subpoena them to take the
work off of you. Your email is disingenuous. Please provide the POA to avoid further motion practice.
Regards,
Joe

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Document Filed Date

April 15, 2024

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September 19, 2022

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Motion,Ex Parte: Sholds, Patricia vs. Pinaski, Edward

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