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will also hear Plaintiff's motion on her request to strike Defendants’ interlocutory appeal (Paper
#57).
SO ORDERED.
Ned
Lynn C. Rt ey
Justice of uperior Court
Dated: May 16, 2024
The Court conducted a hearing on May 16, 2024. Counsel for the Defendants did not
appear and new counsel filed an appearance on behalf of Clayton Sova and Richard Maybury.
Mary Pat DeRosa, Irene Frontiero and Kelly Secrest appeared and proceeded without counsel.
Steven Sexton did not appear.
Counsel on behalf of Sova and Maybury withdrew their motions to quash (Papers #43,
#44, #45, #46, #48, & #49). Kelly Secrest brought forty-four documents responsive to the
amended Schedule A on behalf of Steven Sexton which were provided to Plaintiff's counsel.
Mary Pat DeRosa, Irene Frontiero, and Kelly Secrest, each asserted that although they
have documents in their possession that are responsive to the Amended Schedule A, they decline
to provide them alleging each document is protected by “political privilege and attorney client
privilege”. Counsel on behalf of Clayton Sova and Richard Maybury also asserted that each
witness has documents responsive to the Amended Schedule A but decline to provide them
alleging each document is protected by “political privilege and attorney client privilege”.
The Court orders the following:
Each witness is to submit a privilege log that identifies each document which they
maintain is privileged. The log shall contain (1) the nature of the document; (2) the
creator(s) of the document; (3) the recipient(s) of the document; (4) the date the
document was created; and (5) the nature of the privilege claimed. These logs are to
be provided to the Court and counsel no later than May 23, 2024.
The Court will hold a hearing on June 7, 2024 at 10:00 am in person to address the
privilege assertions and will hear the non-party witnesses on their motions to quash the second
subpoena duces tecum issued by Plaintiff on April 24, 2024 seeking additional documents under
the amended Schedule A for dates between September 20, 2023 through April 2024. The Court
WY
COMMONWEALTH OF MASSACHUSETTS
ESSEX, ss. SUPERIOR COURT
CIVIL ACTION
No. 2377CV00627
CONCETTA ORLANDO
ys.
CYNTHIA BJORLIE & others!
ORDER ON
PLAINTIFF’S MOTION TO COMPEL (Paper #33)
On September 19, 2023, following a hearing on Plaintiff's Motion to Compel Production
of Documents, (Paper #22) Barrett, J. amended Schedule A to require production of all emails,
text messages, meeting notes and/or agendas created between March 1, 2023 and September
19, 2023 that contain any of the following terms: Concetta or Connie Orlando, Criminal
illegalities, Criminal enterprise, Voter fraud, Tax fraud, Crime family and Ashley Sullivan,
That order was directed to non-party witnesses Ralph Hobbs, Mary Pat DeRosa, Irene Frontiero,
Clayton Sova, Kelly Secrest, Steven Sexton and Richard Maybury. The only witness who
complied with that Order was Ralph Hobbs.
Plaintiff filed a second Motion to Compel (Paper #33). Clayton Sova and Richard
Maybury filed ex-parte motions to quash (Papers #43, #44, #45, #45, #48 & #49). The Court
denied the request for an ex-parte hearing, provisionally impounded Papers #43, #44, #45, #46
#48 & #49, and scheduled all pending motions to be heard on May 16, 2024.
' Nicole Coles and Robin Hubbard
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will also hear Plaintiff's motion on her request to strike Defendants’ interlocutory appeal (Paper #57). SO ORDERED. Ned Lynn C. Rt ey Justice of uperior Court Dated: May 16, 2024 The Court conducted a hearing on May 16, 2024. Counsel for the Defendants did not appear and new counsel filed an appearance on behalf of Clayton Sova and Richard Maybury. Mary Pat DeRosa, Irene Frontiero and Kelly Secrest appeared and proceeded without counsel. Steven Sexton did not appear. Counsel on behalf of Sova and Maybury withdrew their motions to quash (Papers #43, #44, #45, #46, #48, & #49). Kelly Secrest brought forty-four documents responsive to the amended Schedule A on behalf of Steven Sexton which were provided to Plaintiff's counsel. Mary Pat DeRosa, Irene Frontiero, and Kelly Secrest, each asserted that although they have documents in their possession that are responsive to the Amended Schedule A, they decline to provide them alleging each document is protected by “political privilege and attorney client privilege”. Counsel on behalf of Clayton Sova and Richard Maybury also asserted that each witness has documents responsive to the Amended Schedule A but decline to provide them alleging each document is protected by “political privilege and attorney client privilege”. The Court orders the following: Each witness is to submit a privilege log that identifies each document which they maintain is privileged. The log shall contain (1) the nature of the document; (2) the creator(s) of the document; (3) the recipient(s) of the document; (4) the date the document was created; and (5) the nature of the privilege claimed. These logs are to be provided to the Court and counsel no later than May 23, 2024. The Court will hold a hearing on June 7, 2024 at 10:00 am in person to address the privilege assertions and will hear the non-party witnesses on their motions to quash the second subpoena duces tecum issued by Plaintiff on April 24, 2024 seeking additional documents under the amended Schedule A for dates between September 20, 2023 through April 2024. The Court WY COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. SUPERIOR COURT CIVIL ACTION No. 2377CV00627 CONCETTA ORLANDO ys. CYNTHIA BJORLIE & others! ORDER ON PLAINTIFF’S MOTION TO COMPEL (Paper #33) On September 19, 2023, following a hearing on Plaintiff's Motion to Compel Production of Documents, (Paper #22) Barrett, J. amended Schedule A to require production of all emails, text messages, meeting notes and/or agendas created between March 1, 2023 and September 19, 2023 that contain any of the following terms: Concetta or Connie Orlando, Criminal illegalities, Criminal enterprise, Voter fraud, Tax fraud, Crime family and Ashley Sullivan, That order was directed to non-party witnesses Ralph Hobbs, Mary Pat DeRosa, Irene Frontiero, Clayton Sova, Kelly Secrest, Steven Sexton and Richard Maybury. The only witness who complied with that Order was Ralph Hobbs. Plaintiff filed a second Motion to Compel (Paper #33). Clayton Sova and Richard Maybury filed ex-parte motions to quash (Papers #43, #44, #45, #45, #48 & #49). The Court denied the request for an ex-parte hearing, provisionally impounded Papers #43, #44, #45, #46 #48 & #49, and scheduled all pending motions to be heard on May 16, 2024. ' Nicole Coles and Robin Hubbard