Preview
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
71
COMMONWEALTH OF MASSACHUSETTS
ESSEX, ss. Essex Superior Court
Docket: 2377CV00627
Concetta Orlando,
Plaintiff
Vv.
Cynthia Bjorlie; Nicole Coles, and
Robin Hubbard
Defendants
MOTION TO QUASH SUBPOENA AND FOR A PROTECTIVE ORDER
NOW COMES nonparty Irene Frontiero and moves to quash the Plaintiff's subpoena
duces tecum in accordance with M.R.C.P. Rule 45(b), and further moves for a protective order
under M.R.C.P. Rule 26(c).
Background
On July 26, 2023 the Plaintiff served non-party witnesses with subpoena duces tecum.
Some of the non-party witnesses filed motions to quash shortly after. The Plaintiff served
motions to compel the production of documents from non-party witnesses including myself on
August 25, 2023. The Court heard arguments from the non-party witnesses and issued an order
dated September 19, 2023 limiting the scope of documents the non-party witnesses must
produce. On April 1, 2024 the same non-party witnesses were served with a 24 subpoena duces
tecum that is now the subject of this motion to quash and for a protective order.
1. Plaintiff’s request violates provision of Rule 45(d) governing time for a party to
comply with Subpoena.
The relevant portion of Rule 45(d) states “A subpoena upon a party which commands the
production of documents, electronically stored information, or things must give the party at
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
least 30 days for compliance after service thereof” (emphasis added). The Plaintiffs subpoena
was served on April 1, 2024 and demands production of the materials at her counsel’s office on
April 30, 2024, which is less time than Rule 45 requires for compliance.
Additionally, Plaintiff's subpoena seeks communications that occurred between
September 20, 2023 and April 30, 2024, which is also the date this subpoena demands these
materials be produced. This does not give a party 30 days (or 29 days in line with Plaintiff's
April | service) to comply with the subpoena — it gives exactly zero days to comply.
The April 1 service of this Subpoena does not conform to the 30-day notice rule, and
furthermore the materials demanded in the 2°“ subpoena relate to communications transmitted
during the 30 days allotted for compliance AND further demands communications that haven’t
even occurred yet. This practice cannot conform with the applicable provision(s) of Rule 45(d)
and contradicts fundamental principles of justice and fair play in providing parties fair notice of
their obligations.
2. There is no reason for the Plaintiff to believe that relevant and discoverable
materials are in the possession of nonparty witnesses.
The complaint in this matter was filed by the Plaintiff on June 26, 2023 and alleges that,
during a political dispute within the Gloucester Republican City Committee (“GRCC”) which
uncovered allegations of misconduct by the Plaintiff, the Defendants defamed her. There are no
allegations in the complaint claiming that I did anything tortious to the Plaintiff, and the record is
silent about any alleged need to obtain materials from nonparties that were generated ten months
after the case was filed.
After a hearing on September 19, 2023, Judge Barrett limited the Plaintiff’s previous
subpoena duces tecum to fewer search terms that are responsive to a significantly reduced
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
timeftame than originally requested. The subpoena duces tecum? served to nonparties on April
1, 2024 articulates no showing that the requested materials somehow relate to the Plaintiff's
claims, and absent this showing these requests are irrelevant, harassing, and constitute an undue
burden upon nonparties like myself. This court should order that the materials not be produced
just based on the irrelevant nature of the Plaintiff's request.
3. Plaintiff's Subpoena duces tecum exceeds the scope of Judge Barrett’s 09/19/23
order limiting the similar production of materials.
The Plaintiff previous subpoena requested materials similar to those now sought in this
subpoena and, after opposition to the 1 subpoena, the parties received an explicit order limiting
the Plaintiff's entitlement to those materials. Specifically, Judge Barrett stated with regard to the
scope of production:
“{t]he time period shall be 3/1/23 to 9/19/23. The Plaintiffs are only entitled to
the deponents email and text messaging as well as meeting, notices, notes or
agendas. All of the above production is limited to those materials ...”
(See 09/19/23 endorsement on motion to compel at Exhibit 1).
Despite the clear language associated with this order limiting the production of materials
to materials responsive to dates between March 1, 2023 through September 19, 2023, and
without articulating any showing of need for materials sought in the 2° subpoena, the Plaintiff
now seeks materials well exceeding the scope ordered by Judge Barrett.
Where the Plaintiff seeks irrelevant materials that exceed the scope of Judge Barrett’s
previous order, this Court should order that these materials not be produced.
1 See Exhibit 1: 09/09/2023 order from Judge Barrett.
? See Exhibit 2: Plaintiff's Subpoena duces tecum directed to Irene Frontiero dated 03/25/2024 and served April 1,
2024,
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
4, Plaintiff's Subpoena is in bad faith.
In this matter the Plaintiff has repeatedly targeted me and other nonparties with expansive
requests for materials and communications between and among the political opposition of whom
the Orlando family personally supported in the various GRCC intra-committee disputes. Many of
these political struggles within the GRCC are still ongoing to date (but have nothing to do with
the Plaintiffs case).
Despite the Plaintiff's knowledge that I and the other deponents are ancillary — at best —
to this litigation, she still seeks communications that exceed any justification based on a reading
of the facts described in the complaint; she has previously (and is likely to again) sought
sanctions and attorney’s fees related to the previous motion to compel against pro se nonparties
like myself; has violated provisions of M.R.C.P. Rule 45 in the process, all while her Counsel
has issued threats to other pro se nonparties in communications. For these reasons, I respectfully
request this Court issue an order quashing the Plaintiffs subpoena; order that the Plaintiff and
her counsel cease their harassing and burdensome tactics; and order any other relief this Court
deems as just.
Sincerely,
DATE: 04/16/2024 /s/ Irene Fronticro
Irene Frontiero
28 Fort Square
Gloucester, MA 01930
(508) 284-3541
3 See Exh 3-—April 2, 2024 communication from Attorney Orlando to Richard Maybury: “Given your willful non-
compliance, and current dishonest posture, I will be asking the Court to financially and civilly sanction you, if
necessary, for your violation ... I’m doubtful that the Court will look kindly on you so flagrantly flouting Judge
Barrett’s order.”
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
CERTIFICATE OF SERVICE
Thereby certify under the penalties of perjury that on this date I made service to all counsel on
record via email.
DATE 04/16/2024 /s/ Irene Frontiero
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
Date Filed 5/24/2024 12:01 AM
superior Court - Essex
Docket Number 2377CV00627 |
Date Filed 9/8/2023 9:50 AM
Superior Court - Essex
%
Number 2377CV00627
» 22
COMMONWEALTH OF MASSACHUSETTS
=
SR 3 ESSEX, SS SUPERIOR COURT
y
Concetta Orlando,
ve
SS
Plaintiff
Civil Action No. 2377¢v00627
x oss
8
C Cynthia Bjorlie
5s Nicole Coles
obin Hubbard
No! > Defendants
~
PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM NON
PARTY WITNESSES FRONTIERO, SOVA. DEROSA, HOBBS, SEXTON, SECREST.
AND MAYBURY
J) Gye
> é £ NOW Comes the plaintiff, Concetta O. rlando, to compel production of documents from each of
yi Qyhe non-party witnesses, who were properly served with Keeper of Records Deposition Notices
3
3 wS 3 id Subpoenas on 7/26/2023. In support of this motion the Plaintiff refers this Honorable Court
Se “),
her Memorandum of Law in Support of hér Motion, filed Contemporaneously herewith.
é Respectfully Submitted,
el IN Plaintiff by her Attorneys,
Sos
SS! XY
> 3 => 4s/ Joseph M. Orlando Jr.
Se 8 JOSEPH M. ORLANDO JR. ESQ.
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BBO #680995
JOSEPH M. ORLANDO, ESQ.
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Sop
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Orlando & Associates
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Gloucester, MA 01930
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Ph: 978-283-8100
Fx: 978-283-8507
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y a CERTIFICATE OF SERVICE
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2 ph M. Orlando Jr., Esq. attorney for the plaintiff herein, certify that I served the foregoing
gy ito for the defendants:
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a8 William E. Gens, Esq.
Gens & Stanton P.C.
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Ok
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
The Commontwealth of Massachusetts
Subpoena
Essex 3 SS.
7.!rene Frontiero(Sova), 28 Fort Square
Gloucester, MA 01930
Bou are hereby commanbed, in the name of the Commonwealth of Massachusetts, to
appear before the Superior Court at Salem
the County of. Essex on the 30th day op Aril >
in the year 2024 at 10 a.m. am/pm, and from day to day thereafter, until
the action hereinafter named is heard by said Court, to give evidence of what you know
relating to an action then and there to be heard and tried between
Concetta Orlando » Plaintiff, and
Cynthia Bijorlie, et al Defendant,
docket number 2377cv00627 , and you are further required to bring with you
See Schedule A, with Notice of Deposition, served with this Subpoena.
counsel on or before April 30, 2024.
Bereof fail not, as your failure to appear as required will subject you to such pains and
penalties as the law provides.
pater at @lOucester the ZOtN gay 9¢ March in the year
2024 /
[
ae
Notary Publ ic — Justice of ‘the Peace
ve
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
RETURN OF SERVICE
L , certify that I this day summoned the within named
to appear and give evidence at Court as directed by the attached subpoena by delivering
to
in hand, - leaving at
a copy of the subpoena together with Sees for attendance and
travel.
1 further certify that I am not a party to the above entitled action and that I am not less
than 18 years of age.
Signed under penalties of perjury this day of. , in the
year
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
COMMONWEALTH OF MASSACHUSETTS
ESSEX, SS SUPERIOR COURT
Concetta Orlando,
Plaintiff
Vv. Civil Action No. 2377¢v00627
Cynthia Bjorlie
Nicole Coles
Robin Hubbard
Defendants
To: Irene Frontiero (Sova)
28 Fort Square
Gloucester, MA 01930
Ifront28@hotmail.com
2"4 NOTICE OF DEPOSITION
Please take notice that on April 30, 2024 at 10:00 a.m. at the law offices of Orlando &
Associates, One Western Avenue, Gloucester, Massachusetts, the plaintiff, Concetta Orlando, by
her attorneys, pursuant to the applicable Massachusetts Statute, will take the keeper of records
deposition of Irene Frontiero(Sova) before a Notary Public or before some other officer
authorized by law to administer oaths. Further, the deponent is requested to provide those
documents listed in Schedule A, attached hereto.
DEPONENT IS NOT REQUIRED TO APPEAR, BUT TO PRODUCE DOCUMENTS
ONLY.
Plaintiff,
By her attorney,
/s/ Joseph M. Orlando Jr.
Joseph M. Orlando, Jr., Esq.
BBO# 680995
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
Joseph M. Orlando, Esq.
BBO #380215
Orlando & Associates
One Western Avenue
Gloucester, MA 01930
Ph. (978) 283-8100
Fx. (978) 283-8507
jmorlandojr@orlandoassociates.com
Certificate of Service
I, Joseph M. Orlando, Jr., Esq.
Hereby certify that I have caused
A copy of the foregoing to be
Served upon the Deponent.
Date: 3/25/2024 4s Joseph M. Orlando Jr.
SIGNATURE
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
Schedule A
The deponent is required to produce all documents in his/her possession, custody, or control
responsive to the following requests and categories discoverable and relevant to the instant
litigation. The requests apply to all material in the deponent’s possession, custody, or control
from September 20, 2023-April 30, 2024.
Documents may be submitted via email to carnold@orlandoassociates.com.
The following documents are sought in accordance with the court’s order dated 9/19/2023.
1. All written, tangible, or electronic, communications, including, but not limited to letters,
emails, text messages, memoranda, notes, agendas, or any other written document by,
between, or inclusive of the deponent and the defendants:
a. Cynthia Bjorlie,
b. Nicole Coles,
¢. and Robin Hubbard.
All meeting notices, notes, or agendas for any meeting which included the deponent and
any of the defendants.
All written communication, including, but not limited to, emails, text messages, letters,
social media private messages, social media posts, which include the following search
terms:
Concetta or Connie Orlando;
Criminal Ilegalities;
Criminal Enterprise;
Voter Fraud;
Tax Fraud;
Crime Family;
Ashley Sullivan.
Date Filed 5/24/2024 12:01 AM
Superior Court - Essex
Docket Number 2377CV00627
Date Filed 8/2/2002 0%MAM
Superior Court - Essex
Docket Number 2377CV00627
ORLANDO
& ASSOCIATES Joseph M. Orlando, Jr., Esq,
ale
Joseph M. Orlando, Esq
Brian $, McCormick, Esq
Nolan R. Young, Esq
SPREE SCALES IN YOUR TAVON™
April 2, 2024
Richard “Rick” Maybury
One Squam Hollow
Rockport, MA 01966
‘ickmaybury757@gmail.com
maybury@kjigs.org
Re: Concetta Orlando v. Bjorlie, Coles, Hubbard
Civil Action No. 2377cv00627
Dear Mr. Maybury:
In response to your email of 4/2/2024, claiming to have no responsive documents to the 2 subpoenas which
have been served upon you to date, please be advised of the following.
The schedule A attached to the Subpoena and Notice of Deposition listed a number of discoverable topics, not
just “that pertain to the lawsuit or specifically mention Connie or Joe senior.”
That is not the scope of discovery, and since you are not a judge, it’s not up to you to decide whether a
document in your possession should be produced.
Here are the documents, court ordered by Judge Barrett on September 19, 2023, for you to produce(from
March 1, 2023-April 30, 2024):
The following documents are sought in accordance with the court’s order dated 9/19/2023:
1 All written, tangible, or electronic, communications, including, but not limited to letters, emails, >
text messages, memoranda, notes, agendas, or any other written document by, between, or
inclusive of the deponent and the defendants:
Cynthia Bjorlie,
Nicole Coles,
and Robin Hubbard.
One Western Avenue ® Gloucester, Massachusetts 01930 Ph: (978) 283-8100 @ Fx: (978) 283-8507
firm@orlandoassociates.com ® www.orlandoassociates.com
Date Filed 8/2/7002 0%MAM
Superior Court - Essex
Docket Number 2377CV00627
All meeting notices, notes, or agendas for any meeting which included the deponent and any of the
defendants.
All written communication, including, but not limited to, emails, text messages, letters, social
media private messages, social media posts, which include the following search terms:
Concetta or Connie Orlando;
Criminal Illegalities;
Criminal Enterprise;
Voter Fraud;
Tax Fraud;
Crime Family;
Ashley Sullivan.
Please be aware that because subpoenas were served on multiple individuals, we are already in possession of
some of the communications you have had that are responsive to the subpoena. We also know that you
regularly wrote to Ashley Sullivan, and about Ashley Sullivan to others, up to as recently as March 1, 2024.
All communications which exist between you and ANY INDIVIDUAL, about the topics listed in a-g, are
discoverable, and they have already been court ordered. ALL communications between you and any of the
defendants are discoverable.
You are being untruthful claiming you don’t have documents.
Given your willful non-compliance, and current dishonest posture, I will be asking the Court to financially
and civilly sanction you, if necessary, for your violation.
Please produce ALL responsive documents by April 30, 2024. Otherwise, I will see you at the hearing on May
16, 2024. I’m doubtful that the Court will look kindly on you so flagrantly flouting Judge Barrett’s order.
Very Truly Yours,
/s/ Joseph M. Orlando Jr. Esq.
JOSEPH M. ORLANDO JR. ESQ.
JMOSJR/caa
One Western Avenue @ Gloucester, Massachusetts 01930 # Ph: (978) 283-8100 ® Fx: (978) 283-8507
firm@orlandoassociates.com ® www.orlandoassociates.com
Preview
Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 71 COMMONWEALTH OF MASSACHUSETTS ESSEX, ss. Essex Superior Court Docket: 2377CV00627 Concetta Orlando, Plaintiff Vv. Cynthia Bjorlie; Nicole Coles, and Robin Hubbard Defendants MOTION TO QUASH SUBPOENA AND FOR A PROTECTIVE ORDER NOW COMES nonparty Irene Frontiero and moves to quash the Plaintiff's subpoena duces tecum in accordance with M.R.C.P. Rule 45(b), and further moves for a protective order under M.R.C.P. Rule 26(c). Background On July 26, 2023 the Plaintiff served non-party witnesses with subpoena duces tecum. Some of the non-party witnesses filed motions to quash shortly after. The Plaintiff served motions to compel the production of documents from non-party witnesses including myself on August 25, 2023. The Court heard arguments from the non-party witnesses and issued an order dated September 19, 2023 limiting the scope of documents the non-party witnesses must produce. On April 1, 2024 the same non-party witnesses were served with a 24 subpoena duces tecum that is now the subject of this motion to quash and for a protective order. 1. Plaintiff’s request violates provision of Rule 45(d) governing time for a party to comply with Subpoena. The relevant portion of Rule 45(d) states “A subpoena upon a party which commands the production of documents, electronically stored information, or things must give the party at Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 least 30 days for compliance after service thereof” (emphasis added). The Plaintiffs subpoena was served on April 1, 2024 and demands production of the materials at her counsel’s office on April 30, 2024, which is less time than Rule 45 requires for compliance. Additionally, Plaintiff's subpoena seeks communications that occurred between September 20, 2023 and April 30, 2024, which is also the date this subpoena demands these materials be produced. This does not give a party 30 days (or 29 days in line with Plaintiff's April | service) to comply with the subpoena — it gives exactly zero days to comply. The April 1 service of this Subpoena does not conform to the 30-day notice rule, and furthermore the materials demanded in the 2°“ subpoena relate to communications transmitted during the 30 days allotted for compliance AND further demands communications that haven’t even occurred yet. This practice cannot conform with the applicable provision(s) of Rule 45(d) and contradicts fundamental principles of justice and fair play in providing parties fair notice of their obligations. 2. There is no reason for the Plaintiff to believe that relevant and discoverable materials are in the possession of nonparty witnesses. The complaint in this matter was filed by the Plaintiff on June 26, 2023 and alleges that, during a political dispute within the Gloucester Republican City Committee (“GRCC”) which uncovered allegations of misconduct by the Plaintiff, the Defendants defamed her. There are no allegations in the complaint claiming that I did anything tortious to the Plaintiff, and the record is silent about any alleged need to obtain materials from nonparties that were generated ten months after the case was filed. After a hearing on September 19, 2023, Judge Barrett limited the Plaintiff’s previous subpoena duces tecum to fewer search terms that are responsive to a significantly reduced Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 timeftame than originally requested. The subpoena duces tecum? served to nonparties on April 1, 2024 articulates no showing that the requested materials somehow relate to the Plaintiff's claims, and absent this showing these requests are irrelevant, harassing, and constitute an undue burden upon nonparties like myself. This court should order that the materials not be produced just based on the irrelevant nature of the Plaintiff's request. 3. Plaintiff's Subpoena duces tecum exceeds the scope of Judge Barrett’s 09/19/23 order limiting the similar production of materials. The Plaintiff previous subpoena requested materials similar to those now sought in this subpoena and, after opposition to the 1 subpoena, the parties received an explicit order limiting the Plaintiff's entitlement to those materials. Specifically, Judge Barrett stated with regard to the scope of production: “{t]he time period shall be 3/1/23 to 9/19/23. The Plaintiffs are only entitled to the deponents email and text messaging as well as meeting, notices, notes or agendas. All of the above production is limited to those materials ...” (See 09/19/23 endorsement on motion to compel at Exhibit 1). Despite the clear language associated with this order limiting the production of materials to materials responsive to dates between March 1, 2023 through September 19, 2023, and without articulating any showing of need for materials sought in the 2° subpoena, the Plaintiff now seeks materials well exceeding the scope ordered by Judge Barrett. Where the Plaintiff seeks irrelevant materials that exceed the scope of Judge Barrett’s previous order, this Court should order that these materials not be produced. 1 See Exhibit 1: 09/09/2023 order from Judge Barrett. ? See Exhibit 2: Plaintiff's Subpoena duces tecum directed to Irene Frontiero dated 03/25/2024 and served April 1, 2024, Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 4, Plaintiff's Subpoena is in bad faith. In this matter the Plaintiff has repeatedly targeted me and other nonparties with expansive requests for materials and communications between and among the political opposition of whom the Orlando family personally supported in the various GRCC intra-committee disputes. Many of these political struggles within the GRCC are still ongoing to date (but have nothing to do with the Plaintiffs case). Despite the Plaintiff's knowledge that I and the other deponents are ancillary — at best — to this litigation, she still seeks communications that exceed any justification based on a reading of the facts described in the complaint; she has previously (and is likely to again) sought sanctions and attorney’s fees related to the previous motion to compel against pro se nonparties like myself; has violated provisions of M.R.C.P. Rule 45 in the process, all while her Counsel has issued threats to other pro se nonparties in communications. For these reasons, I respectfully request this Court issue an order quashing the Plaintiffs subpoena; order that the Plaintiff and her counsel cease their harassing and burdensome tactics; and order any other relief this Court deems as just. Sincerely, DATE: 04/16/2024 /s/ Irene Fronticro Irene Frontiero 28 Fort Square Gloucester, MA 01930 (508) 284-3541 3 See Exh 3-—April 2, 2024 communication from Attorney Orlando to Richard Maybury: “Given your willful non- compliance, and current dishonest posture, I will be asking the Court to financially and civilly sanction you, if necessary, for your violation ... I’m doubtful that the Court will look kindly on you so flagrantly flouting Judge Barrett’s order.” Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 CERTIFICATE OF SERVICE Thereby certify under the penalties of perjury that on this date I made service to all counsel on record via email. DATE 04/16/2024 /s/ Irene Frontiero Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 Date Filed 5/24/2024 12:01 AM superior Court - Essex Docket Number 2377CV00627 | Date Filed 9/8/2023 9:50 AM Superior Court - Essex % Number 2377CV00627 » 22 COMMONWEALTH OF MASSACHUSETTS = SR 3 ESSEX, SS SUPERIOR COURT y Concetta Orlando, ve SS Plaintiff Civil Action No. 2377¢v00627 x oss 8 C Cynthia Bjorlie 5s Nicole Coles obin Hubbard No! > Defendants ~ PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM NON PARTY WITNESSES FRONTIERO, SOVA. DEROSA, HOBBS, SEXTON, SECREST. AND MAYBURY J) Gye > é £ NOW Comes the plaintiff, Concetta O. rlando, to compel production of documents from each of yi Qyhe non-party witnesses, who were properly served with Keeper of Records Deposition Notices 3 3 wS 3 id Subpoenas on 7/26/2023. In support of this motion the Plaintiff refers this Honorable Court Se “), her Memorandum of Law in Support of hér Motion, filed Contemporaneously herewith. é Respectfully Submitted, el IN Plaintiff by her Attorneys, Sos SS! XY > 3 => 4s/ Joseph M. Orlando Jr. Se 8 JOSEPH M. ORLANDO JR. ESQ. e9 bs SY | —~) BBO #680995 JOSEPH M. ORLANDO, ESQ. eS BBO #380215 Sop 2a Orlando & Associates vs =~ ov I Western Avenue — sf 3 Gloucester, MA 01930 a 2 Ph: 978-283-8100 Fx: 978-283-8507 Q jmorlandoir@orlandoassociates.com y a CERTIFICATE OF SERVICE uw Se 3? L 2 ph M. Orlando Jr., Esq. attorney for the plaintiff herein, certify that I served the foregoing gy ito for the defendants: AS re a8 William E. Gens, Esq. Gens & Stanton P.C. m~ Oy Re cS “p 2s SO @ Ok Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 The Commontwealth of Massachusetts Subpoena Essex 3 SS. 7.!rene Frontiero(Sova), 28 Fort Square Gloucester, MA 01930 Bou are hereby commanbed, in the name of the Commonwealth of Massachusetts, to appear before the Superior Court at Salem the County of. Essex on the 30th day op Aril > in the year 2024 at 10 a.m. am/pm, and from day to day thereafter, until the action hereinafter named is heard by said Court, to give evidence of what you know relating to an action then and there to be heard and tried between Concetta Orlando » Plaintiff, and Cynthia Bijorlie, et al Defendant, docket number 2377cv00627 , and you are further required to bring with you See Schedule A, with Notice of Deposition, served with this Subpoena. counsel on or before April 30, 2024. Bereof fail not, as your failure to appear as required will subject you to such pains and penalties as the law provides. pater at @lOucester the ZOtN gay 9¢ March in the year 2024 / [ ae Notary Publ ic — Justice of ‘the Peace ve Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 RETURN OF SERVICE L , certify that I this day summoned the within named to appear and give evidence at Court as directed by the attached subpoena by delivering to in hand, - leaving at a copy of the subpoena together with Sees for attendance and travel. 1 further certify that I am not a party to the above entitled action and that I am not less than 18 years of age. Signed under penalties of perjury this day of. , in the year Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 COMMONWEALTH OF MASSACHUSETTS ESSEX, SS SUPERIOR COURT Concetta Orlando, Plaintiff Vv. Civil Action No. 2377¢v00627 Cynthia Bjorlie Nicole Coles Robin Hubbard Defendants To: Irene Frontiero (Sova) 28 Fort Square Gloucester, MA 01930 Ifront28@hotmail.com 2"4 NOTICE OF DEPOSITION Please take notice that on April 30, 2024 at 10:00 a.m. at the law offices of Orlando & Associates, One Western Avenue, Gloucester, Massachusetts, the plaintiff, Concetta Orlando, by her attorneys, pursuant to the applicable Massachusetts Statute, will take the keeper of records deposition of Irene Frontiero(Sova) before a Notary Public or before some other officer authorized by law to administer oaths. Further, the deponent is requested to provide those documents listed in Schedule A, attached hereto. DEPONENT IS NOT REQUIRED TO APPEAR, BUT TO PRODUCE DOCUMENTS ONLY. Plaintiff, By her attorney, /s/ Joseph M. Orlando Jr. Joseph M. Orlando, Jr., Esq. BBO# 680995 Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 Joseph M. Orlando, Esq. BBO #380215 Orlando & Associates One Western Avenue Gloucester, MA 01930 Ph. (978) 283-8100 Fx. (978) 283-8507 jmorlandojr@orlandoassociates.com Certificate of Service I, Joseph M. Orlando, Jr., Esq. Hereby certify that I have caused A copy of the foregoing to be Served upon the Deponent. Date: 3/25/2024 4s Joseph M. Orlando Jr. SIGNATURE Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 Schedule A The deponent is required to produce all documents in his/her possession, custody, or control responsive to the following requests and categories discoverable and relevant to the instant litigation. The requests apply to all material in the deponent’s possession, custody, or control from September 20, 2023-April 30, 2024. Documents may be submitted via email to carnold@orlandoassociates.com. The following documents are sought in accordance with the court’s order dated 9/19/2023. 1. All written, tangible, or electronic, communications, including, but not limited to letters, emails, text messages, memoranda, notes, agendas, or any other written document by, between, or inclusive of the deponent and the defendants: a. Cynthia Bjorlie, b. Nicole Coles, ¢. and Robin Hubbard. All meeting notices, notes, or agendas for any meeting which included the deponent and any of the defendants. All written communication, including, but not limited to, emails, text messages, letters, social media private messages, social media posts, which include the following search terms: Concetta or Connie Orlando; Criminal Ilegalities; Criminal Enterprise; Voter Fraud; Tax Fraud; Crime Family; Ashley Sullivan. Date Filed 5/24/2024 12:01 AM Superior Court - Essex Docket Number 2377CV00627 Date Filed 8/2/2002 0%MAM Superior Court - Essex Docket Number 2377CV00627 ORLANDO & ASSOCIATES Joseph M. Orlando, Jr., Esq, ale Joseph M. Orlando, Esq Brian $, McCormick, Esq Nolan R. Young, Esq SPREE SCALES IN YOUR TAVON™ April 2, 2024 Richard “Rick” Maybury One Squam Hollow Rockport, MA 01966 ‘ickmaybury757@gmail.com maybury@kjigs.org Re: Concetta Orlando v. Bjorlie, Coles, Hubbard Civil Action No. 2377cv00627 Dear Mr. Maybury: In response to your email of 4/2/2024, claiming to have no responsive documents to the 2 subpoenas which have been served upon you to date, please be advised of the following. The schedule A attached to the Subpoena and Notice of Deposition listed a number of discoverable topics, not just “that pertain to the lawsuit or specifically mention Connie or Joe senior.” That is not the scope of discovery, and since you are not a judge, it’s not up to you to decide whether a document in your possession should be produced. Here are the documents, court ordered by Judge Barrett on September 19, 2023, for you to produce(from March 1, 2023-April 30, 2024): The following documents are sought in accordance with the court’s order dated 9/19/2023: 1 All written, tangible, or electronic, communications, including, but not limited to letters, emails, > text messages, memoranda, notes, agendas, or any other written document by, between, or inclusive of the deponent and the defendants: Cynthia Bjorlie, Nicole Coles, and Robin Hubbard. One Western Avenue ® Gloucester, Massachusetts 01930 Ph: (978) 283-8100 @ Fx: (978) 283-8507 firm@orlandoassociates.com ® www.orlandoassociates.com Date Filed 8/2/7002 0%MAM Superior Court - Essex Docket Number 2377CV00627 All meeting notices, notes, or agendas for any meeting which included the deponent and any of the defendants. All written communication, including, but not limited to, emails, text messages, letters, social media private messages, social media posts, which include the following search terms: Concetta or Connie Orlando; Criminal Illegalities; Criminal Enterprise; Voter Fraud; Tax Fraud; Crime Family; Ashley Sullivan. Please be aware that because subpoenas were served on multiple individuals, we are already in possession of some of the communications you have had that are responsive to the subpoena. We also know that you regularly wrote to Ashley Sullivan, and about Ashley Sullivan to others, up to as recently as March 1, 2024. All communications which exist between you and ANY INDIVIDUAL, about the topics listed in a-g, are discoverable, and they have already been court ordered. ALL communications between you and any of the defendants are discoverable. You are being untruthful claiming you don’t have documents. Given your willful non-compliance, and current dishonest posture, I will be asking the Court to financially and civilly sanction you, if necessary, for your violation. Please produce ALL responsive documents by April 30, 2024. Otherwise, I will see you at the hearing on May 16, 2024. I’m doubtful that the Court will look kindly on you so flagrantly flouting Judge Barrett’s order. Very Truly Yours, /s/ Joseph M. Orlando Jr. Esq. JOSEPH M. ORLANDO JR. ESQ. JMOSJR/caa One Western Avenue @ Gloucester, Massachusetts 01930 # Ph: (978) 283-8100 ® Fx: (978) 283-8507 firm@orlandoassociates.com ® www.orlandoassociates.com