Preview
Date Filed 12/14/2023 11:48 AM
‘Superior Court - Essex
Docket Number 2377CV00627
36.1
COMMONWEALTH OF MASSACHUSETTS
ESSEX, SS SUPERIOR COURT
Concetta Orlando,
Plaintiff
Vv. Civil Action No. 2377cv00627
Cynthia Bjorlie
Nicole Coles
Robin Hubbard
Defendants
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PLAINTIFF’S MEMORANDUM OF LAW IN SUPPORT OF HER MOTION FOR
LEAVE TO FILE SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO
DEFENDANTS’ SPECIAL MOTION TO DISMISS
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The plaintiff submits the within Memorandum of Law.
Introduction
The recently received ddcuments from the non-party witnesses speak directly to material issues
argued by the parties during the hearing on 12/7/2023. Should the court find that the plaintiff is
a limited public figure, the documents which are submitted herewith demonstrate actual malice
by the defendants in their published defamatory activity.
Additionally, the documents produced demonstrate the defendants’ ulterior motive in contacting
government entities, which belies their argument that they were engaged in protected petitioning
activity. Last, the documents show clearly that the defendants’ allegations about the plaintiff
were personal towards plaintiff and her family, where they include the following statements by
defendants in their own words
Hubbard Email 5/20/2023: Thanks and enjoy the rain. It is much more pleasant than
Amanda,” (Plaintiff's Supplemental Memorandum of Law, Exhibit 1)
Hubbard Text 6/15/2023: “BOBO will investigate Joe scumbag when and only when there is a
conviction. ” (Plaintiffs Supplemental Memorandum of Law, Exhibit 2)
Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
Hubbard Email 6/26/2023: My best advice is to link the senior Orlandos voting behavior with the
chair and Amanda. Develop a narrative that hypothecates that Ashley and Amanda have known
and been privy to their voting behavior and in fact facilitated it. Pin the responsibility on
Amanda and Ashley. I is an egregious violation of trust and make it their handiwork.”
(Plaintiff's Supplemental Memorandum of Law, Exhibit 3)
Hubbard Email 8/7/2023: “.... can get interested in countersuing the O's and they will rue the
day they ever conducted themselves the way in which they did and, cherry on top, sued us. We
need to get rid of |these, people once and for all.” (Plaintiff's Supplemental Memorandum of
Law, Exhibit 4). boy
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Factual Background
The plaintiff: filed her Complaint on June 26, 2023(Doc. 1).
On June 27, 2023, the plaintiff served an evidence preservation letter upon 7 non-party
witnesses: Mary Pat Derosa, Irene Frontiero, Ralph “Bud” Hobbs, Richard Maybury,
Kelly Secrest, Steven “Brent” Sexton, and Clayton Sova(Exhibit B: Evidence
Preservation Letter).
On July 26, 2023, each of the seven non-party witnesses were properly served with
Keeper of Records Deposition Notices and Subpoenas to produce documents(Exhibit C:
Returns of Service)
The KOR Deposition Notices required production of documents by August 24, 2023.
None of the seven witnesses produced documents by this deadline.
On August 25,/2023, the plaintiff served a Motion to Compel on each of the seven non-
party witnesses(Boc, 22).
On September 119, 2023, at hearing before the Honorable Judge Barrett, the Court issued
an order regarding Plaintiff's Motion to Compel Documents from non-party witnesses.
The court’s order stated that the motion was allowed: “Allowed in part-all parties are
required to respond to the ScheduleA with the following modifications. The 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 discovery
production is limited to those materials that have the following terms or search terms: 1.
Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
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Concetta or Connie Orlando; 2. Criminal illegalities; 3. Criminal enterprise; 4. Voter
fraud; 5. Tax fraud; 6 Crime family; 7. Ashley Sullivan.”
8. Judge Barrett allowed an additional 60 days, up to and including November 19, 2023, for
the seven non-patty witnesses to produce the documents.
9. On November i3, 2023, Hobbs produced documents to plaintiff's counsel, in compliance
with the Order.’
10. None of the other witnesses produced documents by the deadline of November 19, 2023.
11. On November 20, 2023, the plaintiff served Motion to Compel and for Sanctions upon
Derosa, Frontiero, Maybury, Secrest, Sexton, and Sova, for non-compliance with Judge
Barrett’s September 19, 2023 order(Doc. 33).
12. In the letter serving this motion upon these 6 non-party witnesses, the plaintiff advised
that the motion’ would be filed, pursuant to M.R.C:P. 9A, on Monday, December 4,
2023.(Exhibit D: Letter dated 11/20/2023).
13. In the last two weeks of November, documents/communications evidencing the
defendants’ continued defamatory actions and statements towards the plaintiff were
forwarded to plaintiff's counsel and staff.
14. In the afternoon df Friday, December 1, 2023, Derosa, Frontiero, Secrest, Sexton, and
Sova produced'documents to plaintiff's counsel’s office.
15. Frontiero and Sova produced a letter indicating that they were withholding discoverable
documents basedjon their opinion that the materials were “irrelevant or embarrassing.”
(Exhibit E: Letter from Frontiero/Sova received 12/1/2023).
16. Secrest and Sexton produced a letter indicating that they were withholding discoverable
documents based on their opinion that the materials were “irrelevant or embarrassing.”
(Exhibit F: Letter from Secrest/Sova received 12/1/2023).
17. The 11" hour production of documents by the non-party witnesses, though woefully
inadequate andclearly withholding responsive documents, has revealed some additional
documents which evidence the defendants’ ulterior motives in their defamatory
statements about the plaintiff, which belies their argument that they engaged in valid
petitioning activity.
18. The documents produced also speak to the defendants’ personal and malicious motive
towards plaintiff and her family.
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Date Filed 12/14/2023 11:48 AM
‘Superior Court - Essex
ket Number 2377CV00627
19. Due to the fact that the non-party witnesses waited until the 11" hour to produce
documents in the first instance, the plaintiff was unable to review, and provide these
relevant documents to the court within the 9A period of service prior to the 12/7/2023
scheduled hearing.
20. One of the documents produced is an email from defendant Robin Hubbard to the co-
defendants and to non party witnesses, demonstrating clearly their ulterior motive in
alleging crimes against the plaintiff.
i Legal Standard
Rule 9A of the Massachusetts Superior Court Rules provides that "[p]apers not served with
the motion or opposition may be filed only with the leave of court."
Lisciotti v. Lattanzio. 2006 Mass. Super. LEXIS 427. *2
Newly discovered eviderice is admissible if it has relevance to the material issue and other
evidence presented: “Evidence that does not qualify as newly discovered may nevertheless have
a reasonable bearing on the weight and reliability of other evidence that is newly discovered for
purposes of a new trial!” Leavitt v. Mizner, 404 Mass. 81. 82. 533 N.E.2d 1334. 1335. 1989
Mass. LEXIS 46, *1 :
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Argument
The materials received by the plaintiff's counsel are newly discovered evidence which point to
the defendants’ ulterior motives in contacting government agencies and alleging that the plaintiff
had committed crimes such as “voter fraud,” and “tax fraud.” The case law, which plaintiff
provided to the Court iin her Opposition to the Defendants’ Special Motion to Dismiss(Doc.
29.1), is clear that wire a party has an ulterior motive in contacting a government agency, their
action is not protected petitioning activity. Additionally, the documents speak clearly to the
personal and malicious motivation of the defendants in publishing false statements about the
plaintiff. Should the court rule that plaintiff is a public figure, these documents demonstrate the
defendants’ actual malice.
The non-party witnesses have been colluding with the defendants for months to withhold
discoverable documents from the plaintiff. This collusion was highlighted for the court at the
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hearing on December 7, 2023, when non-party witness Irene Frontiero entered the counsel area
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Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
to talk with defendants? counsel during the hearing. The court will recall that Ms. Frontiero had
to be instructed to leave the area and return to the gallery, when plaintiff's counsel objected to
her communications with the defendants’ counsel, who does not represent her.
The fact that the non party witnesses willfully withheld discoverable documents from plaintiff,
and, at the 11" hour, pro duced inadequate responses anyway, demonstrates the extent of the
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collusion. Since the non-party witnesses intentionally withheld discoverable documents which
they unilaterally deemed /“embarrassing,” it is likely that those withheld documents further
illustrate the collusion and ulterior motives/malicious intent of the defendants. Once the plaintiff
received document production at the late hour, the references to the defendants’ ulterior motives
were made patently obvious, and those documents should be provided to the Court for its
consideration of the Defendants’ Special Motion to Dismiss(Doc. 29). Had the non-party
witnesses not colluded with the defendants to evade discovery production until the 11" hour,
these materials would have been available to the plaintiff months ago.
The fact that they were' produced just days before the hearing was clearly calculated. However,
these documents are on point to the material issues which were argued at hearing, namely, that
the defendants engaging in “petitioning” of government entities with an ulterior motive and
defamed the plaintiff with actual malice. As such, the documents attached to Plaintiff's Proposed
Supplemental Memorandum, are relevant.
Wherefore, the plaintiff requests leave of the court to file a Supplemental Memorandum,
attaching newly discovered evidence of defendants’ ulterior motive in “petitioning” government
entities, belying their argument that they engaged in protected activity, to the Court.
Respectfully Submitted,
Plaintiff by her Attorneys,
/s/ Joseph M. Orlando Jr.
JOSEPH M. ORLANDO JR. ESQ.
BBO #680995
JOSEPH M. ORLANDO, ESQ.
BBO #380215
Orlando & Associates
Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
1 Western Avenue
Gloucester, MA 01930
Ph: 978-283-8100
Fx: 978-283-8507
jmorlandojr@orlandoassociates.com
CERTIFICATE OF SERVICE
I, Joseph M. Orlando Tr 'Bsq, attorney for the plaintiff herein, certify that I served the foregoing
to counsel for the defendants:
I
William E. Gens, Esq.
Gens & Stanton P.C.
12 Ericsson Street 2" Floor
Boston, MA 02122
billgens@genslawoffices.com
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On this 13" day of December, 2023. /s/ Joseph M. Orlando Jr., Esq.
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Date Filed 12/14/2023 11:48 AM
Superior Court - eX
Docket Number 2377CV00627
EXHIBIT A
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Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
COMMONWEALTH OF MASSACHUSETTS
1
ESSEX, SS Il SUPERIOR COURT
CONCETTA ORLANDO,
Plaintiff
v. {t Civil Action No. 2377cv00627
CYNTHIA BJORLIE, '
NICOLE COLES, and
ROBIN HUBBARD.
Defendants
PLAINTIFF’S SUPPLEMENTAL MEMORANDUM IN SUPPORT OF HER
OPPOSITION TO DEFENDANTS’ SPECIAL MOTION TO DISMISS
Now comes the plaintiff, and submits this Supplemental Memorandum in support of her
Opposition to Defendants’ Special Motion to Dismiss.
Background
On May 20, 2023, defendant Hubbard emailed co-defendants and non party witnesses in
regards to their effort to win the intra-committee political dispute as to leadership.
Hubbard wrote: isfy ‘anyone wants to forward the two emails I sent to the board of
registrars now is the time to step up to the plate. But let’s discuss a little more before
anyone does it. Thanks and enjoy the rain. It is much more pleasant than
Amanda.”(Exhibit 1).
On June 15, 2023,!defendant Hubbard sent a text message to non-party witness Irene
Frontiero: “Morning, BOBO(Board of Bar Overseers) just called me. BOBO will
investigate Joe selmbag when and only when there is a conviction.” (Exhibit 2)
On June 26, 2023 at 6:17 AM, defendant Hubbard emailed co-defendant Bjorlie, and non
party witnesses the following: “My best advice is to link the senior Orlandos voting
behavior with the chair and Amanda. Develop a narrative that hypothecates tha
Ashley and. Amanita have known and been privy to their voting behavior and in fact
facilitated it, Pin the responsibility on Amanda and Ashl. . It is an egious violation
of trust and make’ ‘it their handiwork.” (Exhibit 3).
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Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
5. On August 7, 2023, defendant Hubbard emailed co-defendants Bjorlie and Coles, and
non party witnesses Sova and Frontiero, the following: “Jf either of you know a person
who could manage a gofundme page for lawyer’s fees I can get interested in
ountersuing the O’s and they will rue the day they ever conducted themselves the way
in which they did and, cherry on top, sued us, We need to get rid of these people once
md for all.”(Hubbard Email 8/17/2023, Exhibit 4).
On or about August 13, 2023, defendant Nicole Coles published false statements to Jeff
Worthley, regarding this litigation and the plaintiff's husband. Specifically, Coles told
Worthley: “Nicole informed me that it had been proven in Federal Court that Joseph
Orlando Sr. had voted in the 2022 election three times.” (Exhibit 5, Statement of Jeff
Worthley)
On August 16, 2023, non-party witness Sova emailed a “timeline”(which he did not
produce to plaintiff's counsel) to an attorney, describing the instant litigation as follows
“The plaintiff is, Concetta “Connie” Orlando, represented by Joe Orlando Jr.-Orlando
law firm. Her t and and founder of the firm Joe Orlando Sr. resides with her at the
Villages in Florida, Their daughter Amanda Orlando is presently the female Republican
Sessex Middlesex District 1 chair, and formerly the chair of the GRCC. It is Amanda’s
political ambitions and need for control driving this. This is a pattern of behavior... will
send background on this later.”(Exhibit 6).
Sova’s email makes clear that the defendants, to whom he is aligned, feel that their
allegations against the plaintiff are tied to their dispute with the plaintiff's daughter,
Amanda.
On September 11, 2023, defendant Hubbard wrote an email to co-defendants, and several
non-party witnesses: “Joe Jr is misbehaving and in a bad way. He broke some of the
rules. So you understand, we already filed an ordinary motion to dismiss that is excellent
but the court did not accept it because the fucking Orlandos filed a motion
prematurely. "(Exhibit 7)
10. On November 20, 2023, defendants Cynthia Bjorlie and Robin Hubbard, attended a town
committee meeting in Georgetown, MA.
11. Said meeting was run by Georgetown Republican Committee chairman, Lenny Mirra.
Date Filed 12/14/2023 11:48 AM
‘Superior Court - Essex :
Docket Number 2377CV00627
12. The next moming, November 21, 2023, Bjorlie sent Mirra an email, in which she
published false statements regarding the plaintiff and her husband to a non-public
official, Lenny’ Mirra, via email(Exhibit 8, Bjorlie-Mirra Email dated 11/21/2023).
13 Specifically, Bjorlie wrote: “/1 was also learned that two of the elected officials and
voting members of the committee, who happen to be the parents of the outgoing
chairman, are aciually not residents of Gloucester and therefore not eligible to be on the
committee or even legally allowed to vote in Gloucester when they were also voting in
and homesteacdled in another state and receiving a $50,000 per year homestead exemption
in the other slate! They had been voting in alternate states for almost 20 years."
14 On or about November 21, 2023, defendant Coles posted a comment ona post by
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defendant Bjorlie, on Facebook, about Coles’ plan to run for elected office. In her post
she writes: * ill be running too. I will be exposing the truth about our elections and
voter fraud. Masscourts.org Essex superior court.”
15. Attached to Coles’ comment is a screenshot of the docket from the instant litigation.
(Coles Facebook! comment and screenshot, Exhibit 9).
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4} Legal Standard
The plaintiff refers thig Honorable Court to the legal standard section of her Opposition to
Defendants’ Special Motion to Dismiss, p. 6-7(Doc. 29.1)
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Argument
The defendants have argied that their publishing of false statements about the plaintiff is
protected as “petitioning” activity. As pleaded by the plaintiff in her Opposition to the
Defendants’ Special Motion to Dismiss, the defendants cannot prove that their speech is
protected in any way. Here, the defendants’ argument is further undermined by the defendants’
recent behavior in continuing to publish false statements about the plaintiff as recently as
November 21, 2023. To whom are they petitioning now?
1 The defendants repeatedly indicate that they are using their allegations about the plaintiff
as fodder to gain traction in the intra-committee leadership dispute. Their focus, based
upon these newly-discovered documents, was to use their false allegations against the
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Date Filed 12/14/2023 11:48 AM
‘Superior Court - Essex
Docket Number 2377CV00627
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plaintiff to defeat Ashley Sullivan and Amanda Orlando, the elected leaders of the
committee.
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Coles states in her Facebook comment that she’s planning to use the material issues in
this litigation, and the false allegations she’s made against the plaintiff as the basis for her
campaign message in her bid to wina political seat in 2024, which is clearly not
petitioning activity nor protected speech. (Exhibit 9)
Defendant Hubbard makes their motive to simply disparage the plaintiff and her family
extremely clear in her commentary regarding them above. First, prior to the plaintiff
filing suit, Hubbard wrote that she wished to use her allegations about the plaintiff for
political gain (Exhibit 3). Then, in August of 2023, she writes that, “We need to get rid of
these people once and for all.” (Exhibit 4)
Jeff Worthley is a city councilor in Gloucester, MA. In his capacity as city councilor, he
is not in any position of authority or jurisdiction to act on information about alleged
voting crimes. Hi s place in city government is akin to a fire fighter or DPW director.
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Lenny Mirra, is alformer elected official, and now serves as chairman of a local town
committee in Georgetown, MA. Discussing the matters of this litigation, and the
defendants’ false allegations about the plaintiff with these individuals can not be
considered protected petitioning activity pursuant to the statute, because these individuals
are not ina government role such that reporting allegations of crimes to them is
actionable. Nor did either of them ask for any action to be taken, nor seek to solicit
support for their alleged “petitioning.” Given that the defendants published their
commentary to these individuals months after they claim to have been petitioning, they
can’t couch their commentary as attempting to build public support for the purpose of
petitioning cither-it is long over, to the extent that their “petitioning” was ever legitimate.
Where the defendants have made so abundantly clear that their motive was to do harm to the
plaintiff and her family, there is no support for their contention that they were engaging in
protected petitioning activity or trying to build public support for petitioning activity. There is
ample evidence that they acted maliciously.
The defendants have also argued that the Plaintiff filing her Complaint on June 26, 2023(Doc. 1)
“chilled” their so-called petitioning activity, and “silenced” them from further commentary about
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Date Filed 12/14/2023 11:48 AM oy
Superior Court - Essex
Docket Number 2377CV00627
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the plaintiff. This arguim ent is also without merit in the first instance, and undermined by the
defendants’ recent conduct. Bjorlie, Coles, and Hubbard engaged in these publications months
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after the plaintiff filediher Complaint. As such, any argument that they feel “chilled” or
“silenced” by this liti ion is clearly false. To the contrary, the defendants seemingly are
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continuing to broadly sp read their false allegations about the plaintiff to anyone they feel may
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listen.
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s | Respectfully submitted,
| Plaintiff,
By Her Attorney,
/s/ Joseph M. Orlando Jr.
I
JOSEPH M. ORLANDO, JR., ESQ.
I
i BBO # 680995
t Orlando & Associates, PC
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1 Western Avenue
Gloucester, MA 01930
Ph: 978-283-8100 +
Fx: 978-283-8507
| jmorlandojr@orlandoassociates.com
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| CERTIFICATE OF SERVICE
I, Joseph M. of lando, Jr., attorney for the Plaintiff herein, herby certify that I served the
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forgoing document to counsel for the defendants via electronic mail to:
' :
1 William E. Gens, Esq.
Gens & Stanton, PC
12 Ericsson Street, 2 Floor
Boston, MA 02122
billgens genslawsoffices.com
on this 13th day of December, 2023.
4s/ Joseph M. Orlando Jr.
i JOSEPH M. ORLANDO, JR., ESQ.
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Date Filed 12/14/2023 11:48 AM
‘Superior Court - Essex I
Docket Number 2377CV00627
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Date Filed 12/14/2023 11:48 AM |
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‘From:
Subj ‘GRCC members email
Date: Saturday, May 20, 2023 3:28:35 PM
Attachments: SRCC Dt
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This is the email list fonmembers that ) was able to create. | have no emails for Jamie Orlando or
Caoin Sullivan or Sheila|Ryder. When | was noticing them | had to send via US Post. Status of both
Clancys | am unsure of & nd Ronald Richards — not sure. The email with the word fiduciary in itis
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Kathleen P the treasyrer in Ward 5.
id wos
| may have missed someone but | can’t be sure. od | Ifanyone-wants.
ermails Sent to th Joard OF registrars a he time to stép up to the plat t's. discuss
(more before ani Thanks and yoy in. much more pl lan Amani a
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Date Filed 12/14/2023 11:48 AM
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iperior Court - Essex
From: Irene Frontiero
ifront2: 3@hotmail.com
Subject: Law Suite Texts
Date: Nov 27, 2023 at 9:10::
To: Irene Frontiero
itr Gnt28@hotmail. con
Ty |
—
ri
Thu, Jun 15, 9:25 AM
Robin | Hubbard
Morning BOBO just
called me. Cheryl
Hunter to be exact
BOBO will investigate
Joe scumbag WHEN
and only when therei:
a conviction
Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
EXHIBIT 3
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Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
From:
To:
Cc: “Patti Page"; id stem
“Irene Frontiero"
Subject: RE: Eason AND MEETINGS UPDATE
Date: Mendey, June 26, 2023 6:17:59 AM
My best advice (first thing in the morning) is to link the senior
Orlandos voting behavior with the
chair and Amanda. | evelop a narrative that hypothecates that Ashley and Amanda
have known and
been privy to their voting behavior and in fact facilitated it, Pin the
responsibility.on Amanda and
Ashley. It is an eerebigus violation of trust and make it their
handiwork,
From: cs ; Robin Hubbard
Ce: Patti Page ; Buddy Hobbs ; Cynthia Bjorlie
; Irene Frontiero
Subject: Re; Eason AND MEETINGS UPDATE
’
To all, t5
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Kelly and others onjoyr committee were right on the mark.
We hada good meeting today
and | will give you an update.
The Sunday July 2 nhesting at Mortillaro's Lobster at 10 AM
is legitimate, official, and on. They
must attend this meeting because the meeting is official, and
actions taken during it are valid
and official becauseit\was Properly called by five members in accorda
nce with city and state
bylaws. We will attend this official meeting in full force and in person
because it will include a
vote to terminate the chairwoman for cause. We are leaning
towards no zoom componentto
this meeting because of the possible complications and uninten
ded consequences that may
arise from it. There will be other important items included on the agenda
that we can discuss
over the next couple o' F days. We'll induct and introduce new members
for one.
}
The diversionary Amarlda a nd Ashley missives aren't legitimate.
I'm still the vice chairman
because | was voted in‘by the membership and they simply can't call a secret executi
ve
session among them: elves, especially without notifying me (as has become
their habit) and
then just vote out the vice chairman. The chairwoman has committed
numerous and
egregious city and state committee bylaws violations, as well as Roberts
Rules of Order
violations and a multitude of OCPF violations. We'll document and present
these. Since this is
not an executive session it will be video recorded.
‘
Happy Fiesta!
Clayton
Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
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EXHIBIT 4
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Date Filed 12/14/2023 11:48 AM
Superior Court - Essex
Docket Number 2377CV00627
{
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From:
To: ho
r ‘Irene Frontiero
Nicole”;
Subject: Amended Complaint
Date: coer Au igust 7, 2023 5:14:49 PM
Attachments: Mi lic
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r
Irene and Cassius Clay:
The Os amended the original complaint. Here it is in all its glory.
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Would you read this!and help me find the lies? Fact number 11 isa lie,
and when | went on OCPFto
download the updated April 2023 membership statement it was gone. |
remember seeing a printed
copy of it at the April meeting, my name and other names had been added
to the membership rolls.
Connie was still a member and treasurer in 2023. Or am | imagining things? Also
both Connie and Joe
voted in Florida in 022 so the lie (fact 11) is a compound one.
lam told Rick M isa sod guy and wants to help. Also if either of you know a person
| who could
manage a gofundine| Ipage for lawyer’s fees I can get interestedin countersuing
the O’s and they will
rue the day they ever Conducted themselves the way in which they did and, cherry
on top, sued us.
We need to get ri of these people once and for all.
RH | I
Preview
Date Filed 12/14/2023 11:48 AM ‘Superior Court - Essex Docket Number 2377CV00627 36.1 COMMONWEALTH OF MASSACHUSETTS ESSEX, SS SUPERIOR COURT Concetta Orlando, Plaintiff Vv. Civil Action No. 2377cv00627 Cynthia Bjorlie Nicole Coles Robin Hubbard Defendants t PLAINTIFF’S MEMORANDUM OF LAW IN SUPPORT OF HER MOTION FOR LEAVE TO FILE SUPPLEMENTAL MEMORANDUM IN OPPOSITION TO DEFENDANTS’ SPECIAL MOTION TO DISMISS t The plaintiff submits the within Memorandum of Law. Introduction The recently received ddcuments from the non-party witnesses speak directly to material issues argued by the parties during the hearing on 12/7/2023. Should the court find that the plaintiff is a limited public figure, the documents which are submitted herewith demonstrate actual malice by the defendants in their published defamatory activity. Additionally, the documents produced demonstrate the defendants’ ulterior motive in contacting government entities, which belies their argument that they were engaged in protected petitioning activity. Last, the documents show clearly that the defendants’ allegations about the plaintiff were personal towards plaintiff and her family, where they include the following statements by defendants in their own words Hubbard Email 5/20/2023: Thanks and enjoy the rain. It is much more pleasant than Amanda,” (Plaintiff's Supplemental Memorandum of Law, Exhibit 1) Hubbard Text 6/15/2023: “BOBO will investigate Joe scumbag when and only when there is a conviction. ” (Plaintiffs Supplemental Memorandum of Law, Exhibit 2) Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 Hubbard Email 6/26/2023: My best advice is to link the senior Orlandos voting behavior with the chair and Amanda. Develop a narrative that hypothecates that Ashley and Amanda have known and been privy to their voting behavior and in fact facilitated it. Pin the responsibility on Amanda and Ashley. I is an egregious violation of trust and make it their handiwork.” (Plaintiff's Supplemental Memorandum of Law, Exhibit 3) Hubbard Email 8/7/2023: “.... can get interested in countersuing the O's and they will rue the day they ever conducted themselves the way in which they did and, cherry on top, sued us. We need to get rid of |these, people once and for all.” (Plaintiff's Supplemental Memorandum of Law, Exhibit 4). boy ‘ Factual Background The plaintiff: filed her Complaint on June 26, 2023(Doc. 1). On June 27, 2023, the plaintiff served an evidence preservation letter upon 7 non-party witnesses: Mary Pat Derosa, Irene Frontiero, Ralph “Bud” Hobbs, Richard Maybury, Kelly Secrest, Steven “Brent” Sexton, and Clayton Sova(Exhibit B: Evidence Preservation Letter). On July 26, 2023, each of the seven non-party witnesses were properly served with Keeper of Records Deposition Notices and Subpoenas to produce documents(Exhibit C: Returns of Service) The KOR Deposition Notices required production of documents by August 24, 2023. None of the seven witnesses produced documents by this deadline. On August 25,/2023, the plaintiff served a Motion to Compel on each of the seven non- party witnesses(Boc, 22). On September 119, 2023, at hearing before the Honorable Judge Barrett, the Court issued an order regarding Plaintiff's Motion to Compel Documents from non-party witnesses. The court’s order stated that the motion was allowed: “Allowed in part-all parties are required to respond to the ScheduleA with the following modifications. The 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 discovery production is limited to those materials that have the following terms or search terms: 1. Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 1 Concetta or Connie Orlando; 2. Criminal illegalities; 3. Criminal enterprise; 4. Voter fraud; 5. Tax fraud; 6 Crime family; 7. Ashley Sullivan.” 8. Judge Barrett allowed an additional 60 days, up to and including November 19, 2023, for the seven non-patty witnesses to produce the documents. 9. On November i3, 2023, Hobbs produced documents to plaintiff's counsel, in compliance with the Order.’ 10. None of the other witnesses produced documents by the deadline of November 19, 2023. 11. On November 20, 2023, the plaintiff served Motion to Compel and for Sanctions upon Derosa, Frontiero, Maybury, Secrest, Sexton, and Sova, for non-compliance with Judge Barrett’s September 19, 2023 order(Doc. 33). 12. In the letter serving this motion upon these 6 non-party witnesses, the plaintiff advised that the motion’ would be filed, pursuant to M.R.C:P. 9A, on Monday, December 4, 2023.(Exhibit D: Letter dated 11/20/2023). 13. In the last two weeks of November, documents/communications evidencing the defendants’ continued defamatory actions and statements towards the plaintiff were forwarded to plaintiff's counsel and staff. 14. In the afternoon df Friday, December 1, 2023, Derosa, Frontiero, Secrest, Sexton, and Sova produced'documents to plaintiff's counsel’s office. 15. Frontiero and Sova produced a letter indicating that they were withholding discoverable documents basedjon their opinion that the materials were “irrelevant or embarrassing.” (Exhibit E: Letter from Frontiero/Sova received 12/1/2023). 16. Secrest and Sexton produced a letter indicating that they were withholding discoverable documents based on their opinion that the materials were “irrelevant or embarrassing.” (Exhibit F: Letter from Secrest/Sova received 12/1/2023). 17. The 11" hour production of documents by the non-party witnesses, though woefully inadequate andclearly withholding responsive documents, has revealed some additional documents which evidence the defendants’ ulterior motives in their defamatory statements about the plaintiff, which belies their argument that they engaged in valid petitioning activity. 18. The documents produced also speak to the defendants’ personal and malicious motive towards plaintiff and her family. | i Date Filed 12/14/2023 11:48 AM ‘Superior Court - Essex ket Number 2377CV00627 19. Due to the fact that the non-party witnesses waited until the 11" hour to produce documents in the first instance, the plaintiff was unable to review, and provide these relevant documents to the court within the 9A period of service prior to the 12/7/2023 scheduled hearing. 20. One of the documents produced is an email from defendant Robin Hubbard to the co- defendants and to non party witnesses, demonstrating clearly their ulterior motive in alleging crimes against the plaintiff. i Legal Standard Rule 9A of the Massachusetts Superior Court Rules provides that "[p]apers not served with the motion or opposition may be filed only with the leave of court." Lisciotti v. Lattanzio. 2006 Mass. Super. LEXIS 427. *2 Newly discovered eviderice is admissible if it has relevance to the material issue and other evidence presented: “Evidence that does not qualify as newly discovered may nevertheless have a reasonable bearing on the weight and reliability of other evidence that is newly discovered for purposes of a new trial!” Leavitt v. Mizner, 404 Mass. 81. 82. 533 N.E.2d 1334. 1335. 1989 Mass. LEXIS 46, *1 : it Argument The materials received by the plaintiff's counsel are newly discovered evidence which point to the defendants’ ulterior motives in contacting government agencies and alleging that the plaintiff had committed crimes such as “voter fraud,” and “tax fraud.” The case law, which plaintiff provided to the Court iin her Opposition to the Defendants’ Special Motion to Dismiss(Doc. 29.1), is clear that wire a party has an ulterior motive in contacting a government agency, their action is not protected petitioning activity. Additionally, the documents speak clearly to the personal and malicious motivation of the defendants in publishing false statements about the plaintiff. Should the court rule that plaintiff is a public figure, these documents demonstrate the defendants’ actual malice. The non-party witnesses have been colluding with the defendants for months to withhold discoverable documents from the plaintiff. This collusion was highlighted for the court at the ! hearing on December 7, 2023, when non-party witness Irene Frontiero entered the counsel area fy 1 Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 to talk with defendants? counsel during the hearing. The court will recall that Ms. Frontiero had to be instructed to leave the area and return to the gallery, when plaintiff's counsel objected to her communications with the defendants’ counsel, who does not represent her. The fact that the non party witnesses willfully withheld discoverable documents from plaintiff, and, at the 11" hour, pro duced inadequate responses anyway, demonstrates the extent of the \ collusion. Since the non-party witnesses intentionally withheld discoverable documents which they unilaterally deemed /“embarrassing,” it is likely that those withheld documents further illustrate the collusion and ulterior motives/malicious intent of the defendants. Once the plaintiff received document production at the late hour, the references to the defendants’ ulterior motives were made patently obvious, and those documents should be provided to the Court for its consideration of the Defendants’ Special Motion to Dismiss(Doc. 29). Had the non-party witnesses not colluded with the defendants to evade discovery production until the 11" hour, these materials would have been available to the plaintiff months ago. The fact that they were' produced just days before the hearing was clearly calculated. However, these documents are on point to the material issues which were argued at hearing, namely, that the defendants engaging in “petitioning” of government entities with an ulterior motive and defamed the plaintiff with actual malice. As such, the documents attached to Plaintiff's Proposed Supplemental Memorandum, are relevant. Wherefore, the plaintiff requests leave of the court to file a Supplemental Memorandum, attaching newly discovered evidence of defendants’ ulterior motive in “petitioning” government entities, belying their argument that they engaged in protected activity, to the Court. Respectfully Submitted, Plaintiff by her Attorneys, /s/ Joseph M. Orlando Jr. JOSEPH M. ORLANDO JR. ESQ. BBO #680995 JOSEPH M. ORLANDO, ESQ. BBO #380215 Orlando & Associates Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 1 Western Avenue Gloucester, MA 01930 Ph: 978-283-8100 Fx: 978-283-8507 jmorlandojr@orlandoassociates.com CERTIFICATE OF SERVICE I, Joseph M. Orlando Tr 'Bsq, attorney for the plaintiff herein, certify that I served the foregoing to counsel for the defendants: I William E. Gens, Esq. Gens & Stanton P.C. 12 Ericsson Street 2" Floor Boston, MA 02122 billgens@genslawoffices.com 1‘ On this 13" day of December, 2023. /s/ Joseph M. Orlando Jr., Esq. i Date Filed 12/14/2023 11:48 AM Superior Court - eX Docket Number 2377CV00627 EXHIBIT A | Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 COMMONWEALTH OF MASSACHUSETTS 1 ESSEX, SS Il SUPERIOR COURT CONCETTA ORLANDO, Plaintiff v. {t Civil Action No. 2377cv00627 CYNTHIA BJORLIE, ' NICOLE COLES, and ROBIN HUBBARD. Defendants PLAINTIFF’S SUPPLEMENTAL MEMORANDUM IN SUPPORT OF HER OPPOSITION TO DEFENDANTS’ SPECIAL MOTION TO DISMISS Now comes the plaintiff, and submits this Supplemental Memorandum in support of her Opposition to Defendants’ Special Motion to Dismiss. Background On May 20, 2023, defendant Hubbard emailed co-defendants and non party witnesses in regards to their effort to win the intra-committee political dispute as to leadership. Hubbard wrote: isfy ‘anyone wants to forward the two emails I sent to the board of registrars now is the time to step up to the plate. But let’s discuss a little more before anyone does it. Thanks and enjoy the rain. It is much more pleasant than Amanda.”(Exhibit 1). On June 15, 2023,!defendant Hubbard sent a text message to non-party witness Irene Frontiero: “Morning, BOBO(Board of Bar Overseers) just called me. BOBO will investigate Joe selmbag when and only when there is a conviction.” (Exhibit 2) On June 26, 2023 at 6:17 AM, defendant Hubbard emailed co-defendant Bjorlie, and non party witnesses the following: “My best advice is to link the senior Orlandos voting behavior with the chair and Amanda. Develop a narrative that hypothecates tha Ashley and. Amanita have known and been privy to their voting behavior and in fact facilitated it, Pin the responsibility on Amanda and Ashl. . It is an egious violation of trust and make’ ‘it their handiwork.” (Exhibit 3). i Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 5. On August 7, 2023, defendant Hubbard emailed co-defendants Bjorlie and Coles, and non party witnesses Sova and Frontiero, the following: “Jf either of you know a person who could manage a gofundme page for lawyer’s fees I can get interested in ountersuing the O’s and they will rue the day they ever conducted themselves the way in which they did and, cherry on top, sued us, We need to get rid of these people once md for all.”(Hubbard Email 8/17/2023, Exhibit 4). On or about August 13, 2023, defendant Nicole Coles published false statements to Jeff Worthley, regarding this litigation and the plaintiff's husband. Specifically, Coles told Worthley: “Nicole informed me that it had been proven in Federal Court that Joseph Orlando Sr. had voted in the 2022 election three times.” (Exhibit 5, Statement of Jeff Worthley) On August 16, 2023, non-party witness Sova emailed a “timeline”(which he did not produce to plaintiff's counsel) to an attorney, describing the instant litigation as follows “The plaintiff is, Concetta “Connie” Orlando, represented by Joe Orlando Jr.-Orlando law firm. Her t and and founder of the firm Joe Orlando Sr. resides with her at the Villages in Florida, Their daughter Amanda Orlando is presently the female Republican Sessex Middlesex District 1 chair, and formerly the chair of the GRCC. It is Amanda’s political ambitions and need for control driving this. This is a pattern of behavior... will send background on this later.”(Exhibit 6). Sova’s email makes clear that the defendants, to whom he is aligned, feel that their allegations against the plaintiff are tied to their dispute with the plaintiff's daughter, Amanda. On September 11, 2023, defendant Hubbard wrote an email to co-defendants, and several non-party witnesses: “Joe Jr is misbehaving and in a bad way. He broke some of the rules. So you understand, we already filed an ordinary motion to dismiss that is excellent but the court did not accept it because the fucking Orlandos filed a motion prematurely. "(Exhibit 7) 10. On November 20, 2023, defendants Cynthia Bjorlie and Robin Hubbard, attended a town committee meeting in Georgetown, MA. 11. Said meeting was run by Georgetown Republican Committee chairman, Lenny Mirra. Date Filed 12/14/2023 11:48 AM ‘Superior Court - Essex : Docket Number 2377CV00627 12. The next moming, November 21, 2023, Bjorlie sent Mirra an email, in which she published false statements regarding the plaintiff and her husband to a non-public official, Lenny’ Mirra, via email(Exhibit 8, Bjorlie-Mirra Email dated 11/21/2023). 13 Specifically, Bjorlie wrote: “/1 was also learned that two of the elected officials and voting members of the committee, who happen to be the parents of the outgoing chairman, are aciually not residents of Gloucester and therefore not eligible to be on the committee or even legally allowed to vote in Gloucester when they were also voting in and homesteacdled in another state and receiving a $50,000 per year homestead exemption in the other slate! They had been voting in alternate states for almost 20 years." 14 On or about November 21, 2023, defendant Coles posted a comment ona post by i defendant Bjorlie, on Facebook, about Coles’ plan to run for elected office. In her post she writes: * ill be running too. I will be exposing the truth about our elections and voter fraud. Masscourts.org Essex superior court.” 15. Attached to Coles’ comment is a screenshot of the docket from the instant litigation. (Coles Facebook! comment and screenshot, Exhibit 9). 1 4} Legal Standard The plaintiff refers thig Honorable Court to the legal standard section of her Opposition to Defendants’ Special Motion to Dismiss, p. 6-7(Doc. 29.1) | | i i Argument The defendants have argied that their publishing of false statements about the plaintiff is protected as “petitioning” activity. As pleaded by the plaintiff in her Opposition to the Defendants’ Special Motion to Dismiss, the defendants cannot prove that their speech is protected in any way. Here, the defendants’ argument is further undermined by the defendants’ recent behavior in continuing to publish false statements about the plaintiff as recently as November 21, 2023. To whom are they petitioning now? 1 The defendants repeatedly indicate that they are using their allegations about the plaintiff as fodder to gain traction in the intra-committee leadership dispute. Their focus, based upon these newly-discovered documents, was to use their false allegations against the l it 1 Date Filed 12/14/2023 11:48 AM ‘Superior Court - Essex Docket Number 2377CV00627 ' t plaintiff to defeat Ashley Sullivan and Amanda Orlando, the elected leaders of the committee. I Coles states in her Facebook comment that she’s planning to use the material issues in this litigation, and the false allegations she’s made against the plaintiff as the basis for her campaign message in her bid to wina political seat in 2024, which is clearly not petitioning activity nor protected speech. (Exhibit 9) Defendant Hubbard makes their motive to simply disparage the plaintiff and her family extremely clear in her commentary regarding them above. First, prior to the plaintiff filing suit, Hubbard wrote that she wished to use her allegations about the plaintiff for political gain (Exhibit 3). Then, in August of 2023, she writes that, “We need to get rid of these people once and for all.” (Exhibit 4) Jeff Worthley is a city councilor in Gloucester, MA. In his capacity as city councilor, he is not in any position of authority or jurisdiction to act on information about alleged voting crimes. Hi s place in city government is akin to a fire fighter or DPW director. | Lenny Mirra, is alformer elected official, and now serves as chairman of a local town committee in Georgetown, MA. Discussing the matters of this litigation, and the defendants’ false allegations about the plaintiff with these individuals can not be considered protected petitioning activity pursuant to the statute, because these individuals are not ina government role such that reporting allegations of crimes to them is actionable. Nor did either of them ask for any action to be taken, nor seek to solicit support for their alleged “petitioning.” Given that the defendants published their commentary to these individuals months after they claim to have been petitioning, they can’t couch their commentary as attempting to build public support for the purpose of petitioning cither-it is long over, to the extent that their “petitioning” was ever legitimate. Where the defendants have made so abundantly clear that their motive was to do harm to the plaintiff and her family, there is no support for their contention that they were engaging in protected petitioning activity or trying to build public support for petitioning activity. There is ample evidence that they acted maliciously. The defendants have also argued that the Plaintiff filing her Complaint on June 26, 2023(Doc. 1) “chilled” their so-called petitioning activity, and “silenced” them from further commentary about i 1 Date Filed 12/14/2023 11:48 AM oy Superior Court - Essex Docket Number 2377CV00627 th | the plaintiff. This arguim ent is also without merit in the first instance, and undermined by the defendants’ recent conduct. Bjorlie, Coles, and Hubbard engaged in these publications months | after the plaintiff filediher Complaint. As such, any argument that they feel “chilled” or “silenced” by this liti ion is clearly false. To the contrary, the defendants seemingly are i continuing to broadly sp read their false allegations about the plaintiff to anyone they feel may 1 listen. | s | Respectfully submitted, | Plaintiff, By Her Attorney, /s/ Joseph M. Orlando Jr. I JOSEPH M. ORLANDO, JR., ESQ. I i BBO # 680995 t Orlando & Associates, PC i 1 Western Avenue Gloucester, MA 01930 Ph: 978-283-8100 + Fx: 978-283-8507 | jmorlandojr@orlandoassociates.com i | | CERTIFICATE OF SERVICE I, Joseph M. of lando, Jr., attorney for the Plaintiff herein, herby certify that I served the | forgoing document to counsel for the defendants via electronic mail to: ' : 1 William E. Gens, Esq. Gens & Stanton, PC 12 Ericsson Street, 2 Floor Boston, MA 02122 billgens genslawsoffices.com on this 13th day of December, 2023. 4s/ Joseph M. Orlando Jr. i JOSEPH M. ORLANDO, JR., ESQ. | I Date Filed 12/14/2023 11:48 AM ‘Superior Court - Essex I Docket Number 2377CV00627 i i EXHIBIT 1 } f i i I I i i \ t Date Filed 12/14/2023 11:48 AM | ‘Superior Court - Essex Docket Number 2377CV00627 1 585 I Ev ‘From: Subj ‘GRCC members email Date: Saturday, May 20, 2023 3:28:35 PM Attachments: SRCC Dt 1 tl 7 T This is the email list fonmembers that ) was able to create. | have no emails for Jamie Orlando or Caoin Sullivan or Sheila|Ryder. When | was noticing them | had to send via US Post. Status of both Clancys | am unsure of & nd Ronald Richards — not sure. The email with the word fiduciary in itis vl Kathleen P the treasyrer in Ward 5. id wos | may have missed someone but | can’t be sure. od | Ifanyone-wants. ermails Sent to th Joard OF registrars a he time to stép up to the plat t's. discuss (more before ani Thanks and yoy in. much more pl lan Amani a i RH {i I i' , , \ i\ ' 1 i i I , i| i i I 1 i 1 " I 1, i i Date Filed 12/14/2023 11:48 AM ‘Superior Court - Essex I Docket Number 2377CV00627 i EXHIBIT 2. | { i | 1t I i | i I i | 1 i ! | 1 | I | |I | I | | I { { | i i it I ft ' "I i | i t iperior Court - Essex From: Irene Frontiero ifront2: 3@hotmail.com Subject: Law Suite Texts Date: Nov 27, 2023 at 9:10:: To: Irene Frontiero itr Gnt28@hotmail. con Ty | — ri Thu, Jun 15, 9:25 AM Robin | Hubbard Morning BOBO just called me. Cheryl Hunter to be exact BOBO will investigate Joe scumbag WHEN and only when therei: a conviction Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 EXHIBIT 3 i i i , i t i i K 4 ' i " be Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 From: To: Cc: “Patti Page"; id stem “Irene Frontiero" Subject: RE: Eason AND MEETINGS UPDATE Date: Mendey, June 26, 2023 6:17:59 AM My best advice (first thing in the morning) is to link the senior Orlandos voting behavior with the chair and Amanda. | evelop a narrative that hypothecates that Ashley and Amanda have known and been privy to their voting behavior and in fact facilitated it, Pin the responsibility.on Amanda and Ashley. It is an eerebigus violation of trust and make it their handiwork, From: cs ; Robin Hubbard Ce: Patti Page ; Buddy Hobbs ; Cynthia Bjorlie ; Irene Frontiero Subject: Re; Eason AND MEETINGS UPDATE ’ To all, t5 t Kelly and others onjoyr committee were right on the mark. We hada good meeting today and | will give you an update. The Sunday July 2 nhesting at Mortillaro's Lobster at 10 AM is legitimate, official, and on. They must attend this meeting because the meeting is official, and actions taken during it are valid and official becauseit\was Properly called by five members in accorda nce with city and state bylaws. We will attend this official meeting in full force and in person because it will include a vote to terminate the chairwoman for cause. We are leaning towards no zoom componentto this meeting because of the possible complications and uninten ded consequences that may arise from it. There will be other important items included on the agenda that we can discuss over the next couple o' F days. We'll induct and introduce new members for one. } The diversionary Amarlda a nd Ashley missives aren't legitimate. I'm still the vice chairman because | was voted in‘by the membership and they simply can't call a secret executi ve session among them: elves, especially without notifying me (as has become their habit) and then just vote out the vice chairman. The chairwoman has committed numerous and egregious city and state committee bylaws violations, as well as Roberts Rules of Order violations and a multitude of OCPF violations. We'll document and present these. Since this is not an executive session it will be video recorded. ‘ Happy Fiesta! Clayton Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 i EXHIBIT 4 | | k I 1 | " k i i ' | i 1 ! i It i i ‘ 1 | I i i i Date Filed 12/14/2023 11:48 AM Superior Court - Essex Docket Number 2377CV00627 { i From: To: ho r ‘Irene Frontiero Nicole”; Subject: Amended Complaint Date: coer Au igust 7, 2023 5:14:49 PM Attachments: Mi lic i r Irene and Cassius Clay: The Os amended the original complaint. Here it is in all its glory. | Would you read this!and help me find the lies? Fact number 11 isa lie, and when | went on OCPFto download the updated April 2023 membership statement it was gone. | remember seeing a printed copy of it at the April meeting, my name and other names had been added to the membership rolls. Connie was still a member and treasurer in 2023. Or am | imagining things? Also both Connie and Joe voted in Florida in 022 so the lie (fact 11) is a compound one. lam told Rick M isa sod guy and wants to help. Also if either of you know a person | who could manage a gofundine| Ipage for lawyer’s fees I can get interestedin countersuing the O’s and they will rue the day they ever Conducted themselves the way in which they did and, cherry on top, sued us. We need to get ri of these people once and for all. RH | I