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

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                                Date Filed 4/15/2024 9:34 AM
Superior Court - Essex
Docket Number 2277CV00887          ALLOWED in part. The plaintiff shall make her expert disclosures in                     16
                                   compliance with Mass, . Civ. P. 26(b)(4) and Superior Court Rule 30B by


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    RECEIVED
                                   May 17, 2024 |
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                     ESSEX, SS.                                                                      SUPERIOR COURT

                     PATRICIA SHOLDS,
                               Plaintiff

                    Vv.                                       CIVIL ACTION NO. 227CV00887

                    EDWARD PINASKI,
                               Defendant


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

                               Now comes the plaintiff, Patricia Sholds, and respectfully moves this Honorable Court to
                    extend time for the plaintiff to disclose experts pursuant to Rule 30, for an additional 60 days, up
                    to and including, June 15, 2024. Plaintiff bases her motion on the fact that diligent efforts to
                    obtain the defendant’s full medical records, which must be supplied to plaintiffs experts in order
                    for them to complete their review and provide their reports, have not resulted in acquisition of
                    his records to date. Defendant’s medical providers asked for plaintiff to provide the complete
                    power of attorney document, in order for those providers to release Defendant’s records. On
                    January 31, 2024, plaintiffs counsel asked Defendant’s counsel for the full document.
                    Defendant’s counsel sent a redacted version to plaintiff's counsel on Thursday, April 11, 2024.
                               As grounds therefore, and for further information and chronology of this issue, the
                    plaintiff refers this Honorable Court to her Memorandum of Law, filed contemporaneously
                    herewith.
                                                                            Respectfully submitted,
                                                                            Plaintiff by his Attorney,

                                                                            4s/ Joseph M. Orlando Jr.
                                                                            JOSEPH M. ORLANDO, JR., ESQ.
                                                                            BBO # 680995
                                                                            Orlando & Associates
                                                                            One Western Avenue
                                                                            Gloucester, MA 01930
                                                                            Phone: (978) 283-8100
                                                                            Fax:   (978) 283-8507