THE STATE OF NEW HAMPSHIRE
HILLSBOROUGH, SS. SUPERIOR COURT
SOUTHERN DISTRICT No. 2020-CV-00133
Laurie Ortolano
v.
The City of Nashua
ORDER ON PLAINTIFF’S MOTION FOR DISCOVERY SANCTIONS
The plaintiff, Laurie Ortolano, has brought a petition in which she seeks access to
records from the City of Nashua’s (the “City” or “Nashua’) assessing department (the
“Department”). Currently pending before the Court is the plaintiff's motion for discovery
sanctions. On July 9, 2021, the Court held a hearing on the plaintiff's motion. After
consideration of the evidence, arguments, and the applicable law, the Court finds and
rules as follows.
Facts
The facts forming the basis of the plaintiff's motion are not in dispute. (See July
9, 2021 Hr'g at 10:20 (City conceding that the facts are not in dispute); but see City’s
Obj. 7 A (“The piaintiff’s motion is rife with unsupported and inflammatory allegations,
conjecture, and hyperbole unworthy of a motion before this Court."). On July 20, 2020,
the plaintiff propounded a request for production to the City for “[a]l! emails sent by Kim
Kleiner from August 9, 2019 through to September 30, 2019.” (Pl.’s Mot. Disc.
Sanctions at Ex. 2.) Nearly one month later, on August 18, 2020, the City responded
stating, “[t]he City is still searching and the City will update its responses when search is
complete.” (Id. at Ex. 3.) After receiving no further response from the City, a meet and
confer was scheduled between the parties. (Id. 41.) On October 6, 2020, the parties
Ortofano v. The City of Nashua / 2020-CV-00133
4
This is a Service Document For Case: 226-2020-CV-00133
Hillsborough Superior Court Southern District
7/44/2021 12:11 PM
