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Home My WebLink AboutSubpoena for records 3/16/26 _r�.' 19 2025 . STEVEN C. SHARAF Attorney At Law 180 Wells Avenue, Suite 106 Newton, Massachusetts 02459 Tel: (781)455-0300 Fax: (617)928-3301 e-mail: steve@legalsteve.com www.legalsteve.com March 16, 2026 Keeper of Records Yarmouth Building Department Yarmouth Town Hall 1146 Route 28 South Yarmouth, MA 02664 Re: Aquaknot Pools, Inc. Vs. Kristine P. Uhlman, et al. C.A. No. 2582CV00701 Dear Sir or Madam: Enclosed please find pursuant to M.R.C.P. Rule 34 and Rule 45 a subpoena for records in regard to the above-referenced matter. Please note that you are not required to appear, but only to provide the records requested on or before April 17, 2026. Thank you for your immediate attention to this matter. If you should have any questions, please do not hesitate to contact this office. Very truly yours, .,.. -4 '.. '''...- ------P (V /SCS Steven C. Sharaf Encl. cc: Nadine M. Bailey, Esq. COMMONWEALTH OF MASSACHUSETTS NORFOLK, ss. SUPERIOR COURT DEPARTMENT CIVIL ACTION NO. 2582CV00701 Aquaknot Pools, Inc., ] Plaintiffs, ] v. ] ] SUBPOENA DUCES TECUM Kristine P. Uhlman and Michael Freiberger, ] (DOCUMENTS ONLY) Individually and as Manager of MF ] Landscape & Design, LLC. ] Mass.R.Civ.P. 34 and 45 Defendants. ] TO: Keeper of Records Yarmouth Building Department Yarmouth Town Hall 1146 Route 28 South Yarmouth, MA 02664 YOU ARE HEREBY COMMANDED in the name of the Commonwealth of Massachusetts in accordance with the provisions of Rules 34 amd 45 of the Massachusetts Rules of Civil Procedure, to produce documents, electronically stored information, or tangible things as requested and described in the Schedule "A" attached hereto to Attorney Steven C. Sharaf, counsel for the Plaintiff Aquaknot Pools, Inc., at the address of 180 Wells Avenue, Suite 106, Newton, MA 02459, on the 17th day of April,2026 no later than 5:00 P.M. HEREOF fail not, as your failure to comply may deem you in contempt and may subject you to such penalties as the law provides. Respectfully submitted, Aquaknot Pools, Inc., By its attorney, --e•P Steven C. Sharaf, BBO# 552524 180 Wells Avenue, Suite 106 Newton, MA 02459 (781)455-0300 steve@legalsteve.com D.ted this 16th day of Marc 1, 2026 .tosoltoititi Uri II otar y Publ*IP:4r /1 � '' Yl �� My commission expires: 3.5 • 6 3�' % ei WEAL'5��5��` %Viliilia •� • •4 COMMONWEALTH OF MASSACHUSETTS NORFOLK, ss. SUPERIOR COURT DEPARTMENT CIVIL ACTION NO. 2582CV00701 Aquaknot Pools, Inc., ] Plaintiffs, ] v. ] ] PLAINTIFF'S NOTICE OF Kristine P. Uhlman and Michael Freiberger, ] SUBPOENA DUCES TECUM Individually and as Manager of MF ] (DOCUMENTS ONLY) Landscape & Design, LLC. ] Defendants. ] PLEASE TAKE NOTICE that, pursuant to Rules 34 and 45 of the Massachusetts Rules of Civil Procedure, Plaintiff,Aquaknot Pools, Inc. will cause a subpoena to be served upon Yarmouth Building Department, commanding it to produce documents, electronically stored information,and/or tangible things as requested and described in the Schedule A attached thereto to the law office of Steven C. Sharaf, counsel for Aquaknot Pools, Inc., on the 17th day of April,2026 no later than 5:00 P.M. Respectfully submitted, Aquaknot Pools, Inc., By its attorney, Steven C. Sharaf, BBO# 552524 180 Wells Avenue, Suite 106 Newton, MA 02459 (781)455-0300 steve@legalsteve.com Dated: March 16, 2026 CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the above document to all counsel of record by electronic mail. Steven C. Sharaf 180 Wells Avenue, Suite 106 Newton, MA 02459 (781)455-0300 steve@legalsteve.com Dated: March 16, 2026 SCHEDULE A 1. Any and all documents and/or records including electronic records from June 1, 2024 to the present that constitute, identify, refer to or comment on 39 Channel Point Drive, West Yarmouth, Massachusetts, including but not limited to the following: any and all correspondence, including electronic mail to and from Kristine P. Uhlman, her agents and/or employees; any and all correspondence, including electronic mail to and from Michael Freiberger, his agents and/or employees; application for permits; permits; inspection records; file records, electronic or otherwise; and/or any and all other documents relating to 39 Channel Point Drive, West Yarmouth, Massachusetts. **NOTE: YOU ARE NOT REQUIRED TO APPEAR. COMPLETE PRODUCTION OF ALL DOCUMENTS REQUESTED HEREIN ON OR BEFORE APRIL 13, 2026, SHALL SATISFY YOUR OBLIGATIONS UNDER THIS SUBPOENA. WE RESERVE THE RIGHT TO REQUIRE YOUR APPEARANCE THROUGH A SUBSEQUENT SUBPOENA BEFORE OR AT TRIAL. YOU MAY CALL ATTORNEY STEVEN C. SHARAF AT 781-455-0300 WITH ANY QUESTIONS. CERTIFICATE OF SERVICE I hereby certify that I have served a copy of the above document to all counsel of record by electronic mail. Steven C. Sharaf 180 Wells Avenue, Suite 106 Newton, MA 02459 (781)455-0300 steve@legalsteve.com Dated: March 16, 2026 Grylls, Mark From: Grylls, Mark Sent: Thursday, March 19, 2026 3:40 PM To: 'steve@legalsteve.com' Subject: 39 Channel Point Dr Hi Atty.Sharaf, Please see attached link which contains the records in electronic format. If you need any assistance, let me know. Thank you, Mark https://lf.yarrn a h.ma.us/WebLink/Browse.aspx?id=827435&db d=Q&repo=LASHCHE MARK GRYLLS DIRECTOR OF INSPECTIONAL SERVICES/BUILDING COMMISSIONER TOWN OF YARMOUTH (508)398-2231 x 1260 1