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  • Hsbc Bank Usa, National Association, In Its Capacity As Trustee Of Nomura Home Equity Loan, Inc., Asset Backed Certificates, Series 2007-2 v. Nomura Credit & Capital, Inc. Commercial Division document preview
  • Hsbc Bank Usa, National Association, In Its Capacity As Trustee Of Nomura Home Equity Loan, Inc., Asset Backed Certificates, Series 2007-2 v. Nomura Credit & Capital, Inc. Commercial Division document preview
  • Hsbc Bank Usa, National Association, In Its Capacity As Trustee Of Nomura Home Equity Loan, Inc., Asset Backed Certificates, Series 2007-2 v. Nomura Credit & Capital, Inc. Commercial Division document preview
  • Hsbc Bank Usa, National Association, In Its Capacity As Trustee Of Nomura Home Equity Loan, Inc., Asset Backed Certificates, Series 2007-2 v. Nomura Credit & Capital, Inc. Commercial Division document preview
  • Hsbc Bank Usa, National Association, In Its Capacity As Trustee Of Nomura Home Equity Loan, Inc., Asset Backed Certificates, Series 2007-2 v. Nomura Credit & Capital, Inc. Commercial Division document preview
  • Hsbc Bank Usa, National Association, In Its Capacity As Trustee Of Nomura Home Equity Loan, Inc., Asset Backed Certificates, Series 2007-2 v. Nomura Credit & Capital, Inc. Commercial Division document preview 
						
                                
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                                FILED:         NEW     YORK       COUNTY        CLERK        06/23/2021             11:12        PM                 INDEX    NO.   650337/2013
   NYSCEF     DOC.   NO.   626                                                                                RECEIVED      NYSCEF:     06/23/2021




                                                      EXHIBIT                                  J
   FILED:         NEW     YORK       COUNTY        CLERK        06/23/2021             11:12        PM                 INDEX    NO.   650337/2013
   NYSCEF     DOC.   NO.   626                                                                                RECEIVED      NYSCEF:     06/23/2021




         From:                  SFC-PART15 
         Sent:                  Tuesday, June 8, 2021 9:03 AM
         To:                    Daniel M. Sullivan; SFC-PART15
         Cc:                    hfsidman@jonesday.com; Dwight Healy; astovall@constantinecannon.com; Agnès Dunogué; Eileen
                                Monaghan DeLucia; Michael Shuster; Matthew Craner; Jeff Hoschander; Brendon DeMay;
                                jboylan@jonesday.com; adollinger@jonesday.com; Meredith J. Nelson; jbaltruzak@jonesday.com;
                                Margot B. Hoppin; Joshua Ebersole; 'Daniel Kahn'; Robert Scheef; jchernov@constantinecannon.com;
                                wfoley@lockelord.com; Courtney Statfeld; Stan Chelney; David Schiefelbein;
                                choward@lockelord.com; dfleming@mckoolsmith.com; cpjohnson@mckoolsmith.com;
                                zmazin@mckoolsmith.com
         Subject:               RE: Nomura Cases: 652619/2012, 652842/2014, 653390/2012, 651124/2013, 650337/2013,
                                653783/2012, 652614/2012


         Dear all: if you cannot work this out, I think it probably needs a motion.       I would be most interested in what the
         prejudice is—mac.

         From: Daniel M. Sullivan 
         Sent: Monday, June 7, 2021 7:04 PM
         To: SFC‐PART15 
         Cc: hfsidman@jonesday.com; Dwight Healy ; astovall@constantinecannon.com; Agnès Dunogué
         ; Eileen Monaghan DeLucia ; Michael Shuster
         ; Matthew Craner ; Jeff Hoschander
         ; Brendon DeMay ; Daniel M. Sullivan
         ; jboylan@jonesday.com; adollinger@jonesday.com; Meredith J. Nelson
         ; jbaltruzak@jonesday.com; Margot B. Hoppin ; Joshua Ebersole
         ; 'Daniel Kahn' ; Robert Scheef
         ; jchernov@constantinecannon.com; wfoley@lockelord.com; Courtney Statfeld
         ; Stan Chelney ; David Schiefelbein
         ; choward@lockelord.com; dfleming@mckoolsmith.com;
         cpjohnson@mckoolsmith.com; zmazin@mckoolsmith.com
         Subject: Nomura Cases: 652619/2012, 652842/2014, 653390/2012, 651124/2013, 650337/2013, 653783/2012,
         652614/2012

         Dear Justice Crane:

         I write on behalf of HSBC Bank USA, N.A., the Plaintiff-Trustee (“Trustee”) in the above-listed actions
         between the Trustee and Defendant Nomura.              Mindful of the Court’s directive to promptly raise disputes with
         the Court, the Trustee requests a conference regarding an issue that has arisen regarding Nomura’s attempt to
         replace one of Nomura’s experts, Professor Jerry Hausman—after Professor Hausman has already been deposed
         and all other expert discovery in the Trustee’s actions against Nomura has concluded—by serving
         “supplemental” disclosures of a new expert, Dr. Mark Rainey.                The Trustee believes that Nomura’s purported
         supplemental disclosures (copies of which are attached for the Court’s reference) should be stricken for reasons
         it can set forth either at a conference or in briefing, as Your Honor directs.

         The Trustee will await the Court’s instructions for how to present this issue to Your Honor.

         Respectfully submitted,

                                                                            1
   FILED:         NEW     YORK       COUNTY        CLERK        06/23/2021             11:12        PM                 INDEX    NO.   650337/2013
   NYSCEF     DOC.   NO.   626                                                                                RECEIVED      NYSCEF:     06/23/2021

         Daniel   Sullivan




         Daniel  M.  Sullivan
         Holwell  Shuster  &  Goldberg   LLP
         425  Lexington  Avenue
         New   York, New   York  10017

         (646) 837-5132    (office)
         (773)  203-6598   (mobile)
         (646) 837-8515    (fax)
         www.hsellp.com


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