Motion for Protective Order in Pamela Goldstein, Ellyn Berk, Tony Berk, Paul Benjamin v. Houlihan/Lawrence Inc.| Trellis.Law

On July 14, 2018 a Exhibit,Appendix was filed involving a dispute between Ellyn Berk, Pamela Goldstein, Paul Benjamin, Tony Berk, and Houlihan Lawrence Inc., for Commercial Division in the District Court of Westchester County.

Preview
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

Exhibit 4
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
--------------------------------------------------------------------X
PAMELA GOLDSTEIN,
ELLYN & TONY BERK, as Administrators REPLY IN FURTHER
of the Estate of Winifred Berk, and PAUL SUPPORT OF SECOND
BENJAMIN, on behalf of themselves MOTION FOR PROTECTIVE
and all others similarly situated,
ORDER
Plaintiffs,
-against-

Index No. 60767/2018
HOULIHAN/LAWRENCE INC.,
Hon. Linda S. Jamieson
Defendant.

--------------------------------------------------------------------X

Plaintiffs’ hyperbole and mischaracterizations notwithstanding, Houlihan has undertaken

extraordinary efforts to satisfy Plaintiffs’ extensive and ever-evolving discovery demands. Many

of those demands are untethered to any pending discovery request. Houlihan will not engage

with each of Plaintiffs’ accusations of forgeries, spoliation, false pretenses, “feigning” an

inability to locate documents, “surreptitiously” withholding documents from InCrowd,

“unilaterally” modifying search terms, “withholding” 97% of documents, etc., none of which

have any basis in reality.1 Now Plaintiffs also complain about documents Houlihan has

produced as part of the supplemental production. Plaintiffs will complain regardless what

1 As a couple of examples, Plaintiffs do not explain how Houlihan has “surreptitiously” withheld
documents from InCrowd when Houlihan has transparently conveyed the available formats for
production and Plaintiffs have refused to accept any of them. Plaintiffs have known for months
the reasonable set of search terms Houlihan was using for its document review. See Plaintiffs’
Ex. H (letter dated Oct. 29, 2019). There has been no spoliation of evidence; Houlihan has
preserved all documents on its H Drive. And Houlihan has always been transparent that it was
not running broad-based searches across the unindexed files in all of its shared drives – that was
the whole purpose of the report protocol the Discovery Referee ordered. Nor does the
percentage of files produced by a given custodian say anything about whether the production was
appropriate. Rather, it speaks to the quality of the search terms (or lack thereof) and the
frequency with which the custodian dealt with issues relevant to the case.
1
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

Houlihan does, and their inflammatory rhetoric will continue no matter how much Houlihan

explains. The four issues in the Second R&R have been addressed. No further discovery bears

any proportionality to the needs of this case.

In their latest evolution, Plaintiffs claim that Houlihan somehow “further debased these

proceedings” by reviewing thousands of documents from sixty-nine (69) custodians based on

search terms Plaintiffs proposed related to the in-house bonus. Plaintiffs attempt to twist the

Second R&R to mean that Houlihan must produce every email hitting on their overbroad and

unilaterally imposed search terms regardless of relevance. That is not what the R&R said, nor

would it be appropriate to require Houlihan to produce thousands of irrelevant documents.

Plaintiffs also attempt to bootstrap recommendations from the Third Report and

Recommendation, which related only to the Gricar subpoena, in an effort to expand discovery

from Houlihan. The Third R&R said nothing about discovery from Houlihan directly and did

not allow Plaintiffs to take additional discovery from Houlihan not set forth in the Second R&R;

it was limited to the specific requests in the Gricar subpoena as related to Gricar.

I. Houlihan’s Production Is More than Sufficient.

While Plaintiffs have seized on Houlihan’s interrogatory responses in an effort to revisit

the Discovery Referee’s ruling on producing documents from Stephen and Christopher Meyers,

in reality nothing has changed.2 Toni Chrystal is the person who primarily possessed and

handled policy and training for the company, and Plaintiffs have her documents.

2 While Plaintiffs refer to “belated” identification of the Meyers brothers, Plaintiffs cannot
seriously claim that they were unaware of the Meyers’ identities when they have demanded to
add the Meyers as custodians for months. For example, in Exhibit D to Plaintiffs’ submission,
dated May 2019, they argued that they “can identify at least the following key custodians whose
documents have not been collected or produced:”

 Houlihan Lawrence’s President, Chris Meyers, has discussed the company’s shift to a
market-share growth strategy and the importance of dual agency to the company’s
2
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

As to the corporate shared drives and InCrowd, Plaintiffs’ purported deficiencies are the

result of their own obstreperousness. Houlihan offered to evaluate a list of documents Plaintiffs

had identified from the shared drives, which Plaintiffs have never provided. Houlihan also

offered to produce documents from InCrowd in a format that is accessible to it. Plaintiffs

insisted on talking to the vendor themselves, even though Houlihan’s counsel and e-discovery

vendor had already done so.

Nor is Plaintiffs’ statement that they have received no communications regarding the

rationale, implementation, and enforcement of Houlihan’s dual agency policies and practices

accurate. Several examples from Houlihan’s voluminous production are attached, including:

 Email from Brendon DeSimone to the Bedford Office with an updated Exclusive

Right to Sell Agreement and explanation of changes (Ex. 1);

 Email from Toni Chrystal to Debra Dalton and others attaching updated new

agent book and explaining plan for training (Ex. 2);

 Email from Toni Chrystal to branch managers, Elizabeth Nunan, and others

regarding new agent orientation (Ex. 3);

growth, [and]

 Houlihan Lawrence’s CEO, Stephen Meyers, has likewise discussed the company’s shift
to a market-share growth to “get a larger share of a shrinking pie[.]”

Plaintiffs’ Ex. D. Plaintiffs did not identify Jim Gricar in that initial submission but added a
request for him at the last minute. Houlihan maintained that Gricar was not particularly involved
in these issues and would not have much responsive information. Nevertheless, Houlihan was
ordered to produce documents from his files and, consistent with Houlihan’s prior
representations, there was not much of relevance there. Plaintiffs now act like this is an
extensive cover up, rather than a result of their over-the-top discovery antics and insistence on
production from a largely irrelevant custodian that Houlihan described as such.
3
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

 Email from Toni Chrystal to branch managers copying Debra Dalton and Jim

Gricar following up on a discussion at the managers meeting about an addition to

the agency disclosure “best practices” document (Ex. 4);

 Email exchange between Toni Chrystal and Jim Gricar discussing plan for new

agent training program (Ex. 5);

 Emails from Brendon DeSimone to Bedford Office following up on an office

training by passing along a “cheat sheet” on how to correctly complete agency

disclosure forms (Exs. 6-7);

 Email from Howard Chwett to Bedford Office regarding compliance and code of

ethics documents (Ex. 8);

 Email from Deborah Valentino to Debra Dalton and Christopher Meyers

regarding a training class with Toni Chrystal at the Yonkers Office (Ex. 9);

 Email from Joseph Franco to Toni Chrystal thanking her for a “great and very

informative” training class (Ex. 10).

Plaintiffs’ take liberty in reading the Discovery Referee’s Third R&R as somehow

applicable to discovery from Houlihan when it addressed only the Gricar subpoena. For

example, Houlihan has not been ordered to produce documents regarding the original “creation”

of its policies, nor do such documents have anything to do with what disclosures were made in

the context of individual transactions. If a policy was considered but never implemented or

revised before implementation, that says nothing about the corporate-wide policy that was

actually provided to agents and deployed in the field.

4
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

II. Plaintiffs’ Accusations Are Unfounded.

It is unclear what exactly Plaintiffs are seeking in terms of an “articulation” of the

standard of relevance. The Second R&R required Houlihan to produce (1) “documents regarding

the HLI corporate policy, if any, regarding the institutional implementation, rationale and

training regarding dual agency” and (2) “internal emails from Scarsdale, Bronxville and White

Plains offices regarding any HLI institutional dual agency ‘bonus’ program” limited by agreed

upon search terms and, as discussed at the Court conference, custodians. In the first category,

Houlihan has produced the HLI corporate dual agency policies and documents related to their

institutional implementation, including voluminous training materials.3 As to the second, as set

forth in its Motion, Houlihan collected documents from the agents involved in the sample

transactions as well as the office managers (sixty-nine (69) custodians in total). Plaintiffs

premised their request for this extensive and burdensome review on the supposition that many

“blast” emails emphasizing the importance of keeping transactions in house would surface. If

such communications existed, they would have been captured through any of these agents’

emails since each office has its own listserv, and blast emails are sent to all agents. The absence

of such communications does not suggest that Houlihan withheld anything, but rather that the

anonymous letters were (much like Plaintiffs’ counsel) overblown.

As to the lack of responsive documents in Mr. Gricar’s files, the best explanation is that

he dealt with many business issues unrelated to dual agency such as recruitment and marketing.

3 Plaintiffs’ suggestion that the November 6 production predated the Second R&R and thus
should be expanded is a red herring. The Second R&R did not change the scope of Houlihan’s
review of Ms. Chrystal and Mr. Gricar’s documents, as Houlihan already produced policy
documents from these custodians (with the exception of those subject to the search term error
that has now been corrected). The in-house bonus issue was borne of Plaintiffs’ insistence that
office-wide emails touting the in-house bonus existed, and involved a separate collection and
review.
5
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

He did not have responsibility for training in this area and was not front line on this issue. The

fact that he did not frequently deal with dual agency issues means nothing more.4 As to

Plaintiffs’ counsel’s repeated accusations of spoliation, they have no evidence that any files that

previously existed have been deleted. To the contrary, Houlihan immediately placed a hold on

the H Drive when the lawsuit was filed, and the volume of documents Houlihan has been forced

to retain as a result of this litigation imposes an ongoing and significant burden on its IT systems.

Houlihan cannot help the fact that Mr. Gricar apparently did not store his files on the H Drive,

and he was not required to do so.5 Plaintiffs will have the opportunity to depose him for further

information based on the Third R&R.

Plaintiffs’ reliance on Houlihan’s position from a letter from October 2018 – a year and a

half ago – is unconvincing. The parties have exchanged volumes of correspondence, and the

Discovery Referee has engaged in the process and made recommendations since that time. As

evidenced by the documents attached as exemplars (see Exs. 1-10), Houlihan’s production has

gone well beyond simply the production of policies themselves and includes hundreds of related

emails, among other things. Tellingly, the case Plaintiffs cite emphasizes the difficulty of

obtaining class certification across disparate offices; the Court there denied class certification

after discussing at some length the hurdles imposed by the Supreme Court’s opinion in Wal-Mart

v. Dukes. Ruiz v. Citibank, N.A., 93 F. Supp. 3d 279, 289 (S.D.N.Y. 2015).

In the latest iteration of their legal theory, Plaintiffs now seek to avoid the Court’s

recognition that each transaction is unique by attempting to cast this case as one solely of

4 Houlihan would be willing to provide a random sample of such non-responsive documents for
in-camera review. It would attach such a sample to this submission but is reluctant to provide
those documents to Plaintiffs’ counsel for obvious reasons.
5 Plaintiffs’ reference to the “absence of” such files is just that – an absence; it does not mean
that files were not preserved; rather, it means there were no files there.
6
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

“omissions” not “affirmative representations.” That is a far cry from what Plaintiffs pled and

what they have argued in the past. The Third Amended Complaint focuses on allegedly

inadequate disclosures limited to the information in the required forms and an alleged “only if

asked” elaboration, not a complete absence of disclosure. In prior briefing Plaintiffs have been

hyperfocused on an alleged “script” regarding disclosures. Perhaps realizing that no such script

exists and that the cases they cited on the script issue come out the wrong way for them (see

Reply in Support of Motion for Protective Order), Plaintiffs pivot to an “omission” theory. But

the cases they cite are true omission cases – inaccurate pricing on title insurance, in one case (In

re Coordinated Title Ins. Case, 2005 WL 690380 (N.Y. Sup. Ct. Jan. 8, 2004)) and alleged

failure to disclose a known issue with the performance of a car, in the other (Haag v. Hyundai

Motor America, 330 F.R.D.127 (W.D.N.Y. 2019)6). These types of cases are a far cry from the

situation here, where disclosure forms were provided and even according to Plaintiffs’

allegations some discussions took place. Even if Houlihan had downplayed the risks of dual

agency as Plaintiffs allege – which Houlihan obviously disputes – that suggests that there was at

least discussion of the subject. Plaintiffs’ “nondisclosure” theory does not remove their burden

of proving the elements of class certification, which they cannot carry across thousands of

unique real estate transactions.

III. The Search Terms Houlihan Has Run Are Sufficient to Identify Relevant
Documents.

Houlihan has run the vast majority of the terms Plaintiffs proposed with slight

modifications to account for substantial overbreadth and the elimination of two terms that were

unworkable. Houlihan has already sifted through thousands upon thousands of irrelevant

6 Notably, despite the true “omission” theory at issue in Haag, the court declined to certify the
class based on its finding that individual issues predominated on damages. Plaintiffs’ claims
suffer from the same defect.
7
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

documents – requiring many hours of attorney time – identified by Plaintiffs’ still-overbroad

search terms. For the most part, Houlihan opted not to fight those search terms but rather to

incur the cost of reviewing irrelevant materials (an approach it continued with the substantially

overbroad “in house bonus” terms Plaintiffs proposed). The responsiveness rate about which

Plaintiffs complain is directly tied to the substantial overbreadth of their search terms. Now,

Plaintiffs ask for still more irrelevant review.

In considering the additional terms Plaintiffs propose, it is important to keep in mind the

terms that have already been run:

 any iteration of “designated agency” (i.e. designated agent, etc.);

 any iteration of “dual agency” (i.e. dual agent, etc.);

 any iteration of any form of the word “agency” within five words of any form of

the word disclose (i.e. agency disclosure, agent disclosed, agent did not disclose,

agent failed to disclose, agent should have disclosed, etc.);

 “in house”;

 “market share”;

 fiduciary;

 any iteration of grow within five words of strategy (i.e. growth strategy, strategy

to grow, strategy involves growing, etc.);

 the word bonus where the word commission appears anywhere in the document;

and

 the word bonus within three words of “in house” (capturing any reference to an in

house bonus).

8
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

These terms, which Houlihan has already run, are as broad as they sound. It is also

important to bear in mind that any incremental value of the terms Plaintiffs seek to add will only

be in identifying documents that hit on their new terms but do not hit on the terms that have

already been run. (If a document also hits on any of the other search terms, it has already been

captured and reviewed.) So any “scripts” or “talking points” Plaintiffs seek are those that do not

reference, among other things, dual agency, fiduciary duties, designated agency, or the in-house

bonus. It is difficult to see how such a document could bear any relationship to the issues in this

case. The same is true for the term “inventory”, even as modified. And the generic nature and

number (eighteen) of terms Plaintiffs propose for modification of “inventory” make their

proposal barely a limitation at all.

IV. Plaintiffs Are Not “Entitled” to the Name of Every File on Houlihan’s System
Regardless of Relevance.

Plaintiffs seek a pat on the back for “voluntarily relieving” Houlihan of the obligation to

run indexed searches across all of its shared drives (presumably using the same overbroad search

terms discussed above). Such searches would have involved not only what Plaintiffs deem a

“trivial” initial indexing cost of tens of thousands of dollars, those up-front costs would be

followed by many thousands of additional dollars in collection, processing, and attorney review

time. Contrary to Plaintiffs’ suggestion that running complex searches across an entire

company’s files in litigation that involves a discrete issue is par for the course, it absolutely is

not. Proportionality in discovery limits discovery to relevant sources of information.

Plaintiffs have received more than enough information from the reports Houlihan has

provided to identify the folders and/or documents, if any, that relate to the issues in this case.

Should the Discovery Referee have any doubt about the volume of information that Houlihan has

provided, the corporate drive report is attached as Exhibit 11 (Houlihan also provided twenty-

9
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

three file-level server reports from its branch offices, which are not included in this submission).7

The report provides tens of thousands of lines worth of path information. And Plaintiffs do not

address why they should have access to individual agents’ or executives’ personal files, such as

files relating to charitable contributions and taxes, or to files related to company litigation,

among other things. It is clear from Exhibit 11 that the vast majority of these file paths have

nothing to do with any issue in this lawsuit, and for those Plaintiffs think may contain policy or

training documents to which they are entitled under the Second R&R, Houlihan has invited a

targeted request on that topic.

V. Houlihan Cannot Create a Way to Collect and Produce Documents from a Third-
Party InCrowd Platform that Does Not Exist.

Houlihan has been transparent about the challenges of collecting and producing

documents from InCrowd. It informed Plaintiffs many months ago that complex searching was

not possible but offered to run the bulk of Plaintiffs searches as simple searches in the format to

which it had direct access to the platform and produce screenshots or PDFs of relevant results.

Plaintiffs did not want that. So Houlihan went to the vendor and tried to find a solution by

asking it to run complex searches on the back end. That generated an Excel report that Plaintiffs

are unwilling to accept. The parties discussed this issue, and at Plaintiffs’ request, Houlihan

went back to the vendor again and this time spoke with the founder. He confirmed that the

output formats Houlihan had offered were the outputs available. It is not Houlihan that has been

unreasonable in relation to InCrowd. To suggest that Houlihan has been anything less than

transparent about the challenges associated with searching InCrowd is not factual, nor is it

accurate that Houlihan somehow made a “revelation” of these difficulties for the first time in its

7 To see the full path, expand column A of the Excel spreadsheet.
10
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

February 2020 letter. See Ex. B to Second Motion for Protective Order (July 2019

correspondence outlining issues with searching InCrowd).

An additional call to the vendor of InCrowd is an unnecessary waste of time, and

Houlihan does not have an obligation to give opposing counsel direct access to its vendors to

satisfy its discovery obligations. Plaintiffs’ request for production in multiple formats is

unnecessary and unduly burdensome given the already cumbersome process of collecting from

this platform and the unnecessary time that has already been spent on this issue.

VI. Houlihan’s Review and Production of Documents from Sixty-Nine (69) Custodians
Related to the In-House Bonus Issue Is Sufficient.

Houlihan collected and reviewed thousands of irrelevant documents hitting on Plaintiffs’

proposed “in house bonus” search terms run across sixty-nine (69) custodians. Contrary to

Plaintiffs’ suggestion, Houlihan included the office managers for these three offices in its

collection. Houlihan did not select these agents in a self-serving fashion; rather, it collected from

the agents involved in the sample transactions. Plaintiffs, not Houlihan, selected those sample

transactions. This is an appropriate and proportionate approach to the Discovery Referee’s

directive.

Plaintiffs fail to grapple with the possibility that their anonymous sources may have been

exaggerating. Regardless, Houlihan did not “rig” the results of its search. If there were any

volume of widespread emails encouraging agents to keep transactions in-house, they certainly

would have been picked up by Plaintiffs’ broad search terms. The fact that there were not a large

volume of these communications reflects the quality of Plaintiffs’ anonymous sources, not any

action on Houlihan’s part. And the administrative assistants would not add much to the mix – if

there had been blast emails they would certainly go to at least some, if not all, of the agents from

whom Houlihan has collected documents and be reflected in those agents’ custodial files.

11
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

Plaintiffs’ protestations notwithstanding, it is true that the overwhelming majority of the

results of Plaintiffs’ searches were spam, even with the limitation they proposed. While that

limitation did eliminate some spam documents, the majority of the remaining hits were still

spam. A few examples of the type of documents in this category are attached as Exhibits 12-14.

Plaintiffs’ purported bewilderment notwithstanding, unsolicited email is a part of life for all

entities, large or small, and much of that unsolicited email promises the possibility of bonuses.

Perhaps Plaintiffs’ counsel is used to running higher quality search terms than the ones Plaintiffs

dictated to Houlihan.

Under no circumstances should Houlihan be required to produce “all emails sent or

received” by all email accountholders in Scarsdale, Bronxville, and White Plains that hit on

Plaintiffs’ extremely overbroad search terms. The Second R&R does not require that non-

standard approach, which would encompass production of many documents that have nothing to

do with the issues in this case. If production of all documents hitting on search terms had been

required, regardless of relevance, Houlihan would have (1) objected to the R&R, and (2)

objected to Plaintiffs’ overbroad search terms. It did neither, but instead went through the

exercise of reviewing thousands of documents on the basis of anonymous letters from Houlihan

detractors. It has done enough.

VII. Conclusion.

Far from seeking to limit Plaintiffs to “superficial” disclosure, Houlihan has gone to

extraordinary lengths to satisfy Plaintiffs’ extensive and ever-evolving discovery demands. Now

is the time to draw the line. Houlihan asks that the Discovery Referee enter a Fourth Report and

Recommendation imposing a protective order against further discovery not required by the

Second Report and Recommendation.

12
FILED: WESTCHESTER COUNTY CLERK 05/14/2020 08:55 AM INDEX NO. 60767/2018
NYSCEF DOC. NO. 578 RECEIVED NYSCEF: 05/14/2020

Dated: White Plains, New York
March 11, 2020

By: _Jessica M. Lindemann____________
Robert D. MacGill (Pro Hac Vice)
Jessica M. Lindemann (Pro Hac Vice)
BARNES & THORNBURG LLP
11 South Meridian Street
Indianapolis, IN 46204
(317) 231-7223

Alfred E. Donnellan
DELBELLO DONNELLAN
WEINGARTEN
WISE & WIEDERKEHR LLP
One North Lexington Avenue
White Plains, New York 10601
(914) 681-0200
Attorneys for Defendant Houlihan
Lawrence, Inc.

Case Info

Judge

Linda S. Jamieson Track Judge’s New Case

Case No.

(Subscribe to View)

Document Filed Date

May 14, 2020

Case Filing Date

July 14, 2018

County

Parties

BHOLAN, MICHELLE ANN Attorney for the Defendant
DONNELLAN, ALFRED E. Attorney for the Defendant
Ellyn Berk Plaintiff
FATTARUSO, PAUL Attorney for the Plaintiff
FRIEDLAND, AMOS EMORY Attorney for the Plaintiff
HARRINGTON, WILLIAM P Attorney
HOCHBERG, SHARI B. Attorney for the Defendant
Houlihan/Lawrence Inc. Defendant
KRINICK, EVAN H Attorney for the Defendant
LARA-GARDUNO, NELIDA Attorney for the Defendant
OHLEMEYER, WILLIAM S. Attorney for the Plaintiff
Pamela Goldstein Plaintiff
Paul Benjamin Plaintiff
Tony Berk Plaintiff
VEST, JEREMY CAIN Attorney for the Plaintiff
William P. Harrington Court-Appointed Discovery Referee Non Party
ZACH, JOHN T. Attorney for the Plaintiff
Peter Kiernan Attorney
MATTHEW TEBO Attorney
ERIC EICHENLAUB Attorney
COURTNEY ROCKETT Attorneys for Plaintiffs
ANTHONY GIAIMO Attorney
SCOTT NEJAME Attorney
HENRY MAN Attorney
ALBERT PELLEGRINO Attorney
COLLEEN CALABRO Attorney
BRIAN LEVINE Attorney
SCOTT WEBER Attorney
Jessica Lu Attorneys for Defendants
WILLIAM HARDING Attorney
FRANK SALVI Attorney
STEPHEN LEWIS Attorney
MATTHEW CUNHA Attorneys for Defendants
ROBERT MILLER Attorney
JUDITH SHAMPANIER Attorney
JOHN MCCONNELL Attorney
PATRICIA HARRINGTON Attorney
SALVATORE GATTO Attorney
EDWARD SUMBER Attorney
WILLIAM PICCIANO Attorney
LEON CAMERON Attorney
LEONARD BENOWICH Attorney
PATRICK HARRINGTON Attorney
MATTHEW TRIPOLITSIOTIS Attorneys for Plaintiffs
PHILIP HALPERN Attorney
STEPHEN JONES Attorney
MARK HALPERN Attorney
ROBERT GILMAN Attorneys for Defendants
MARC LIFSET Attorney
PATRICK ROHAN Attorneys for Plaintiffs
NICHOLAS GRAVANTE Attorneys for Plaintiffs
MARC ANTONECCHIA Attorneys for Defendants
JAMES RIDDLE Attorneys for Defendants
STEPHEN LEW Attorney
SCOTT SALANT Attorneys for Defendants
J JONES Attorney
JEREMY VIRGIL Attorneys for Plaintiffs
AIDAN MCCORMACK Attorney
PATRICK J. Attorneys for Plaintiffs
ROBERT SANTORO Attorneys for Defendants
Mike Byrnes Attorney
LOUIS ALTMAN Attorney
KAITLIN JACKSON Attorney
ARTHUR SCINTA Attorney
RUSSELL YANKWITT Attorney
ALFRED EHRENCLOU Attorneys for Defendants

For full print and download access, please subscribe at https://www.trellis.law/.

Exhibit,Appendix: Pamela Goldstein, Ellyn Berk, Tony Berk, Paul Benjamin v. Houlihan/Lawrence Inc.

Preview

Case Info

Parties