Motion for Summary Judgment 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.

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FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

HOULIHAN LAWRENCE
OPPOSITION TO MOTION TO CERTIFY

EXHIBIT 9

HL OPP. - EXHIBIT 9 - PAGE 1
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF WESTCHESTER
--------------------------------------------------------------------X
PAMELA GOLDSTEIN,
ELLYN & TONY BERK, as Administrators
of the Estate of Winifred Berk, and PAUL Index No. 60767/2018
BENJAMIN, on behalf of themselves
and all others similarly situated, Hon. Linda S. Jamieson

Plaintiffs,
-against-
AFFIDAVIT IN SUPPORT
OF MOTION TO SEAL
HOULIHAN/LAWRENCE INC.,

Defendant.

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

STATE OF CONNECTICUT )
) ss:
COUNTY OF FAIRFIELD )

GEOFFREY BERRY, being duly sworn, hereby deposes and says as follows:

1. I am the White Plains Office Manager for Houlihan Lawrence. I am an adult over

the age of 21, competent to make this affidavit. Unless otherwise stated, I have personal

knowledge of the facts stated in this affidavit.

2. I submit this affidavit in support of Houlihan Lawrence’s Motion to Seal

Plaintiffs’ Motion for Class Certification and Exhibits & Affidavits in Support, filed in the

above-captioned matter.

3. The Exhibits in Support filed by Plaintiffs consist of 5,333 pages. Many of these

pages contain proprietary Houlihan Lawrence business information and internal

communications. Examples of the proprietary information in the Exhibits include:

a. Plaintiffs’ Exhibits 85 and 86 contain master lists of agent “splits.” Agent

“splits” are widely recognized as confidential and proprietary to the
1

HL OPP. - EXHIBIT 9 - PAGE 2
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NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

brokerage. Even other agents at the brokerage typically do not have access to

the “splits” of their fellow agents. Public release of this information would

give competitors information on how to compete with Houlihan Lawrence for

services of real estate agents.

b. Plaintiffs’ Exhibits 88, 100, 177, 179, and 183 contain specific internal split

information specific to a transaction. Again, agent “splits” are widely

recognized as confidential and proprietary to the brokerage. Even other agents

at the brokerage typically do not have access to the “splits” of their fellow

agents. Public release of this information would give competitors information

on how to compete with Houlihan Lawrence for services of real estate agents.

c. Plaintiffs’ Exhibit 176 contains confidential financial information of a

customer.

d. Many copies of Houlihan Lawrence’s internal polices, procedures, and

training materials appear within Plaintiffs’ exhibits. These materials are

proprietary and confidential to Houlihan Lawrence, and creating them took

Houlihan Lawrence a great deal of time, money, and effort. They are of

extreme competitive value and were compiled and maintained at great cost

and effort to Houlihan Lawrence. Providing these materials to the public

would give Houlihan Lawrence’s competition an unfair advantage, as they

would have access to the vast majority of Houlihan Lawrence’s training,

policy, and procedure library at no cost.

e. Many items of internal correspondence appear within the Exhibits in Support.

This correspondence shows, for example, Houlihan Lawrence personnel

HL OPP. - EXHIBIT 9 - PAGE 3
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

considering various business strategies and policies. These internal

deliberations of Houlihan Lawrence personnel constitute Houlihan Lawrence

business strategies. Such strategies are kept confidential, and their release

would pose competitive risks to Houlihan Lawrence.

f. Full copies of nearly every deposition transcript in this case are within the

Exhibits in Support, including the transcript of my deposition in this case.

These transcripts were taken with the assurance that the Court’s

Confidentiality Order would protect them from disclosure. Many confidential

topics were discussed, including salaries, bonuses, splits, training protocols,

business strategies, business outcomes, profits, personnel matters, etc. For

example, the transcript of my deposition discloses my exact salary and

incentive compensation payment structure. See Plaintiffs’ Exhibit 28 – Geoff

Berry Transcript – page 108–110.

4. The public release of the information in the Exhibits in Support would cause

Houlihan Lawrence competitive harm and would threaten Houlihan Lawrence’s competitive

advantage.

5. The Affidavits in Support (including especially the affidavit of Mr. Cusack) and

the Memo in Support of Motion to Certify repeat much of the information in the Exhibits in

Support. Therefore, their public release would harm Houlihan Lawrence in the same way.

6. I am familiar with certain press coverage of the allegations made by Plaintiffs in

this case and related Court filings. As to press coverage, I can confirm specific details:

a. Plaintiffs retained a public relations firm called Rubenstein Public Relations,

Inc. at some time before the filing of this lawsuit. See Ciulla Aff. Ex. J at 6

HL OPP. - EXHIBIT 9 - PAGE 4
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

(“Plaintiffs’ counsel utilized Rubenstein, a third-party strategic

communications advisor… in connection with its development and

implementation of the class’s pre-filing legal strategy.”).

b. Rubenstein, on behalf of Plaintiffs, issued a press release upon the filing of

this lawsuit. See Ciulla Aff. Ex. J at 1 (“Rubenstein Associates, Inc. issued a

short press release on behalf of Plaintiffs’ counsel announcing the filing of

this lawsuit, forwarding a copy of the complaint, summarizing its central

allegations, and quoting two of Plaintiffs’ attorneys”); id. at 2 (characterizing

press release as an “announce[ment of] the filing of a class action involving

allegations of widespread consumer-oriented misconduct”); see also, e.g.,

Ciulla Aff. Ex. J at 9–10 (copy of press release).

c. The press release was published by many news agencies, including Inman and

the Wall Street Journal. See, e.g., Berry Exhibit A (news article reciting the

July 7, 2019 “joint statement” by “Jeremy Vest,” “with partner William

Ohlemeyer”); see also Ciulla Aff. Ex. J at 12–28 (copies of news articles).

d. The press release contained allegations such as:

i. “[Houlihan Lawrence] operated a bait-and-switch scheme to lure

thousands of homebuyers and sellers into dual-agent transactions.”

Ciulla Aff. Ex. J at 9;

ii. “A huge proportion of Houlihan Lawrence’s growing sales have come

through ill-gotten gains on undisclosed, non-consensual dual-agent

deals where the firm followed a systematic strategy and policy by

HL OPP. - EXHIBIT 9 - PAGE 5
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

which it abandoned its duty of undivided loyalty to its clients to grab

double-commissions and choke out its competitors.” Id.;

iii. “Through high-pressure tactics and sleight of hand, Houlihan

Lawrence was able to pressure area lawyer Pamela Goldstein into a

dual-agent transaction without her informed consent.” Id.;

iv. “Houlihan Lawrence uses its market dominance to lure consumers into

dual-agent transactions.” Id.;

v. “Houlihan Lawrence has aggressively used dual agency and has taken

over the Westchester County real estate market in the process.” Id.;

e. Plaintiffs’ subsequent allegations that Houlihan Lawrence agents in my office

were “forging” signatures on state forms were also published in Inman. See

Berry Exhibit B.

7. These publicly-disseminated statements and accusations damaged my reputation

and the reputations of many of my agents and staff. These statements have had lingering effects

on my business life—a real estate agent’s reputation is very important, especially among

Houlihan Lawrence’s core clientele.

8. Plaintiffs’ Affidavits in Support (including especially the affidavit of Mr. Cusack)

and the Memo in Support of Motion to Certify repeat these and many other similar accusations

about Houlihan Lawrence.

9. Berry Affidavit Exhibit A is a true and correct copy of an Inman News article

published on July 18, 2018.

10. Berry Affidavit Exhibit B is a true and correct copy of an Inman News article

published on November 30, 2018.

HL OPP. - EXHIBIT 9 - PAGE 6
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

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HL OPP. - EXHIBIT9- PAGE7
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

Certificate of Counsel
Pursuant to Commercial Division Rule 17

I, Matthew T. Ciulla, counsel for Defendant, hereby certify, pursuant to
Commercial Division Rule 17, that the word count for the foregoing document,
excluding the caption, table of contents, table of authorities, and signature block, is
1080 words. This document therefore complies with the rule that limits briefs,
memoranda, affirmations, and affidavits to 7,000 words. I certify that the Microsoft
Word generated word count for this document is 1080 words.

Dated: Indianapolis, Indiana
November 8, 2021

BY: DELBELLO DONNELLAN
WEINGARTEN
WISE & WIEDERKEHR LLP

_/s/Matthew T. Ciulla___________
Alfred E. Donnellan, Esq.
Nelida Lara, Esq.
One North Lexington Avenue, 11th Floor
White Plains, New York 10601
Phone: (914) 681-0200

OF COUNSEL:

Robert D. MacGill (pro hac vice)
Matthew T. Ciulla (pro hac vice)
MACGILL PC
156 E. Market St.
Suite 1200
Indianapolis, IN 46204
Phone: (317) 721-1253

Attorneys for Defendant

HL OPP. - EXHIBIT 9 - PAGE 8
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

BERRY EX A

New York lawsuit calls dual agency deals into question
inman.com/2018/07/19/new-york-based-houlihan-lawrence-accused-of-deceptive-dual-agency-practice-in-lawsuit

A White Plains, New York, homebuyer has filed suit against Houlihan Lawrence, among the
largest real estate brokerages in upstate New York, accusing the firm of “predatory behavior”
through a legal practice known as dual agency that has come under increased scrutiny in
recent months.

The homebuyer, Pamela Goldstein, alleged that only three days after submitting a $637,000
bid for the four-bedroom white colonial in White Plains did she learn the brokerage was also
representing the seller and that her agent, Daniel Cezimbra, was the brother-in-law of a
broker leading a team for the seller. Both men shared in the commission.

“This suit seeks to recover millions of dollars in sales commissions that homebuyers and
sellers who were duped into dual-agent transactions paid Houlihan Lawrence for loyal
representation that they didn’t receive,” said attorney Jeremy Vest in a joint statement with
partner William Ohlemeyer.

“It also seeks to ensure that, going forward, no homebuyer or seller ends up in a dual-agent
transaction without fully understanding the important rights they lose in that situation.”

Vest, who delivered a joint statement to Inman on Thursday, believes the case could have
repercussions far beyond their client, herself the general counsel of a large communications
firm, and are seeking to file a class action lawsuit on behalf of other former Houlihan
Lawrence clients. For now, however, Goldstein is the only plaintiff in the case.

1/3

HL OPP. - EXHIBIT 9 - PAGE 9
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

BERRY EX A
The brokerage, which boasts 1,300 agents across upstate New York and Fairfield County,
Connecticut, represented both the buyer and seller in nine out of 10 of its biggest deals in
Westchester in 2017 and, among home sales in Bronxville, a whopping 80 percent of all
transactions in excess of $2 million were through dual agency, according to the lawsuit.

In court papers, Goldstein claims she was pressured by Cezimbra to act fast because other
interested parties were lining up for a chance to purchase the home, and she was told to
overbid for the property.

Three days after her initial bid, she was informed through a mandatory state form, as
required by New York State law, of the dual-agency practice. The form, according to the Wall
Street Journal in a story published Monday, was filled out incorrectly.

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Dual agency is legal in New York State, but only under the condition that the agent receive
“informed consent” from the buyer or seller — defined as “lay[ing] bare the truth, without
ambiguity or reservation, in all its stark significance.”

Critics, however, argue that dual agency frequently opens the door to obvious conflicts of
interest, and it becomes more complicated when it’s not a case of one broker representing
both buyer and seller, but rather, a case of two brokers at the same firm working on the same
sale from opposite sides.

In those cases, the firm itself is legally considered one, dually acting “agent,” and the degree
to which the two brokers are collaborating on the sale is far less clear.

In June, the Canadian province of British Columbia banned the practice entirely, and in the
United States, Colorado, Florida, Kansas and Wyoming prohibit dual agency. Other real
estate experts believe it should be banned nationally.

“It’s like attorney-client,” Nathan White, of Link Real Estate Group, told Inman in June. “You
can’t have an attorney represent the plaintiffs and the defendant neutrally. It’s great from a
money perspective, but why are we allowed to do it?”

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2/3

HL OPP. - EXHIBIT 9 - PAGE 10
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

BERRY EX A
A spokesperson for Houlihan Lawrence on Thursday responded
to Inman’s request for comment with a statement.

“A former client has filed a lawsuit against our company, and we
deny allegations in the complaint,” wrote the Houlihan Lawrence
spokesperson. “Houlihan Lawrence has been dutifully serving
our clients for 130 years and is confident in our business
practices. We will continue to represent our buyer and seller
clients with integrity.”

Email Inman

3/3

HL OPP. - EXHIBIT 9 - PAGE 11
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

BERRY EX B

Brokerage accused of forging documents in dual agency
lawsuit
inman.com/2018/11/30/brokerage-accused-of-forging-documents-in-dual-agency-lawsuit

Clients are accusing top New York brokerage Houlihan Lawrence of forging disclosure forms
in the firm’s effort to have their dual agency lawsuit dismissed.

In a lawsuit first filed in July and amended in October, four buyer and seller plaintiffs allege
Houlihan Lawrence duped them into double-ended deals where the brokerage represented
both buyer and seller, thereby committing breach of fiduciary duty and unjust enrichment,
among other charges.

Anonymous letters sent to the plaintiffs’ law firm also allege the brokerage pays or paid its
agents bonuses for keeping transactions in-house — a tactic that is not unheard of in the real
estate industry but that plaintiffs allege encouraged double-sided transactions to boost the
firm’s market share for its eventual acquisition by Berkshire Hathaway affiliate
HomeServices of America.

Houlihan Lawrence owns and operates 30 offices with more than 1,300 agents in New York’s
largely affluent Westchester, Putnam and Dutchess counties.

In a motion to dismiss the suit filed Oct. 30, attorneys for Houlihan Lawrence argue that
since the buyer and seller plaintiffs each signed statutory disclosure forms consenting to
Houlihan Lawrence’s dual agency with designated sales agents (i.e. with separate Houlihan
Lawrence agents representing buyer and seller), their breach of fiduciary duty claims should
be tossed.

1/5

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NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

BERRY EX B
But attorneys for homebuyers Pamela Goldstein and Paul Benjamin and sibling home sellers
Tony Berk and Dr. Ellyn Berk argue that signed forms are not enough to fulfill a broker’s
consent and disclosure obligations under New York state law, which requires fully informed
consent.

“The Department of State and the state’s major trade association, NYSAR (New York State
Association of Realtors), have recognized that ‘merely presenting the form to a prospective
purchaser or seller is insufficient’ to fulfill a broker’s disclosure and informed consent
duties,” plaintiffs’ attorneys at Boies Schiller Flexner LLP wrote in their opposition to the
motion to dismiss, filed Nov. 20.

“[T]he Department of State explained that the form ‘does not and was not intended to relieve’
brokers of their ‘common law duty’ to ‘obtain informed consent through full disclosure of the
implications of the proposed dual agency relationship’ — rather, the form is ‘the beginning of
full disclosure,’ and is not a ‘substitution for the rigorous duties of full disclosure in the
common law.'”

Dual agents must explain to both buyer and seller that the agent is acting for the other party
as well and explain the possible effects of dual representation, including that their consent
would mean they are giving up their right to undivided loyalty, according to the opposition
filing.

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In its motion to dismiss, “Houlihan Lawrence does not and
cannot contend that it fully disclosed the risks, downsides, and
options of dual agency, as it was duty-bound to do,” plaintiffs’
attorneys added.

‘Sham’ disclosure forms
Moreover, they allege that the signatures on one of the statutory disclosure forms Houlihan
Lawrence included in its legal filing are phony — copied and pasted from another form.

“Its proffered documentary evidence has revealed a new element of Houlihan Lawrence’s
dual-agency scheme: fabricating sham statutory disclosure forms. The motion features … an
undated statutory disclosure form which Houlihan Lawrence claims Plaintiffs Tony and Ellyn
Berk signed. But inspection of the document shows that the signatures on that form were
copied and pasted from a prior, differently marked form — all without the Berks’ knowledge
or consent,” plaintiffs’ attorneys wrote.

2/5

HL OPP. - EXHIBIT 9 - PAGE 13
FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

BERRY EX B

Screen shot from plaintiffs’ opposition to defendants’ motion to dismiss

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Houlihan Lawrence’s apparent practice of creating “sham”
statutory disclosure forms confirms the brokerage’s “culture of
disregard for client consent,” they added. “And it is yet another
reason why statutory disclosure forms, standing alone, cannot
establish disclosure and informed consent as a matter of law.”

Asked to comment on the allegations, a spokesperson for
Houlihan Lawrence said in an emailed statement Wednesday,
“For more than 130 years, Houlihan Lawrence has had a
reputation of responsible business practices and integrity. We
believe this lawsuit is meritless and intend to vigorously defend
against plaintiffs’ claims.”

Claims ‘unique’ or part of a ‘scheme’?
The lawsuit seeks class-action status and aims to represent all buyers and sellers of
residential real estate in Westchester, Putnam, and Dutchess counties from January 1, 2011
to the present where Houlihan Lawrence represented both the buyer and seller in the same

3/5

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FILED: WESTCHESTER COUNTY CLERK 03/22/2022 05:03 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

BERRY EX B
deal.

In its motion to dismiss, Houlihan Lawrence contends that claims regarding real estate
transactions where the facts are “unique” to each plaintiff cannot have a broad impact on
consumers at large and should not be covered under a class action.

“The fact of customer consent is case and individual specific. That is one reason why
Plaintiffs’ breach of fiduciary claim cannot be maintained on a class basis. Common proof of
consent is impossible and requires individual inquiries and individual trials,” wrote attorneys
for Houlihan Lawrence at Collier Halpern & Newburg LLP.

However, plaintiffs’ attorneys argue that Houlihan Lawrence’s conduct has affected all class
members and involve common questions of fact and law.

“Its class certification arguments ignore the fact that this case is based on Houlihan
Lawrence’s firm-wide scheme to steer clients into undisclosed, non-consensual dual agent
transactions, including through secret dual-agency kickbacks to its agents and a long list of
other deceptive and unfair practices,” they wrote.

In its motion to dismiss, Houlihan Lawrence does not dispute that it never told the plaintiffs
“that it financially incentivizes its agents to steer clients into dual-agent transactions,” they
added. That undermines consumers’ ability to make an informed decision about dual agency
and hurts the public, they wrote.

Does it matter who paid the commissions?
Houlihan Lawrence’s attorneys maintain that the unjust enrichment claims from homebuyer
plaintiffs Goldstein and Benjamin should be dismissed because they did not pay any
commission in their transactions and therefore Houlihan Lawerence did not benefit at their
expense.

“Anyone who has sold a home knows that the seller pays the entire commission. The buyer
Plaintiffs’ transactions were no different,” they wrote.

“The sellers agreed to pay a 5 percent commission rate and actually paid that amount at or
after the closing. The buyer Plaintiffs are not entitled to recover any portion of a commission
they did not pay.”

But plaintiffs’ attorneys note that the Federal Trade Commission and Department of Justice
disagree with Houlihan Lawrence’s position. In a 2007 report, the agencies said that
“because the amount home sellers pay their real estate broker is built into the home sales
price, both home buyers and sellers bear this expense.”

4/5

HL OPP. - EXHIBIT 9 - PAGE 15
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NYSCEF DOC. NO. 1138 RECEIVED NYSCEF: 03/22/2022

BERRY EX B
“Illustrating this well-recognized economic reality, Houlihan Lawrence admits that it
collected a sales commission of $80,000 in connection with buyer Plaintiff Paul Benjamin’s
transaction –and received a check from him in that amount at closing,” plaintiffs’ attorneys
wrote.

Screen shot of Paul Benjamin’s check to Houlihan Lawrence in plaintiff’s opposition to motion to
dismiss

Even if the buyers in a dual agency transaction didn’t pay Houlihan Lawrence directly, that
doesn’t mean the brokerage didn’t benefit because it still received more in commission
money, according to plaintiffs’ attorneys.

“Had another broker represented those buyer-Plaintiffs — a broker who was not a dual agent
and could therefore faithfully represent the buyer-Plaintiffs — that commission money would
have gone to the faithful broker instead of Houlihan Lawrence,” they wrote.

“Houlihan Lawrence eagerly represents buyer clients all the time — not out of charity, but for
the financial benefit of the commission money it receives for doing so.”

Email Andrea V. Brambila.

5/5

HL OPP. - EXHIBIT 9 - PAGE 16

Case Info

Judge

Linda S. Jamieson Track Judge’s New Case

Case No.

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Document Filed Date

March 22, 2022

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

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

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