Preview
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1167 RECEIVED NYSCEF: 01/31/2023
EXHIBIT 35
FILED: NEWSean[sean.topping@nortonrosefulbright.com];
YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
To: Topping, Sanjay Ibrahim[Sanjay.Ibrahim@piblaw.com]; Younger, Stephen
P.[spyounger@foleyhoag.com];
NYSCEF DOC. NO. 1167 Michele Kahn[mk@kahngoldberg.com] RECEIVED NYSCEF: 01/31/2023
Cc: Archer, Judith A.[judith.archer@nortonrosefulbright.com]; Corder, Victoria[victoria.corder@nortonrosefulbright.com]; Ward,
Luke[luke.ward@nortonrosefulbright.com]
From: Scott Parker[Scott.Parker@piblaw.com]
Sent: Wed 5/18/2022 10:34:33 PM (UTC)
Subject: RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713]
Sean, we are fine with a June 6 motion exchange date, and a normal briefing schedule thereafter. But we do not agree to a 7,000
word limit, given the scope of the issues involved. We intend to ask the Court to expand the word limit to 14,000 per side, with
oppositions of the same limit, and replies of 8,400 words.
Thanks,
Scott
Scott Parker
NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
Direct: +1 908.333.6220 | Main: +1 212.596.7037
www.piblaw.com
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use,
disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original
message.
From: Topping, Sean
Sent: Wednesday, May 18, 2022 5:12 PM
To: Scott Parker ; Sanjay Ibrahim ; Younger, Stephen P.
; Michele Kahn
Cc: Archer, Judith A. ; Corder, Victoria ;
Ward, Luke
Subject: [EXTERNAL] RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713]
Scott,
Given that we did not receive confirmation on the below from Plaintiffs, we propose filing our respective discovery motions on
June 6 and that each side will file an omnibus motion of 7000 words max for the issues listed below, with oppositions of the same
length, and replies of 4200 words that will follow the normal briefing schedule. Please confirm your agreement.
Best,
Sean
Sean Topping | Senior Associate
Norton Rose Fulbright US LLP
1301 Avenue of the Americas, New York, New York 10019-6022, United States
Tel +1 212 318 3361 | Fax +1 212 318 3400
sean.topping@nortonrosefulbright.com
NORTON ROSE FULBRIGHT
Law around the world
nortonrosefulbright.com
From: Topping, Sean
FILED: NEW INDEX NO. 657193/2020
Sent: Thursday, May YORK
12, 2022 COUNTY
11:47 AM CLERK 01/31/2023 03:42 AM
To: 'ScottDOC.
NYSCEF Parker'NO.
;
1167 'Sanjay Ibrahim' ;RECEIVED 'Younger, Stephen
NYSCEF: P.' 01/31/2023
; 'Michele Kahn'
Cc: Archer, Judith A. ; Corder, Victoria ;
Ward, Luke
Subject: RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713]
Scott,
I’m following up on briefing on the Rule 14 letters. Following the Court’s instruction to proceed with briefing on your March 1,
2022 Rule 14 letter, we assume the parties will brief on the following topics:
Plaintiff
• Issues raised re Defendants’ privilege log (from Plaintiff’s November 11, 2021 letter)
• Issues raised re Defendants’ mental health and purported substance use (in Plaintiff’s March 1, 2022 letter)
Defendants
• Plaintiff’s privilege log entries including Lisa Rubin (from Defendants’ September 16, 2021 letter)
• Paul Schwartzman subpoena (served June 25, 2021, addressed in Defendants’ June 20, 2021 letter)
We do not think any of the issues are particularly complicated and believe they could be argued succinctly within the normal word
limits (7000 words for moving brief, 7000 words for opposition, 4200 for reply). Please let us know if you agree. Also, do you still
want to set May 23rd as the date for initial briefing? If so, we would ask that the opposition due date be extended for both
motions until June 3rd, replies due June 9th, and the return date sent for June 10th. Alternatively, we are fine with setting the
initial briefing due date for after the Memorial Day holiday (perhaps in early June) and following a traditional 16-day return
date/briefing schedule.
Let us know.
Best,
Sean
Sean Topping | Senior Associate
Norton Rose Fulbright US LLP
1301 Avenue of the Americas, New York, New York 10019-6022, United States
Tel +1 212 318 3361 | Fax +1 212 318 3400
sean.topping@nortonrosefulbright.com
NORTON ROSE FULBRIGHT
Law around the world
nortonrosefulbright.com
From: Topping, Sean
Sent: Wednesday, May 4, 2022 5:01 PM
To: Scott Parker ; Sanjay Ibrahim ; Younger, Stephen P.
; Michele Kahn
Cc: Archer, Judith A. ; Corder, Victoria ;
Ward, Luke
Subject: RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713]
Scott,
In response to your questions:
• Defendants do not agree to provide a certification concerning the “Sami Tekiner will, trust, or other operative legal
document that confer rights on Plaintiff.” We have represented that there are not any other documents responsive to that
request to produce. Defendants also understand their duty to supplement if the need arises.
• The parties submitted their Rule 14 letters regarding the issues raised in your March 1, 2022 letter and the Court has not
FILED: INDEX NO. 657193/2020
acted orNEW YORK
addressed COUNTY
the letter. CLERK
We believe that in01/31/2023
order to comply with 03:42 AM
the Commercial Division rules we should wait for the
NYSCEF Court to address
DOC. NO. the letter.
1167 RECEIVED NYSCEF: 01/31/2023
• Based on your response re Mr. Schwartzman’s deposition, we understand that Plaintiff is unwilling to narrow the topics
included in her subpoena. Accordingly, Defendants will address the Schwartzman subpoena at the appropriate time and
fashion.
Best,
Sean
Sean Topping | Senior Associate
Norton Rose Fulbright US LLP
1301 Avenue of the Americas, New York, New York 10019-6022, United States
Tel +1 212 318 3361 | Fax +1 212 318 3400
sean.topping@nortonrosefulbright.com
NORTON ROSE FULBRIGHT
Law around the world
nortonrosefulbright.com
From: Scott Parker
Sent: Friday, April 29, 2022 3:28 PM
To: Topping, Sean ; Sanjay Ibrahim ; Younger, Stephen P.
; Michele Kahn
Cc: Archer, Judith A. ; Corder, Victoria ;
Ward, Luke
Subject: RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713]
Sean, thank you for your e-mail. On our side, you are correct that we intend to brief the issues raised in our November 11, 2021
letter. As for the issues raised in our July 30, 2021 and February 18, 2022 letters, whether we also need to brief those issues
depends upon the following (which we ran out of time to raise in our last call with you): are you willing to provide a certification
that states that defendants do not possess any additional documents – beyond what has already been produced – that confer a
right to Plaintiff in the business, including any Sami Tekiner will, trust, or other operative legal document that confer rights on
Plaintiff, including as a contingent beneficiary? While your March 25 e-mail indicates that defendants do not “believe there are any
other documents relevant to produce here”, that is different from whether any such documents exist.
Additionally, we would also like to brief the issues raised in our March 1, 2022 letter. Whether those issues will be addressed in
our initial brief on the (potential) May 23 date, however, depends upon whether you will consent to our jointly writing to the court
to advise that we do not believe a Rule 14 conference is necessary as to those issues. Once you have let us know your position, we
can determine next steps. As we discussed on our call, given that the Court advised at the last Rule 14 conference that we needed
to brief issues relating to privilege, we believe that the Court will also view the issues raised in our March 1 letter as purely legal
ones that will unquestionably need to be briefed.
Regarding your request relating to Mr. Schwartzman’s deposition, we believe that he has information relevant to this lawsuit. We
are unaware of any additional disclosure requirements beyond what has already been provided.
Hope you have a good weekend.
Best,
Scott
Scott Parker
NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
Direct: +1 908.333.6220 | Main: +1 212.596.7037
www.piblaw.com
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1167 RECEIVED NYSCEF: 01/31/2023
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use,
disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original
message.
From: Topping, Sean
Sent: Monday, April 25, 2022 7:05 PM
To: Scott Parker ; Sanjay Ibrahim ; Younger, Stephen P.
; Michele Kahn
Cc: Archer, Judith A. ; Corder, Victoria ;
Ward, Luke
Subject: [EXTERNAL] Re: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713]
Scott,
We had two questions following on our earlier conversation re Tekiner discovery issues.
In order to set a reasonable briefing schedule for the discovery motions, can you confirm what topics raised in Plaintiff’s
Rule 14 letters you intend on briefing? Based upon our earlier conversations and email exchange, we assumed it was
going to be limited to issues raised in Plaintiff’s November 11, 2021 letter (not Plaintiff’s July 30, 2021 or February 18,
2022 letters).
As for Schwartzman’s deposition, in a final effort to avoid motion practice, can you identify the topics you will question
him on at his deposition? In our discussions and email exchanges with Plaintiff’s former counsel, we repeatedly asked
Plaintiff to identify the relevant topics for Schwartzman, but were never given straightforward answers. As you know, it
is our understanding he does not possess any relevant firsthand knowledge pertinent to this litigation.
Best,
Sean
From: Scott Parker
Sent: Monday, April 25, 2022 12:37 PM
To: Archer, Judith A. ; Corder, Victoria ;
Michele Kahn
Cc: Sanjay Ibrahim ; Younger, Stephen P.
Subject: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713]
[External Email – Use Caution]
Judi, Victoria, and Michele, per the court’s April 18 order, attached is a proposed revised discovery schedule for submission to the
court. Would you please let us know if you have any comments? Best, Scott
Scott Parker
NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
Direct: +1 908.333.6220 | Main: +1 212.596.7037
www.piblaw.com
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1167 RECEIVED NYSCEF: 01/31/2023
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use,
disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original
message.
Sean Topping | Senior Associate
Norton Rose Fulbright US LLP
1301 Avenue of the Americas, New York, New York 10019-6022, United States
Tel +1 212 318 3361 | Fax +1 212 318 3400
sean.topping@nortonrosefulbright.com
NORTON ROSE FULBRIGHT
Law around the world
nortonrosefulbright.com
CONFIDENTIALITY NOTICE: This email, including any attachments, is confidential and may be privileged. If you are not the
intended recipient please notify the sender immediately, and please delete it; you should not copy it or use it for any purpose or
disclose its contents to any other person. Norton Rose Fulbright entities reserve the right to monitor all email communications
through their networks.
Norton Rose Fulbright Australia, Norton Rose Fulbright LLP, Norton Rose Fulbright Canada LLP, Norton Rose Fulbright South Africa
Inc and Norton Rose Fulbright US LLP are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a
Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members but does not itself provide legal services
to clients. Details of each entity, with certain regulatory information, are available at nortonrosefulbright.com.
Preview
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1167 RECEIVED NYSCEF: 01/31/2023 EXHIBIT 35 FILED: NEWSean[sean.topping@nortonrosefulbright.com]; YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 To: Topping, Sanjay Ibrahim[Sanjay.Ibrahim@piblaw.com]; Younger, Stephen P.[spyounger@foleyhoag.com]; NYSCEF DOC. NO. 1167 Michele Kahn[mk@kahngoldberg.com] RECEIVED NYSCEF: 01/31/2023 Cc: Archer, Judith A.[judith.archer@nortonrosefulbright.com]; Corder, Victoria[victoria.corder@nortonrosefulbright.com]; Ward, Luke[luke.ward@nortonrosefulbright.com] From: Scott Parker[Scott.Parker@piblaw.com] Sent: Wed 5/18/2022 10:34:33 PM (UTC) Subject: RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713] Sean, we are fine with a June 6 motion exchange date, and a normal briefing schedule thereafter. But we do not agree to a 7,000 word limit, given the scope of the issues involved. We intend to ask the Court to expand the word limit to 14,000 per side, with oppositions of the same limit, and replies of 8,400 words. Thanks, Scott Scott Parker NJ Office: 270 Davidson Avenue, Somerset, NJ 08873 NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001 Direct: +1 908.333.6220 | Main: +1 212.596.7037 www.piblaw.com Confidentiality: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original message. From: Topping, Sean Sent: Wednesday, May 18, 2022 5:12 PM To: Scott Parker ; Sanjay Ibrahim ; Younger, Stephen P. ; Michele Kahn Cc: Archer, Judith A. ; Corder, Victoria ; Ward, Luke Subject: [EXTERNAL] RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713] Scott, Given that we did not receive confirmation on the below from Plaintiffs, we propose filing our respective discovery motions on June 6 and that each side will file an omnibus motion of 7000 words max for the issues listed below, with oppositions of the same length, and replies of 4200 words that will follow the normal briefing schedule. Please confirm your agreement. Best, Sean Sean Topping | Senior Associate Norton Rose Fulbright US LLP 1301 Avenue of the Americas, New York, New York 10019-6022, United States Tel +1 212 318 3361 | Fax +1 212 318 3400 sean.topping@nortonrosefulbright.com NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com From: Topping, Sean FILED: NEW INDEX NO. 657193/2020 Sent: Thursday, May YORK 12, 2022 COUNTY 11:47 AM CLERK 01/31/2023 03:42 AM To: 'ScottDOC. NYSCEF Parker'NO. ; 1167 'Sanjay Ibrahim' ;RECEIVED 'Younger, Stephen NYSCEF: P.' 01/31/2023 ; 'Michele Kahn' Cc: Archer, Judith A. ; Corder, Victoria ; Ward, Luke Subject: RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713] Scott, I’m following up on briefing on the Rule 14 letters. Following the Court’s instruction to proceed with briefing on your March 1, 2022 Rule 14 letter, we assume the parties will brief on the following topics: Plaintiff • Issues raised re Defendants’ privilege log (from Plaintiff’s November 11, 2021 letter) • Issues raised re Defendants’ mental health and purported substance use (in Plaintiff’s March 1, 2022 letter) Defendants • Plaintiff’s privilege log entries including Lisa Rubin (from Defendants’ September 16, 2021 letter) • Paul Schwartzman subpoena (served June 25, 2021, addressed in Defendants’ June 20, 2021 letter) We do not think any of the issues are particularly complicated and believe they could be argued succinctly within the normal word limits (7000 words for moving brief, 7000 words for opposition, 4200 for reply). Please let us know if you agree. Also, do you still want to set May 23rd as the date for initial briefing? If so, we would ask that the opposition due date be extended for both motions until June 3rd, replies due June 9th, and the return date sent for June 10th. Alternatively, we are fine with setting the initial briefing due date for after the Memorial Day holiday (perhaps in early June) and following a traditional 16-day return date/briefing schedule. Let us know. Best, Sean Sean Topping | Senior Associate Norton Rose Fulbright US LLP 1301 Avenue of the Americas, New York, New York 10019-6022, United States Tel +1 212 318 3361 | Fax +1 212 318 3400 sean.topping@nortonrosefulbright.com NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com From: Topping, Sean Sent: Wednesday, May 4, 2022 5:01 PM To: Scott Parker ; Sanjay Ibrahim ; Younger, Stephen P. ; Michele Kahn Cc: Archer, Judith A. ; Corder, Victoria ; Ward, Luke Subject: RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713] Scott, In response to your questions: • Defendants do not agree to provide a certification concerning the “Sami Tekiner will, trust, or other operative legal document that confer rights on Plaintiff.” We have represented that there are not any other documents responsive to that request to produce. Defendants also understand their duty to supplement if the need arises. • The parties submitted their Rule 14 letters regarding the issues raised in your March 1, 2022 letter and the Court has not FILED: INDEX NO. 657193/2020 acted orNEW YORK addressed COUNTY the letter. CLERK We believe that in01/31/2023 order to comply with 03:42 AM the Commercial Division rules we should wait for the NYSCEF Court to address DOC. NO. the letter. 1167 RECEIVED NYSCEF: 01/31/2023 • Based on your response re Mr. Schwartzman’s deposition, we understand that Plaintiff is unwilling to narrow the topics included in her subpoena. Accordingly, Defendants will address the Schwartzman subpoena at the appropriate time and fashion. Best, Sean Sean Topping | Senior Associate Norton Rose Fulbright US LLP 1301 Avenue of the Americas, New York, New York 10019-6022, United States Tel +1 212 318 3361 | Fax +1 212 318 3400 sean.topping@nortonrosefulbright.com NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com From: Scott Parker Sent: Friday, April 29, 2022 3:28 PM To: Topping, Sean ; Sanjay Ibrahim ; Younger, Stephen P. ; Michele Kahn Cc: Archer, Judith A. ; Corder, Victoria ; Ward, Luke Subject: RE: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713] Sean, thank you for your e-mail. On our side, you are correct that we intend to brief the issues raised in our November 11, 2021 letter. As for the issues raised in our July 30, 2021 and February 18, 2022 letters, whether we also need to brief those issues depends upon the following (which we ran out of time to raise in our last call with you): are you willing to provide a certification that states that defendants do not possess any additional documents – beyond what has already been produced – that confer a right to Plaintiff in the business, including any Sami Tekiner will, trust, or other operative legal document that confer rights on Plaintiff, including as a contingent beneficiary? While your March 25 e-mail indicates that defendants do not “believe there are any other documents relevant to produce here”, that is different from whether any such documents exist. Additionally, we would also like to brief the issues raised in our March 1, 2022 letter. Whether those issues will be addressed in our initial brief on the (potential) May 23 date, however, depends upon whether you will consent to our jointly writing to the court to advise that we do not believe a Rule 14 conference is necessary as to those issues. Once you have let us know your position, we can determine next steps. As we discussed on our call, given that the Court advised at the last Rule 14 conference that we needed to brief issues relating to privilege, we believe that the Court will also view the issues raised in our March 1 letter as purely legal ones that will unquestionably need to be briefed. Regarding your request relating to Mr. Schwartzman’s deposition, we believe that he has information relevant to this lawsuit. We are unaware of any additional disclosure requirements beyond what has already been provided. Hope you have a good weekend. Best, Scott Scott Parker NJ Office: 270 Davidson Avenue, Somerset, NJ 08873 NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001 Direct: +1 908.333.6220 | Main: +1 212.596.7037 www.piblaw.com FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1167 RECEIVED NYSCEF: 01/31/2023 Confidentiality: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original message. From: Topping, Sean Sent: Monday, April 25, 2022 7:05 PM To: Scott Parker ; Sanjay Ibrahim ; Younger, Stephen P. ; Michele Kahn Cc: Archer, Judith A. ; Corder, Victoria ; Ward, Luke Subject: [EXTERNAL] Re: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713] Scott, We had two questions following on our earlier conversation re Tekiner discovery issues. In order to set a reasonable briefing schedule for the discovery motions, can you confirm what topics raised in Plaintiff’s Rule 14 letters you intend on briefing? Based upon our earlier conversations and email exchange, we assumed it was going to be limited to issues raised in Plaintiff’s November 11, 2021 letter (not Plaintiff’s July 30, 2021 or February 18, 2022 letters). As for Schwartzman’s deposition, in a final effort to avoid motion practice, can you identify the topics you will question him on at his deposition? In our discussions and email exchanges with Plaintiff’s former counsel, we repeatedly asked Plaintiff to identify the relevant topics for Schwartzman, but were never given straightforward answers. As you know, it is our understanding he does not possess any relevant firsthand knowledge pertinent to this litigation. Best, Sean From: Scott Parker Sent: Monday, April 25, 2022 12:37 PM To: Archer, Judith A. ; Corder, Victoria ; Michele Kahn Cc: Sanjay Ibrahim ; Younger, Stephen P. Subject: Tekiner -- proposed revised discovery schedule [PIB-LEGAL_DMS.FID449713] [External Email – Use Caution] Judi, Victoria, and Michele, per the court’s April 18 order, attached is a proposed revised discovery schedule for submission to the court. Would you please let us know if you have any comments? Best, Scott Scott Parker NJ Office: 270 Davidson Avenue, Somerset, NJ 08873 NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001 Direct: +1 908.333.6220 | Main: +1 212.596.7037 www.piblaw.com FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1167 RECEIVED NYSCEF: 01/31/2023 Confidentiality: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original message. Sean Topping | Senior Associate Norton Rose Fulbright US LLP 1301 Avenue of the Americas, New York, New York 10019-6022, United States Tel +1 212 318 3361 | Fax +1 212 318 3400 sean.topping@nortonrosefulbright.com NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com CONFIDENTIALITY NOTICE: This email, including any attachments, is confidential and may be privileged. If you are not the intended recipient please notify the sender immediately, and please delete it; you should not copy it or use it for any purpose or disclose its contents to any other person. Norton Rose Fulbright entities reserve the right to monitor all email communications through their networks. Norton Rose Fulbright Australia, Norton Rose Fulbright LLP, Norton Rose Fulbright Canada LLP, Norton Rose Fulbright South Africa Inc and Norton Rose Fulbright US LLP are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members but does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are available at nortonrosefulbright.com.