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 02/07/2023 01:50 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1519 RECEIVED NYSCEF: 02/07/2023
EXHIBIT A
FILED: WESTCHESTER COUNTY CLERK 02/07/2023 01:50 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1519 RECEIVED NYSCEF: 02/07/2023
156 E. Market Street
Suite 1200
Indianapolis, IN 46204
www.MacGillLaw.com
Robert D. MacGill
317.906.5085
Robert.MacGill@MacGillLaw.com
Via Email
February 2, 2023
Jeremy Vest
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Chrysler Center
666 Third Avenue
New York NY 10017
William Ohlemeyer
Boies Schiller Flexner LLP
333 Main Street
Armonk, NY 10504
RE: Goldstein et al. v. Houlihan Lawrence, Inc.
No. 60767/2018 (N.Y. Sup. Ct., Westchester Cty.)
Dear Counsel:
Wewritepursuant to theTwenty-Second Report and Recommendation § 1 (“Section 1”).
A. HL-STRUCPROD-122222
HL contains, among other things, thestructured data
ordinary-course-of
of-business information responsiveto Section 1. Specifically, it
contains the“internal databasewhich is maintained in theordinary courseof HLI’s
business” (for at least theclass transactions) referenced on page3 of the22d R&R.
B. To theextent theTransaction Detail Sheets areresponsiveto Section 1, pleaseseeour
letter and production of October 6, 2022.
C. To theextent therearepaper ordinary-course-of of-business transaction files responsive
to Section 1, a reasonablesearch has returned therecords located at HL00181686 to
HL00625416.
Wedo not haveany further information to provideyou at this time. Wearenot obligated
to createdocumentation that does not exist in theordinary courseof business. Wereservethe
right to prepareexpert reports, calculations, and analysis based upon HL
HL-STRUCPROD-122222
and any other data or documents, and wewill do so in accordancewith theexpert discovery
schedule.
Best regards.
FILED: WESTCHESTER COUNTY CLERK 02/07/2023 01:50 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1519 RECEIVED NYSCEF: 02/07/2023
Jeremy Vest
William Ohlemeyer
February 2, 2023
Page2
Very truly yours,
Robert D. MacGill
cc: Matthew Ciulla, Alfred Donnellan, Nelida Lara
Document Filed Date
February 07, 2023
Case Filing Date
July 14, 2018
Category
Commercial Division
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