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 04:55 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1521 RECEIVED NYSCEF: 02/07/2023
Exhibit A
FILED: WESTCHESTER COUNTY CLERK 02/07/2023 04:55 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1521 RECEIVED NYSCEF: 02/07/2023
MacGillpc
156 E. Market St.
Suite 1200
Indianapolis, IN 46204
www.MacGillLaw.com
Matthew T. Ciulla
317-961-5086
matthew.ciulla@macgilllaw.com
Via Email
December 22, 2022
Jeremy Vest
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Chrysler Center
666 Third A venue
New York NY 10017
RE: Goldstein et al. v. Houlihan Lawrence, Inc.
No. 60767/2018 (N.Y. Sup. Ct., Westchester Cty.)
Dear Counsel:
Please find below a link to Houlihan Lawrence's production of structured data. For
control purposes, we designate today's production HL-STRUCPROD-122222. This production
is HIGHLY CONFIDENTIAL under the protective order.
Today's production consists of certain transactional data from Houlihan Lawrence's ERP
system, Profit Power, and extracts of MLS data from the front-end user interfaces available to
Houlihan Lawrence through the Columbia Greene Northern Dutchess ("CGND"), Mid Hudson
("MH"), and OneKey MLSs. Today's production has been limited as follows: The transaction
was recorded as a residential, closed, sales transaction. The close date was between 1/1/2011 and
7/14/2018 (inclusive). The address of the subject property had a ZIP Code or city name within
Westchester, Putnam or Dutchess counties, per data from the USPS.
The CGND, MH, and OneKey MLS records were identified through the front-end user
interfaces made available to Houlihan Lawrence. The number of records available for export at
one time from each MLS was limited in size. As such the exports were broken into many,
smaller batches and limited upon export to the following criteria:
FILED: WESTCHESTER COUNTY CLERK 02/07/2023 04:55 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1521 RECEIVED NYSCEF: 02/07/2023
Jeremy Vest
December 22, 2022
Page 2
CGND MLS Field MH MLS Field OneKey MLS Field Limitations
1/1/2011-
Date Range Selling Date Sale Date Sold Date
7/14/2018 (inclusive)
Property Type Property Type Property Type Property Type Residential
Status Display
Status Status Status Closed
[Status)
Houlihan Lawrence,
Listing Office Name List Office
Li.st Office List Office Name Coldwell Banker, and
[Office Name] Name
Sothebys
Houlihan Lawrence,
Selling Office
Sell Office Selli ng Office Name Selling Office Name Coldwell Banker, and
Name
Sothebys
To the extent that any of the material today contains privileged information, Houlihan
Lawrence's inadvertent production of that information should not be construed as a waiver, and
Houlihan Lawrence reserves all rights in relation to such an inadvertent production under the
controlling protective order, claw back order, and applicable law. Houlihan Lawrence objects to
any attempt to use today's production to create a class list, to define the class, or to expand the
class.
Best regards.
Matthew T. Ciulla
MacGillpc
Document Filed Date
February 07, 2023
Case Filing Date
July 14, 2018
Category
Commercial Division
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