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  • Pamela Goldstein, Ellyn Berk, Tony Berk, Paul Benjamin v. Houlihan/Lawrence Inc.Commercial Division document preview
  • Pamela Goldstein, Ellyn Berk, Tony Berk, Paul Benjamin v. Houlihan/Lawrence Inc.Commercial Division document preview
  • Pamela Goldstein, Ellyn Berk, Tony Berk, Paul Benjamin v. Houlihan/Lawrence Inc.Commercial Division document preview
  • Pamela Goldstein, Ellyn Berk, Tony Berk, Paul Benjamin v. Houlihan/Lawrence Inc.Commercial Division document preview
  • Pamela Goldstein, Ellyn Berk, Tony Berk, Paul Benjamin v. Houlihan/Lawrence Inc.Commercial Division document preview
  • Pamela Goldstein, Ellyn Berk, Tony Berk, Paul Benjamin v. Houlihan/Lawrence Inc.Commercial Division document preview
						
                                

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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