Preview
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023
E X HI BI T 9
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023
Fram: inny.@mrwneddhaharwnerkrwsom
To: Scott Parker
Cu: Sanjay Erdshn
Subjed: RE: [EXTERNAL] RE: Tekkier
Date: Mauhry, Deernber 5, 2D22 Eie45:00PM
Attadimersts: knaneRD1.rmÀ
Scott,
You and I seem to have very different understandings of the fee agreements.
Under the First Amendment to the Payment Agreement, all the firrns agreed to
Our
It seem that you have a different interpretation, under which your firm can bill
Please point us to the language in the agreements
that supports your interpretation.
Thanks.
Anthony J. Harwood
Harwood Law PLLC
8th
260 Madison Avenue, Floor
New York, NY 10016
Tel.: 212-867-6820
Fax: 212-937-3167
email: Tony.Harwood@aharwondlaw.com
CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE
INDMDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS
PRMLEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPUCABLE LAW. If the reader
of this transmission is NOT the intended recipient, or the employee or agent responsible to deliver it
to the intended recipient, you are hereby notified that any dissemination, distribution or copying of
this communication is strictly prohibited. If you have received this communication in error, please
notify Anthony Harwood immediately by telephone at 212-867-6820 and delete this message from
your system.
From: Scott Parker
Sent: Monday, December 5, 2022 4:57 PM
To: tony.harwood@aharwoodlaw.com
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023
C c: S a n j a y I b r a hi m < S a nj a y.l br a hi m @ pi bl a w. c o m >
S u bj e c t: R E: [ E X T E R N A L] R E: T e ki n e r
T h a n k s T o n y.
F or O c t o b e r a n d g oi n g f o rw a r d, w e p r o p o s e
Wit h r e s p e c t t o S e pt e m b er, i n a c c or d a n c e wi t h y o u r p r o p o s al y e s t e r d a y aft e r n o o n, att a c h e d i s t h e
d r aft r e q ui si ti o n f or m. W e ar e still w ai ti n g t o h e ar b a c k fr o m A n g el o f or
, b u t t hi s i s w h a t t h e f o r m w o ul d l o o k li k e. P er y o u r s u g g e s ti o n, w e a n ti ci p a t e r e c ei vi n g
i
a u t h o ri z a t o n ( b et w e e n St e v e a n d A n g el o)
B e s t,
S c ott
S c o tt P a r k e r
NJ Offi c e: 2 7 0 D a vi d s o n A v e n u e, S o m er s et, NJ 0 8 8 7 3
N Y Offi c e: 5 P e n n Pl a z a, S uit e 2 3 7 1, N e w Y or k, N Y 1 000 1
Dir e ct: + 1 9 0 8. 3 3 3. 6 2 2 0 I M ai n: + 1 2 1 2. 5 9 6. 7 0 3 7
w w w. pi bl a w. c o m
T hi s e m ail m e s s a g e i s f or t h e s ol e u s e of t h e i nt e n d e d r e ci pi e nt(s) a n d m a y c o nt ai n c o n fi d e nti al a n d pri vil e g e d i nf or m ati o n.
A n y u n a ut h o ri z e d r e vi e w, u s e, dis cl o s ur e o r di stri b uti o n i s stri ctl y pr o hi bit e d. If y o u ar e n ot t h e i nt e n d e d r e ci pi e nt, c o nt a ct
t h e s e n d er vi a r e pl y e m ail a n d d estr o y all c o pi es of t h e o ri gi n al m ess a g e.
F r o m: t o n y b a rw o o d @ a b a rw o o dl a w c o m
Se nt: M o n d a y, D e c e m b er 5, 2 0 2 2 2: 3 9 P M
T o: S c ott P a r k e r < S c o tt. P a r k e r @ pi bl a w. o o m >; S a nj a y I b r a hi m < S a nj a y.l b r a hi m @ pi bl a w. c o m >
S u bj e c t: R E: [ E X T E R N A L] R E: T e ki n e r
S c o tt a n d S a nj a y,
When I l a s t s p o k e wi t h S co tt o n t h e t el e p h o n e o n N o v e m b e r 2 9, h e t ol d m e h e w a s o p e n t o all
p r o p o s al s. I u n d e r s t a n d t h at i n t h e p a s t y o ur fi r m s ai d i t w a s i nt er e st e d i n
. Si n c e y o u h a v e n o w s ai d y o ur fi r m w o ul d n ot c o n si d e r
pl e a s e m a k e a c o u nt er pr o p o s al a b o u t h o w t o h a n dl e t h e bill s f o r t h e p eri o d aft e r
S e pt e m b er.
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023
As for the September bill, I left a voice mail for Scott on Sunday afternoon. In that voice mail I stated
that if we have written authorizations from all attorneys
are waiting for your response to this and for the written authorizations so that we can inform
how to direct payment.
Thanks.
Tony
Anthony J. Harwood
Harwood Law PLLC
88
260 Madison Avenue, Floor
New York, NY 10016
Tel.: 212-867-6820
Fax: 212-937-3167
email: Tony.Harwood@aharwoodlaw.com
CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE
INDMDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS
PRMLEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPUCABLE LAW. If the reader
of this transmission is NOT the intended recipient, or the employee or agent responsible to deliver it
to the intended recipient, you are hereby notified that any dissemination, distribution or copying of
this communication is strictly prohibited. If you have received this communication in error, please
notify Anthony Harwood immediately by telephone at 212-867-6820 and delete this message from
your system.
From: Sanjay Ibrahim
Sent: Friday, December 2, 2022 6:49 PM
To: inny.harwondeaharwoodlaw.com; Scott Parker
Subject: RE: [EXTERNAL] RE: Tekiner
Tony please give me a call but we will not do Regards, Jay
Sanjay Ibrahim
NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
Direct: +1 908.333.6210 | Main: +1 212.596.7037
www.piMaw.com
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023
Confidentiality:
This email message is for the sole use of the intended recipient(s] and inay 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.
Frorn: >
Date: Friday, Dec O2, 2022 at 644 PM
To: Scott Parker
cc: Sanjay Ibrahirn
Sabject: [EXTERNAL] RE: Tekiner
Scott,
We had a productive call with They are open to to cover your September bill,
but want to rnake sure there is
Even with here will be a shortfall for the September bill. We are working on how big
that shortfall is and how to solve it.
The bigger problem is how to deal with legal expense going forward in a way that works for
everyone. We would like to move forward on that by exploring for everything
after the September bill. I think it would help if you would propose hat is a
win for everyone. Please let me know if you can do that.
Thanks.
Tony
Anthony J. Harwood
Harwood Law PLLC
8th
260 Madison Avenue, FlSr
New York, NY 10016
Tel.: 212-867-6820
Fax: 212-937-3167
email: Tony.Harwood@aharwondlaw.com
CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE
INDMDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023
PRMLEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader
of this transmission is NOT the intended recipient, or the employee or agent responsible to deliver it
to the intended recipient, you are hereby notified that any dissemination, distribution or copying of
this communication is strictly prohibited. If you have received this communication in error, please
notify Anthony Harwood immediately by telephone at 712-867-6870 and delete this message from
your system.
From: Scott Parker
Sent: Friday, December 2, 2022 4:38 PM
To: tony.harwood@aharwoodlaw.com
Cc: Sanjay Ibrahim
Subject: RE: Tekiner
Tony, we just wanted to circle back on this. 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 inay 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: Scott Parker
Sent: Wednesday, November 30, 2022 11:25 PM
'tony.harwood@aharwoodlaw.com'
To:
Cc: Sanjay Ibrahim
Subject: RE: Tekiner
Thanks Tony, and I completely agree with your assessment. Happy to provide the following budget,
with the caveat that this does not account for things for which we have no line of sight (e.g.,
additional motions or orders to show cause that we cannot anticipate - for
example,
Also, would you please include Jay on correspondence on these
issues going forward; I've cc'd him here. Best, Scott
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023
Irwoice for October 2022:
e
e
Anticipated budget for November 2022 through January 2023: nticipated activities
indude:
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023
ly withheld privileged documents;
r as trustee of Jasrni
From: tony.harwood@aharwoodlaw.com
Sent: Wednesday, November 30, 2022 4:57 PM
To: Scott Parker
Subject: [EXTERNAL] Tekiner
Scott,
It was good talking with you last night. I thought the call was productive.
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023
I spoke with Jasmin and Zeynep today. We are exploring the possibility of
a pay your bill for September. We will be back to you about that after we
gather some more information and speak with
We want to talk about how to deal with the cost of the case going forward as well. It would help us
if you would give us a detailed, task based budget and timeline for taking the case through trial.
Please let me know if you can do that.
Thanks.
Tony
Anthony J. Harwood
Harwood Law PLLC
8th
260 Madison Avenue, Floor
New York, NY 10016
Tel.: 212-867-6820
Fax: 212-937-3167
email: Tony.Harwood@aharwondlaw.com
CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE
INDMDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS
PRMLEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPUCABLE LAW. If the reader
of this transmission is NOT the intended recipient, or the employee or agent responsible to deliver it
to the intended recipient, you are hereby notified that any dissemination, distribution or copying of
this communication is strictly prohibited. If you have received this communication in error, please
notify Anthony Harwood immediately by telephone at 212-867-6820 and delete this message from
your system.
Preview
FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023 E X HI BI T 9 FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023 Fram: inny.@mrwneddhaharwnerkrwsom To: Scott Parker Cu: Sanjay Erdshn Subjed: RE: [EXTERNAL] RE: Tekkier Date: Mauhry, Deernber 5, 2D22 Eie45:00PM Attadimersts: knaneRD1.rmÀ Scott, You and I seem to have very different understandings of the fee agreements. Under the First Amendment to the Payment Agreement, all the firrns agreed to Our It seem that you have a different interpretation, under which your firm can bill Please point us to the language in the agreements that supports your interpretation. Thanks. Anthony J. Harwood Harwood Law PLLC 8th 260 Madison Avenue, Floor New York, NY 10016 Tel.: 212-867-6820 Fax: 212-937-3167 email: Tony.Harwood@aharwondlaw.com CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE INDMDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRMLEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPUCABLE LAW. If the reader of this transmission is NOT the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Anthony Harwood immediately by telephone at 212-867-6820 and delete this message from your system. From: Scott Parker Sent: Monday, December 5, 2022 4:57 PM To: tony.harwood@aharwoodlaw.com FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023 C c: S a n j a y I b r a hi m < S a nj a y.l br a hi m @ pi bl a w. c o m > S u bj e c t: R E: [ E X T E R N A L] R E: T e ki n e r T h a n k s T o n y. F or O c t o b e r a n d g oi n g f o rw a r d, w e p r o p o s e Wit h r e s p e c t t o S e pt e m b er, i n a c c or d a n c e wi t h y o u r p r o p o s al y e s t e r d a y aft e r n o o n, att a c h e d i s t h e d r aft r e q ui si ti o n f or m. W e ar e still w ai ti n g t o h e ar b a c k fr o m A n g el o f or , b u t t hi s i s w h a t t h e f o r m w o ul d l o o k li k e. P er y o u r s u g g e s ti o n, w e a n ti ci p a t e r e c ei vi n g i a u t h o ri z a t o n ( b et w e e n St e v e a n d A n g el o) B e s t, S c ott S c o tt P a r k e r NJ Offi c e: 2 7 0 D a vi d s o n A v e n u e, S o m er s et, NJ 0 8 8 7 3 N Y Offi c e: 5 P e n n Pl a z a, S uit e 2 3 7 1, N e w Y or k, N Y 1 000 1 Dir e ct: + 1 9 0 8. 3 3 3. 6 2 2 0 I M ai n: + 1 2 1 2. 5 9 6. 7 0 3 7 w w w. pi bl a w. c o m T hi s e m ail m e s s a g e i s f or t h e s ol e u s e of t h e i nt e n d e d r e ci pi e nt(s) a n d m a y c o nt ai n c o n fi d e nti al a n d pri vil e g e d i nf or m ati o n. A n y u n a ut h o ri z e d r e vi e w, u s e, dis cl o s ur e o r di stri b uti o n i s stri ctl y pr o hi bit e d. If y o u ar e n ot t h e i nt e n d e d r e ci pi e nt, c o nt a ct t h e s e n d er vi a r e pl y e m ail a n d d estr o y all c o pi es of t h e o ri gi n al m ess a g e. F r o m: t o n y b a rw o o d @ a b a rw o o dl a w c o m Se nt: M o n d a y, D e c e m b er 5, 2 0 2 2 2: 3 9 P M T o: S c ott P a r k e r < S c o tt. P a r k e r @ pi bl a w. o o m >; S a nj a y I b r a hi m < S a nj a y.l b r a hi m @ pi bl a w. c o m > S u bj e c t: R E: [ E X T E R N A L] R E: T e ki n e r S c o tt a n d S a nj a y, When I l a s t s p o k e wi t h S co tt o n t h e t el e p h o n e o n N o v e m b e r 2 9, h e t ol d m e h e w a s o p e n t o all p r o p o s al s. I u n d e r s t a n d t h at i n t h e p a s t y o ur fi r m s ai d i t w a s i nt er e st e d i n . Si n c e y o u h a v e n o w s ai d y o ur fi r m w o ul d n ot c o n si d e r pl e a s e m a k e a c o u nt er pr o p o s al a b o u t h o w t o h a n dl e t h e bill s f o r t h e p eri o d aft e r S e pt e m b er. FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023 As for the September bill, I left a voice mail for Scott on Sunday afternoon. In that voice mail I stated that if we have written authorizations from all attorneys are waiting for your response to this and for the written authorizations so that we can inform how to direct payment. Thanks. Tony Anthony J. Harwood Harwood Law PLLC 88 260 Madison Avenue, Floor New York, NY 10016 Tel.: 212-867-6820 Fax: 212-937-3167 email: Tony.Harwood@aharwoodlaw.com CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE INDMDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRMLEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPUCABLE LAW. If the reader of this transmission is NOT the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Anthony Harwood immediately by telephone at 212-867-6820 and delete this message from your system. From: Sanjay Ibrahim Sent: Friday, December 2, 2022 6:49 PM To: inny.harwondeaharwoodlaw.com; Scott Parker Subject: RE: [EXTERNAL] RE: Tekiner Tony please give me a call but we will not do Regards, Jay Sanjay Ibrahim NJ Office: 270 Davidson Avenue, Somerset, NJ 08873 NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001 Direct: +1 908.333.6210 | Main: +1 212.596.7037 www.piMaw.com FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023 Confidentiality: This email message is for the sole use of the intended recipient(s] and inay 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. Frorn: > Date: Friday, Dec O2, 2022 at 644 PM To: Scott Parker cc: Sanjay Ibrahirn Sabject: [EXTERNAL] RE: Tekiner Scott, We had a productive call with They are open to to cover your September bill, but want to rnake sure there is Even with here will be a shortfall for the September bill. We are working on how big that shortfall is and how to solve it. The bigger problem is how to deal with legal expense going forward in a way that works for everyone. We would like to move forward on that by exploring for everything after the September bill. I think it would help if you would propose hat is a win for everyone. Please let me know if you can do that. Thanks. Tony Anthony J. Harwood Harwood Law PLLC 8th 260 Madison Avenue, FlSr New York, NY 10016 Tel.: 212-867-6820 Fax: 212-937-3167 email: Tony.Harwood@aharwondlaw.com CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE INDMDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023 PRMLEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this transmission is NOT the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Anthony Harwood immediately by telephone at 712-867-6870 and delete this message from your system. From: Scott Parker Sent: Friday, December 2, 2022 4:38 PM To: tony.harwood@aharwoodlaw.com Cc: Sanjay Ibrahim Subject: RE: Tekiner Tony, we just wanted to circle back on this. 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 inay 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: Scott Parker Sent: Wednesday, November 30, 2022 11:25 PM 'tony.harwood@aharwoodlaw.com' To: Cc: Sanjay Ibrahim Subject: RE: Tekiner Thanks Tony, and I completely agree with your assessment. Happy to provide the following budget, with the caveat that this does not account for things for which we have no line of sight (e.g., additional motions or orders to show cause that we cannot anticipate - for example, Also, would you please include Jay on correspondence on these issues going forward; I've cc'd him here. Best, Scott FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023 Irwoice for October 2022: e e Anticipated budget for November 2022 through January 2023: nticipated activities indude: FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023 ly withheld privileged documents; r as trustee of Jasrni From: tony.harwood@aharwoodlaw.com Sent: Wednesday, November 30, 2022 4:57 PM To: Scott Parker Subject: [EXTERNAL] Tekiner Scott, It was good talking with you last night. I thought the call was productive. FILED: NEW YORK COUNTY CLERK 02/17/2023 12:47 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1306 RECEIVED NYSCEF: 02/17/2023 I spoke with Jasmin and Zeynep today. We are exploring the possibility of a pay your bill for September. We will be back to you about that after we gather some more information and speak with We want to talk about how to deal with the cost of the case going forward as well. It would help us if you would give us a detailed, task based budget and timeline for taking the case through trial. Please let me know if you can do that. Thanks. Tony Anthony J. Harwood Harwood Law PLLC 8th 260 Madison Avenue, Floor New York, NY 10016 Tel.: 212-867-6820 Fax: 212-937-3167 email: Tony.Harwood@aharwondlaw.com CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE INDMDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRMLEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPUCABLE LAW. If the reader of this transmission is NOT the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Anthony Harwood immediately by telephone at 212-867-6820 and delete this message from your system.