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 03/15/2023 05:29 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1580 RECEIVED NYSCEF: 03/15/2023
EXHIBIT 3
FILED: WESTCHESTER COUNTY CLERK 03/15/2023 05:29 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1580 RECEIVED NYSCEF: 03/15/2023
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:
We write pursuant to the Twenty-Second Report and Recommendation § 1 (“Section 1”).
A. HL-STRUCPROD-122222 contains, among other things, the structured data
ordinary-course-of-business information responsive to Section 1. Specifically, it
contains the “internal database which is maintained in the ordinary course of HLI’s
business” (for at least the class transactions) referenced on page 3 of the 22d R&R.
B. To the extent the Transaction Detail Sheets are responsive to Section 1, please see our
letter and production of October 6, 2022.
C. To the extent there are paper ordinary-course-of-business transaction files responsive
to Section 1, a reasonable search has returned the records located at HL00181686 to
HL00625416.
We do not have any further information to provide you at this time. We are not obligated
to create documentation that does not exist in the ordinary course of business. We reserve the
right to prepare expert reports, calculations, and analysis based upon HL-STRUCPROD-122222
and any other data or documents, and we will do so in accordance with the expert discovery
schedule.
Best regards.
FILED: WESTCHESTER COUNTY CLERK 03/15/2023 05:29 PM INDEX NO. 60767/2018
NYSCEF DOC. NO. 1580 RECEIVED NYSCEF: 03/15/2023
Jeremy Vest
William Ohlemeyer
February 2, 2023
Page 2
Very truly yours,
Robert D. MacGill
cc: Matthew Ciulla, Alfred Donnellan, Nelida Lara
Document Filed Date
March 15, 2023
Case Filing Date
July 14, 2018
Category
Commercial Division
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