Preview
FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023
Exhibit “H”
FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023
De Santis, Joseph V.
From: tony.harwood@aharwoodlaw.com
Sent: Monday, December 5, 2022 6:46 PM
To: Scott Parker
Cc: Sanjay Ibrahim
Subject: RE: [EXTERNAL] RE: Tekiner
Scott,
You and I seem to have very different understandings of the fee agreements.
Under the First Amendment to the Payment Agreement, all the firms agreed to
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
260 Madison Avenue, 8th 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 INDIVIDUAL OR ENTITY
TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, 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 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
Cc: Sanjay Ibrahim
Subject: RE: [EXTERNAL] RE: Tekiner
Thanks Tony.
For October and going forward, we propose
1
FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023
With respect to September, in accordance with your proposal yesterday afternoon, attached is the draft requisition
form. We are still waiting to hear back from Angelo but this is what the form
would look like. Per your suggestion, we anticipate receiving authorization (between Steve and Angelo) for
Best,
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 may 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: tony.harwood@aharwoodlaw.com
Sent: Monday, December 5, 2022 2:39 PM
To: Scott Parker ; Sanjay Ibrahim
Subject: RE: [EXTERNAL] RE: Tekiner
Scott and Sanjay,
When I last spoke with Scott on the telephone on November 29, he told me he was open to all proposals. I understand
that in the past your firm said it was interested in . For those reasons, I proposed . Since you
have now said your firm would not consider , please make a counterproposal about how to handle the bills
for the period after September.
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
. We 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
260 Madison Avenue, 8th Floor
New York, NY 10016
2
FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023
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 INDIVIDUAL OR ENTITY
TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, 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 212-867-6820 and delete this message from your system.
From: Sanjay Ibrahim
Sent: Friday, December 2, 2022 6:49 PM
To: tony.harwood@aharwoodlaw.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.piblaw.com
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may 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: tony.harwood@aharwoodlaw.com
Date: Friday, Dec 02, 2022 at 6:44 PM
To: Scott Parker
Cc: Sanjay Ibrahim
Subject: [EXTERNAL] RE: Tekiner
Scott,
We had a productive call with . They are open to to cover your September bill, but want to make
sure there is .
Even with a , there will be a shortfall for the September bill. We are working on how big that shortfall is and
how to solve it.
3
FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023
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 that is a win for everyone. Please let me know if you can do that.
Thanks.
Tony
Anthony J. Harwood
Harwood Law PLLC
260 Madison Avenue, 8th 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 INDIVIDUAL OR ENTITY
TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, 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 212-867-6820 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 may 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
4
FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023
To: 'tony.harwood@aharwoodlaw.com'
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
Total PIB budget from October 1, 2022 through trial:
Invoice for October 2022:
Anticipated budget for November 2022 through January 2023: Anticipated activities include:
5
FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023
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.
I spoke with Jasmin and Zeynep today. We are exploring the possibility of to
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.
6
FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023
Tony
Anthony J. Harwood
Harwood Law PLLC
260 Madison Avenue, 8th 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 INDIVIDUAL OR ENTITY
TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, 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 212-867-6820 and delete this message from your system.
7
Preview
FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023 Exhibit “H” FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023 De Santis, Joseph V. From: tony.harwood@aharwoodlaw.com Sent: Monday, December 5, 2022 6:46 PM To: Scott Parker Cc: Sanjay Ibrahim Subject: RE: [EXTERNAL] RE: Tekiner Scott, You and I seem to have very different understandings of the fee agreements. Under the First Amendment to the Payment Agreement, all the firms agreed to 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 260 Madison Avenue, 8th 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 INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, 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 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 Cc: Sanjay Ibrahim Subject: RE: [EXTERNAL] RE: Tekiner Thanks Tony. For October and going forward, we propose 1 FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023 With respect to September, in accordance with your proposal yesterday afternoon, attached is the draft requisition form. We are still waiting to hear back from Angelo but this is what the form would look like. Per your suggestion, we anticipate receiving authorization (between Steve and Angelo) for Best, 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 may 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: tony.harwood@aharwoodlaw.com Sent: Monday, December 5, 2022 2:39 PM To: Scott Parker ; Sanjay Ibrahim Subject: RE: [EXTERNAL] RE: Tekiner Scott and Sanjay, When I last spoke with Scott on the telephone on November 29, he told me he was open to all proposals. I understand that in the past your firm said it was interested in . For those reasons, I proposed . Since you have now said your firm would not consider , please make a counterproposal about how to handle the bills for the period after September. 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 . We 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 260 Madison Avenue, 8th Floor New York, NY 10016 2 FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023 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 INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, 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 212-867-6820 and delete this message from your system. From: Sanjay Ibrahim Sent: Friday, December 2, 2022 6:49 PM To: tony.harwood@aharwoodlaw.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.piblaw.com Confidentiality: This email message is for the sole use of the intended recipient(s) and may 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: tony.harwood@aharwoodlaw.com Date: Friday, Dec 02, 2022 at 6:44 PM To: Scott Parker Cc: Sanjay Ibrahim Subject: [EXTERNAL] RE: Tekiner Scott, We had a productive call with . They are open to to cover your September bill, but want to make sure there is . Even with a , there will be a shortfall for the September bill. We are working on how big that shortfall is and how to solve it. 3 FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023 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 that is a win for everyone. Please let me know if you can do that. Thanks. Tony Anthony J. Harwood Harwood Law PLLC 260 Madison Avenue, 8th 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 INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, 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 212-867-6820 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 may 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 4 FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023 To: 'tony.harwood@aharwoodlaw.com' 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 Total PIB budget from October 1, 2022 through trial: Invoice for October 2022: Anticipated budget for November 2022 through January 2023: Anticipated activities include: 5 FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023 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. I spoke with Jasmin and Zeynep today. We are exploring the possibility of to 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. 6 FILED: NEW YORK COUNTY CLERK 04/10/2023 09:40 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1535 RECEIVED NYSCEF: 04/10/2023 Tony Anthony J. Harwood Harwood Law PLLC 260 Madison Avenue, 8th 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 INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, 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 212-867-6820 and delete this message from your system. 7