Preview
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
EXHIBIT N
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
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CANDACE CARMEL BARASCH, MICHAEL A.
BARACH, and BRADLEY A. CARMEL LIVING Index No. 652380/2023
TRUST,
Plaintiffs,
-against-
LISA SCHIFF, SCHIFF FINE ART LLC, SFA
ADVISORY LLC, and DOES 1-10,
Defendants.
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[PROPOSED] So-Ordered Subpoena
The People of the State of New York
To: David Kordansky Gallery
520 W 20th Street
New York, New York 10011
GREETINGS:
YOU ARE HEREBY COMMANDED to produce at the office of Mazzola Lindstrom, LLP,
1350 Avenue of the Americas, 2nd Floor, New York, New York 10019, on June 23, 2023 (or
such other date to be agreed upon by counsel) at 10:00 AM (or at such other time reasonably
soon thereafter as is mutually agreed to by counsel and by you) the following records:
All documents, records, invoices, information and communications
regarding the proposed, potential, and/or consummated sale of any
and all artwork(s) or other property (a) to Candace Carmel
Barasch, Michael A. Barasch, and/or Bradley A. Carmel Living
Trust; or (b) purported to be purchased by, through, or with Lisa
Schiff, Schiff Fine Art, LLC, and/or SFA Advisory LLC on behalf
of Candace Carmel Barasch, Michael A. Barasch, and/or Bradley
A. Carmel Living Trust. This includes documents, records,
information and communications regarding title to the artworks or
property, and expenses relating to the artworks or property,
including without limitation the sale price, payments, taxes,
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
insurance, crating, packing, transportation and storage of the
artworks or property.
Such information is sought because it is material and necessary in the prosecution of this action
brought by plaintiffs Candace Carmel Barasch, Michael A. Barasch and Bradley A. Carmel
Living Trust to recover monies owed to them by defendants. Upon information and belief, you
are in possession of relevant information.
PLEASE TAKE FURTHER NOTICE that you are subpoenaed by the party whose name
appears on this Subpoena and unless excused from this Subpoena by the party or the Court, you
shall respond to this Subpoena as directed.
PLEASE TAKE FURTHER NOTICE that false swearing or failure to comply with this
Subpoena is punishable as a contempt of court and shall make you liable to the person on whose
behalf this Subpoena was for a penalty not to exceed fifty dollars ($50.00) and all damages
sustained by reason of your failure to comply.
PLEASE TAKE FURTHER NOTICE that the following definitions and instructions shall
apply to this Subpoena:
1. The term “Defendants” refers to any of Lisa Schiff, Schiff Fine Art, LLC, and/or
SFA Advisory LLC (each of whom individually is a “Defendant”), including their agents and
respective directors, officers, employees, subsidiaries, representatives, agents, affiliates,
divisions, licensees, predecessors, successors or assigns, and any other persons or entities acting
or purporting to act on their behalf.
2. The term “Plaintiffs,” refers to Candace Carmel Barasch, Michael A. Barasch,
and/or Bradley A. Carmel Living Trust (each of whom individually is a “Plaintiff”), including
their agents, representatives, and any other persons or entities or purporting to act on their behalf,
unless specified otherwise.
3. The terms “subject property,” and “artwork” as used herein specifically refer to
the artwork entitled RIMS “N” THANGS, 2023, by Lauren Halsey, vinyl, steel tube with
aluminum cladding, custom paint, LED and power supply, 120” x 45” x 30”, and generally refer
to the works identified and facts alleged in the Complaint filed by Plaintiffs in the Supreme
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
Court of the State of New York, New York County, on May 17, 2023, captioned Candace
Carmel Barasch, Michael A. Barasch, and Bradley A. Carmel Living Trust v. Lisa Schiff, Schiff
Fine Art, LLC, SFA Advisory LLC, and Does 1-10, Index Number 652380/2023, and any
amendments thereof (the “Complaint”). The Complaint alleges in relevant part that on May 8,
2023, Defendant Schiff admitted to Plaintiffs that Defendants have used funds which Plaintiffs
provided and entrusted to them for the purchase of artwork on behalf of Plaintiffs, for purposes
other than those for which Plaintiffs entrusted such funds to her. The total amount of funds the
Defendants is believed to have misused exceeds $2.5 million.
4. The terms “Candace,” “Michael,” and “Trust,” refer to plaintiffs Candace Carmel
Barasch, Michael A. Barasch, and Bradley A. Carmel Living Trust, respectively.
5. The terms “Schiff,” “SFA,” and “Schiff Fine Art” refer to Defendants Lisa Schiff,
SFA Advisory LLC and Schiff Fine Art LLC, respectively.
6. Unless otherwise specified, the timeframe referred to in these Demands is January
2020 to the present.
7. The term “person(s)” shall mean a natural person or any business, partnership,
joint venture, corporation, unincorporated association, government, government agency, quasi-
public agency, and any other form of entity.
8. The term “document(s)” shall include physical documents as well as
electronically stored information and includes every form of record, any form of communication
or representation upon any tangible thing, including letters, words, pictures, sounds or symbols,
or combination thereof, such as records of correspondence, reports, memoranda, notes, logs,
financial statements, journal entries, books of account, receipts, and any other writings, whether
recorded by handwriting, printing, or by photographic means, tape, email, website, computer
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
disk, and any other form of data storage compilation, or mechanical or electronic recording.
Every draft or non-identical copy of a “document” is a separate “document” as that term is used
herein.
9. The term “communication(s)” shall mean, without limitation, any act, action, oral
speech, written correspondence, contact, expression of words, thoughts, and/or ideas, or
transmission or exchange of data or other information to another person, whether orally, person-
to-person, in a group, by telephone, letter, personal delivery, facsimile, and/or any other process,
electronic or otherwise.
10. The terms “identify,” “identity,” or “identification,” (a) when used in reference to
an individual person, means that person’s full name, last known address, home and business
telephone numbers, and present occupation or business affiliation; (b) when used in reference to
a person other than an individual person, means that person’s full name, a description of the
nature of the person (that is, whether it is a corporation, partnership, etc. under the definition of
person above), and the person’s last known address, telephone number, and principal place of
business; (c) when used in reference to any person after the person has been properly identified
previously means the person’s name; and (d) when used in reference to a document, requires you
to state the date, the author (or, if different, the signer(s)), the addressee, the identity of the
document’s present custodian, and the type of document (e.g., letter, memorandum, etc.) or to
attach an accurate copy of the document to your answer, appropriate labeled to correspond to the
interrogatory; and (e) when used in reference to a communication, means to identify the mode of
communication (e.g., oral, telephonic, written, electronic, etc.), the date it was made, and the
persons from and to whom it was made.
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
11. The term “describe in detail” means (a) describe fully by reference to underlying
facts rather than by ultimate facts or conclusions of fact or law, (b) state for each such fact the (1)
time, (2) place, and (3) manner of said fact, (c) identify all persons involved, and (d) identify all
documents that support, contradict, refer, relate, or mention such facts.
12. The terms “regarding” “related to” or any variation thereof shall mean referring
to, mentioning, reflecting, containing, pertaining to, evidencing, involving, describing,
discussing, responding to, supporting, opposing, constituting, or being a draft, copy or summary
of, in whole or in part.
13. Words used in the singular shall, where the context permits, include the plural,
and words used in the plural shall, where the context permits, include the singular.
14. Where the words “include or “including” appear, the meaning intended is
“including, but not limited to.” The words “each,” “all,” and “any” mean “any and all” and/or
“each and every.”
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
Instructions
A. Defined Terms. For purposes of this subpoena the definitions of the terms defined
above apply to all uses of such terms in this subpoena, irrespective of whether the initial letter of
a defined term is capitalized when it appears.
B. And/Or. The connectives “and” and “or” shall be construed either disjunctively or
conjunctively as necessary to bring within the scope of each document request all responses that
might otherwise be construed to be outside of its scope.
C. The use of the singular form of any word includes the plural and vice versa.
D. The use of a verb in any tense shall be construed as the use of that verb in all
other tenses, wherever necessary to bring within the scope of each document request all
responses which might otherwise be construed to be outside of its scope.
E. Each request for documents concerning a specified subject matter shall be deemed
to include, without limitation, a request for all documents concerning communications referring
or relating to that subject matter, whether or not expressly set forth in each request.
F. None of the individual document requests set forth below shall be construed with
reference to any other individual request for the purpose of implying a limitation.
G. If you object to producing any document requested, state so in your response to
the particular request, specifying the grounds for your objection in detail. If you object to any
request or part thereof based upon a privilege, or otherwise claim a privilege with respect to any
document, state so in your response to the particular request, identify the nature of the privilege
being asserted (e.g. attorney-client privilege or work product) and provide the following
information in with your response:
i. Each author or maker of the document;
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
ii. Each addressee or recipient of the document and each other person to
whom the document’s content were shown or explained;
iii. The date of the document;
iv. The title or description of the document; the general nature of the subject
matter of the document; and the number of pages;
v. The present location of the document;
vi. Each person who has custody, possession or control of the document; and
vii. Set forth in detail the basis for the claim of privilege.
H. If documents responsive to the following requests have been destroyed, discarded
or otherwise cease to exist, for each such document state:
i. The date of the document;
ii. The author or maker of the document;
iii. The person to whom and from whom the document was sent;
iv. The subject matter of the document;
v. The date on which the document was destroyed, discarded or otherwise
ceased to exist;
vi. The reason for the destruction, discard or nonexistence; and
vii. The person authorizing and/or carrying out said destruction or discard.
I. This request is continuing in nature and requires you promptly to supplement your
production and/or response whenever any other documents or information responsive to this
request enter your possession, custody or control at any time.
Dated: New York, New York
May 24, 2023
Yours, & etc.
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
Mazzola Lindstrom, LLP
By:
Wendy J. Lindstrom
Laura Castner
1350 Avenue of the Americas, 2nd Floor,
New York, New York 10019
646.216.8440
wendy@mazzolalindstrom.com
laura@mazzolalindstrom.com
Attorneys for plaintiffs
So-ordered
_________________________[Date]
J.S.C.
To: All counsel of record (via email)
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023
NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023
Exhibit A
1. All emails, correspondence, documents, videotapes, and any and all other
electronically stored information regarding the artwork entitled, RIMS “N” THANGS, 2023, by
Lauren Halsey, vinyl, steel tube with aluminum cladding, custom paint, LED and power supply,
120” x 45” x 30.”
2. Each agreement or contract entered into with any of the defendants concerning or
relating to the subject artworks.
3. Copies of any and all documents, memorandum, invoices, bills of sale,
consignment agreements, shipment labels, airwaybills, transit bills or courier bills that reflect
that Defendants purchased, shipped, transferred, or sold the subject property from or via David
Kordansky Gallery.
4. Copies of any statements of David Kordansky Gallery concerning the artworks.
5. All emails, correspondence, documents, videotapes, and any and all other
electronically stored information regarding Defendants.
6. All emails, correspondence, documents, videotapes, and any and all other
electronically stored information regarding Plaintiffs.
Preview
FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 EXHIBIT N FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK -------------------------------------------------------------------------x CANDACE CARMEL BARASCH, MICHAEL A. BARACH, and BRADLEY A. CARMEL LIVING Index No. 652380/2023 TRUST, Plaintiffs, -against- LISA SCHIFF, SCHIFF FINE ART LLC, SFA ADVISORY LLC, and DOES 1-10, Defendants. -------------------------------------------------------------------------x [PROPOSED] So-Ordered Subpoena The People of the State of New York To: David Kordansky Gallery 520 W 20th Street New York, New York 10011 GREETINGS: YOU ARE HEREBY COMMANDED to produce at the office of Mazzola Lindstrom, LLP, 1350 Avenue of the Americas, 2nd Floor, New York, New York 10019, on June 23, 2023 (or such other date to be agreed upon by counsel) at 10:00 AM (or at such other time reasonably soon thereafter as is mutually agreed to by counsel and by you) the following records: All documents, records, invoices, information and communications regarding the proposed, potential, and/or consummated sale of any and all artwork(s) or other property (a) to Candace Carmel Barasch, Michael A. Barasch, and/or Bradley A. Carmel Living Trust; or (b) purported to be purchased by, through, or with Lisa Schiff, Schiff Fine Art, LLC, and/or SFA Advisory LLC on behalf of Candace Carmel Barasch, Michael A. Barasch, and/or Bradley A. Carmel Living Trust. This includes documents, records, information and communications regarding title to the artworks or property, and expenses relating to the artworks or property, including without limitation the sale price, payments, taxes, FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 insurance, crating, packing, transportation and storage of the artworks or property. Such information is sought because it is material and necessary in the prosecution of this action brought by plaintiffs Candace Carmel Barasch, Michael A. Barasch and Bradley A. Carmel Living Trust to recover monies owed to them by defendants. Upon information and belief, you are in possession of relevant information. PLEASE TAKE FURTHER NOTICE that you are subpoenaed by the party whose name appears on this Subpoena and unless excused from this Subpoena by the party or the Court, you shall respond to this Subpoena as directed. PLEASE TAKE FURTHER NOTICE that false swearing or failure to comply with this Subpoena is punishable as a contempt of court and shall make you liable to the person on whose behalf this Subpoena was for a penalty not to exceed fifty dollars ($50.00) and all damages sustained by reason of your failure to comply. PLEASE TAKE FURTHER NOTICE that the following definitions and instructions shall apply to this Subpoena: 1. The term “Defendants” refers to any of Lisa Schiff, Schiff Fine Art, LLC, and/or SFA Advisory LLC (each of whom individually is a “Defendant”), including their agents and respective directors, officers, employees, subsidiaries, representatives, agents, affiliates, divisions, licensees, predecessors, successors or assigns, and any other persons or entities acting or purporting to act on their behalf. 2. The term “Plaintiffs,” refers to Candace Carmel Barasch, Michael A. Barasch, and/or Bradley A. Carmel Living Trust (each of whom individually is a “Plaintiff”), including their agents, representatives, and any other persons or entities or purporting to act on their behalf, unless specified otherwise. 3. The terms “subject property,” and “artwork” as used herein specifically refer to the artwork entitled RIMS “N” THANGS, 2023, by Lauren Halsey, vinyl, steel tube with aluminum cladding, custom paint, LED and power supply, 120” x 45” x 30”, and generally refer to the works identified and facts alleged in the Complaint filed by Plaintiffs in the Supreme FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 Court of the State of New York, New York County, on May 17, 2023, captioned Candace Carmel Barasch, Michael A. Barasch, and Bradley A. Carmel Living Trust v. Lisa Schiff, Schiff Fine Art, LLC, SFA Advisory LLC, and Does 1-10, Index Number 652380/2023, and any amendments thereof (the “Complaint”). The Complaint alleges in relevant part that on May 8, 2023, Defendant Schiff admitted to Plaintiffs that Defendants have used funds which Plaintiffs provided and entrusted to them for the purchase of artwork on behalf of Plaintiffs, for purposes other than those for which Plaintiffs entrusted such funds to her. The total amount of funds the Defendants is believed to have misused exceeds $2.5 million. 4. The terms “Candace,” “Michael,” and “Trust,” refer to plaintiffs Candace Carmel Barasch, Michael A. Barasch, and Bradley A. Carmel Living Trust, respectively. 5. The terms “Schiff,” “SFA,” and “Schiff Fine Art” refer to Defendants Lisa Schiff, SFA Advisory LLC and Schiff Fine Art LLC, respectively. 6. Unless otherwise specified, the timeframe referred to in these Demands is January 2020 to the present. 7. The term “person(s)” shall mean a natural person or any business, partnership, joint venture, corporation, unincorporated association, government, government agency, quasi- public agency, and any other form of entity. 8. The term “document(s)” shall include physical documents as well as electronically stored information and includes every form of record, any form of communication or representation upon any tangible thing, including letters, words, pictures, sounds or symbols, or combination thereof, such as records of correspondence, reports, memoranda, notes, logs, financial statements, journal entries, books of account, receipts, and any other writings, whether recorded by handwriting, printing, or by photographic means, tape, email, website, computer FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 disk, and any other form of data storage compilation, or mechanical or electronic recording. Every draft or non-identical copy of a “document” is a separate “document” as that term is used herein. 9. The term “communication(s)” shall mean, without limitation, any act, action, oral speech, written correspondence, contact, expression of words, thoughts, and/or ideas, or transmission or exchange of data or other information to another person, whether orally, person- to-person, in a group, by telephone, letter, personal delivery, facsimile, and/or any other process, electronic or otherwise. 10. The terms “identify,” “identity,” or “identification,” (a) when used in reference to an individual person, means that person’s full name, last known address, home and business telephone numbers, and present occupation or business affiliation; (b) when used in reference to a person other than an individual person, means that person’s full name, a description of the nature of the person (that is, whether it is a corporation, partnership, etc. under the definition of person above), and the person’s last known address, telephone number, and principal place of business; (c) when used in reference to any person after the person has been properly identified previously means the person’s name; and (d) when used in reference to a document, requires you to state the date, the author (or, if different, the signer(s)), the addressee, the identity of the document’s present custodian, and the type of document (e.g., letter, memorandum, etc.) or to attach an accurate copy of the document to your answer, appropriate labeled to correspond to the interrogatory; and (e) when used in reference to a communication, means to identify the mode of communication (e.g., oral, telephonic, written, electronic, etc.), the date it was made, and the persons from and to whom it was made. FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 11. The term “describe in detail” means (a) describe fully by reference to underlying facts rather than by ultimate facts or conclusions of fact or law, (b) state for each such fact the (1) time, (2) place, and (3) manner of said fact, (c) identify all persons involved, and (d) identify all documents that support, contradict, refer, relate, or mention such facts. 12. The terms “regarding” “related to” or any variation thereof shall mean referring to, mentioning, reflecting, containing, pertaining to, evidencing, involving, describing, discussing, responding to, supporting, opposing, constituting, or being a draft, copy or summary of, in whole or in part. 13. Words used in the singular shall, where the context permits, include the plural, and words used in the plural shall, where the context permits, include the singular. 14. Where the words “include or “including” appear, the meaning intended is “including, but not limited to.” The words “each,” “all,” and “any” mean “any and all” and/or “each and every.” FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 Instructions A. Defined Terms. For purposes of this subpoena the definitions of the terms defined above apply to all uses of such terms in this subpoena, irrespective of whether the initial letter of a defined term is capitalized when it appears. B. And/Or. The connectives “and” and “or” shall be construed either disjunctively or conjunctively as necessary to bring within the scope of each document request all responses that might otherwise be construed to be outside of its scope. C. The use of the singular form of any word includes the plural and vice versa. D. The use of a verb in any tense shall be construed as the use of that verb in all other tenses, wherever necessary to bring within the scope of each document request all responses which might otherwise be construed to be outside of its scope. E. Each request for documents concerning a specified subject matter shall be deemed to include, without limitation, a request for all documents concerning communications referring or relating to that subject matter, whether or not expressly set forth in each request. F. None of the individual document requests set forth below shall be construed with reference to any other individual request for the purpose of implying a limitation. G. If you object to producing any document requested, state so in your response to the particular request, specifying the grounds for your objection in detail. If you object to any request or part thereof based upon a privilege, or otherwise claim a privilege with respect to any document, state so in your response to the particular request, identify the nature of the privilege being asserted (e.g. attorney-client privilege or work product) and provide the following information in with your response: i. Each author or maker of the document; FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 ii. Each addressee or recipient of the document and each other person to whom the document’s content were shown or explained; iii. The date of the document; iv. The title or description of the document; the general nature of the subject matter of the document; and the number of pages; v. The present location of the document; vi. Each person who has custody, possession or control of the document; and vii. Set forth in detail the basis for the claim of privilege. H. If documents responsive to the following requests have been destroyed, discarded or otherwise cease to exist, for each such document state: i. The date of the document; ii. The author or maker of the document; iii. The person to whom and from whom the document was sent; iv. The subject matter of the document; v. The date on which the document was destroyed, discarded or otherwise ceased to exist; vi. The reason for the destruction, discard or nonexistence; and vii. The person authorizing and/or carrying out said destruction or discard. I. This request is continuing in nature and requires you promptly to supplement your production and/or response whenever any other documents or information responsive to this request enter your possession, custody or control at any time. Dated: New York, New York May 24, 2023 Yours, & etc. FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 Mazzola Lindstrom, LLP By: Wendy J. Lindstrom Laura Castner 1350 Avenue of the Americas, 2nd Floor, New York, New York 10019 646.216.8440 wendy@mazzolalindstrom.com laura@mazzolalindstrom.com Attorneys for plaintiffs So-ordered _________________________[Date] J.S.C. To: All counsel of record (via email) FILED: NEW YORK COUNTY CLERK 05/31/2023 03:59 PM INDEX NO. 652380/2023 NYSCEF DOC. NO. 19 RECEIVED NYSCEF: 05/31/2023 Exhibit A 1. All emails, correspondence, documents, videotapes, and any and all other electronically stored information regarding the artwork entitled, RIMS “N” THANGS, 2023, by Lauren Halsey, vinyl, steel tube with aluminum cladding, custom paint, LED and power supply, 120” x 45” x 30.” 2. Each agreement or contract entered into with any of the defendants concerning or relating to the subject artworks. 3. Copies of any and all documents, memorandum, invoices, bills of sale, consignment agreements, shipment labels, airwaybills, transit bills or courier bills that reflect that Defendants purchased, shipped, transferred, or sold the subject property from or via David Kordansky Gallery. 4. Copies of any statements of David Kordansky Gallery concerning the artworks. 5. All emails, correspondence, documents, videotapes, and any and all other electronically stored information regarding Defendants. 6. All emails, correspondence, documents, videotapes, and any and all other electronically stored information regarding Plaintiffs.