Preview
FILED: NEW YORK COUNTY CLERK 12/26/2023 12:19 PM INDEX NO. 655672/2023
NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/26/2023
"A"
Exhibit
FILED: NEW YORK COUNTY CLERK 12/26/2023 12:19 PM INDEX NO. 655672/2023
NYSCEF NO . 5 1 O0
INDEX NYSCEF: 0 9 / 2 O2 3
FILED DOC.
:
NO. 16
NEW YORK COUNTY CLERK 08 /30 /2023 12 : 37 PM)
RECEIVED 12/26/2023
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 08/30/2023
Douq Pick
From: Doug Pick
Sent: Friday, August 4, 2023 1:46 PM
To: John
Cc: Eric C. Zabicki; Phoebe Williams; Jack Mur; Elizabeth von Habsburg
Subject.
FW: Questions on Some Artworks
Attachments: WAG Missing or Unlisted Artworks.xisx
Dear Mr Cahill,
Attached is a schedule of artwork that we are unable to locate and to which Ms Schiff has
not responded to. In order to avoid our a motion with the court to address our need for
filing
Ms Schiff to respond to whereabouts of the missing/unaccounted inventory we would request
that you immediately reach out to Ms Schiff and obtain answers for us. Obviously Ms Schiff
can speak to Winston Art to address the missing inventory. Thank you Doug
directly Group
Pick
Douglas J. Pick I Partner
PICK & ZABICKI LLP
369 Lexington Avenue, 12th Floor, New York, NY 10017
PICK & ZABICKI (212) 695-6000 Ext. 223 I dpick@picklaw.net
L L P www.picklaw.net
From: Phoebe Williams
Sent: Friday, August 4, 2023 1:38 PM
To: Lisa Schiff ; Doug Pick ; John
Cc: Elizabeth von Habsburg ; Jack Mur
Subject: RE: Questions on Some Artworks
Dear all,
I sent the below 24th
message to Lisa on the requesting her help identifying some missing works, and haven't received a
- I am John and here in case I have the wrong email address and to hopefully move things along. I
reply including Doug
have added further details to the spreadsheet of missing/unlisted items to specify what information exactly is needed
for each work, and why each work is on this list.
Notes"
The rightmost column on each tab, titled "Additional , will specify why the WAG team has been unable to locate
Works" works"
the piece. The first two tabs, titled "Missing and "SFA missing are works that have not been found by
WA.G., because no information was provided, or incorrect information was provided.
- Whose These"
The third tab, titled "Unlisted Are are artworks that we identified on the lists provided by UOVo and
DAX as under SFA's storage accounts , but were not on the comprehensive inventory list provided a number of weeks
ago titled ""Compressed Final SFA Inventory June 2023". For the works on this tab, we can assume they are at the
storage location listed, but we need images and any other relevant details on the artworks.
FILED: NEW YORK COUNTY CLERK 12/26/2023 12:19 PM INDEX NO. 655672/2023
NYSCEF DOC. NO. 16 RECEIVED NO. 510009/2023
INDEX NYSCEF: 12/26/2023
FILED : NEW YORK COUNTY CLERK 08/30/2023 12: 37 Ply$
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 08 /30/2023
As you will see, there are hundreds of items that are not properly accounted for, and in order to move forward, we need
Information on all of these pieces includinçr images. exact location. and any associate sale documents/provenance. The
cumulative value of all of these unaccounted for pieces is not insignificant, and it is important that we receive as many
details as possible on each one. Please let me know If this sheet is unclear in any way or if I can answer any questions.
Sincerely,
Phoebe
Phoebe Williams
Associate
Winston Art Group
Tower 56
126 East 56th Street, 24th FlOOr
NewYork, NY 10022
Email: williams@winstonartaroup.com
C: 646-512-1824
www.winstonartgroup.com
From: Phoebe Williams
Sent: Monday, July 24, 2023 10:26 AM
To: Lisa Schiff
Cc: Elizabeth von Habsburg ; Jack Mur
Subject: Questions on Some Artworks
Hi Lisa,
I'm reaching out because l've been trying to reconcile all of the inventory we've come across so far. There some works
that Ineed more information on, so I consolidated all of them onto one sheet to ask for your help on.
This spreadsheet shows works that were found by putting together by combining the inventory lists you provided, as
well as UOVO's list, DAX's list, and our own lists from cataloguing everything ourselves at 56 Leonard and 45 White, A
few questions:
1. There were many works on DAX's and UOVO's lists that did not appear on any of the lists you sent over-I
would like to verify whether these are SFA, or if they
belong to anyone else (or are yours personally)
- Whose These"
a. These are found on the first tab titled "Unlisted Are
2. "Missing"
There are also works that you marked as on the SFA General inventory PDF John sent us a couple
Works"
weeks ago (which was very helpfull) -these are on the tab called "5FA Missing
3. I added all of the works from your personal lists, consignment lists, and to be returned lists -any works that did
"Missing"
not have a location , I listed as . I know they might not actually be missing, but if you could note where
they are, that would be a great help.
I know this is a lot , so if it's easier to go through this on a phone call or if you would prefer to make edits yourself and
send it back to me, just let me knowl I know you had mentioned getting in touch with Albert, too, so happy to speak
with him as well if this is something he can help on. You have been so helpful so far, so I would appreciate your insight!
Thank you,
All the best,
Phoebe
Phoebe Williams
FILED: NEW YORK COUNTY CLERK 12/26/2023 12:19 PM INDEX NO. 655672/2023
NYSCEF NO. 510009/2023
INDEX NYSCEF:
IFILED DOC.
: NO. 16
NEW YORK COUNTY CLERK 08/30/2023 12: 37 PM RECEIVED 12/26/2023
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 08/30/2023
Associate
Winston Art Group
Tower 56
56th 245 Floor
126 East Street,
New York, NY 10022
Email: williams@winstonartgroup.com
C: 646-512-1824
www.winstonartgroup.com
Preview
FILED: NEW YORK COUNTY CLERK 12/26/2023 12:19 PM INDEX NO. 655672/2023 NYSCEF DOC. NO. 16 RECEIVED NYSCEF: 12/26/2023 "A" Exhibit FILED: NEW YORK COUNTY CLERK 12/26/2023 12:19 PM INDEX NO. 655672/2023 NYSCEF NO . 5 1 O0 INDEX NYSCEF: 0 9 / 2 O2 3 FILED DOC. : NO. 16 NEW YORK COUNTY CLERK 08 /30 /2023 12 : 37 PM) RECEIVED 12/26/2023 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 08/30/2023 Douq Pick From: Doug Pick Sent: Friday, August 4, 2023 1:46 PM To: John Cc: Eric C. Zabicki; Phoebe Williams; Jack Mur; Elizabeth von Habsburg Subject. FW: Questions on Some Artworks Attachments: WAG Missing or Unlisted Artworks.xisx Dear Mr Cahill, Attached is a schedule of artwork that we are unable to locate and to which Ms Schiff has not responded to. In order to avoid our a motion with the court to address our need for filing Ms Schiff to respond to whereabouts of the missing/unaccounted inventory we would request that you immediately reach out to Ms Schiff and obtain answers for us. Obviously Ms Schiff can speak to Winston Art to address the missing inventory. Thank you Doug directly Group Pick Douglas J. Pick I Partner PICK & ZABICKI LLP 369 Lexington Avenue, 12th Floor, New York, NY 10017 PICK & ZABICKI (212) 695-6000 Ext. 223 I dpick@picklaw.net L L P www.picklaw.net From: Phoebe Williams Sent: Friday, August 4, 2023 1:38 PM To: Lisa Schiff ; Doug Pick ; John Cc: Elizabeth von Habsburg ; Jack Mur Subject: RE: Questions on Some Artworks Dear all, I sent the below 24th message to Lisa on the requesting her help identifying some missing works, and haven't received a - I am John and here in case I have the wrong email address and to hopefully move things along. I reply including Doug have added further details to the spreadsheet of missing/unlisted items to specify what information exactly is needed for each work, and why each work is on this list. Notes" The rightmost column on each tab, titled "Additional , will specify why the WAG team has been unable to locate Works" works" the piece. The first two tabs, titled "Missing and "SFA missing are works that have not been found by WA.G., because no information was provided, or incorrect information was provided. - Whose These" The third tab, titled "Unlisted Are are artworks that we identified on the lists provided by UOVo and DAX as under SFA's storage accounts , but were not on the comprehensive inventory list provided a number of weeks ago titled ""Compressed Final SFA Inventory June 2023". For the works on this tab, we can assume they are at the storage location listed, but we need images and any other relevant details on the artworks. FILED: NEW YORK COUNTY CLERK 12/26/2023 12:19 PM INDEX NO. 655672/2023 NYSCEF DOC. NO. 16 RECEIVED NO. 510009/2023 INDEX NYSCEF: 12/26/2023 FILED : NEW YORK COUNTY CLERK 08/30/2023 12: 37 Ply$ NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 08 /30/2023 As you will see, there are hundreds of items that are not properly accounted for, and in order to move forward, we need Information on all of these pieces includinçr images. exact location. and any associate sale documents/provenance. The cumulative value of all of these unaccounted for pieces is not insignificant, and it is important that we receive as many details as possible on each one. Please let me know If this sheet is unclear in any way or if I can answer any questions. Sincerely, Phoebe Phoebe Williams Associate Winston Art Group Tower 56 126 East 56th Street, 24th FlOOr NewYork, NY 10022 Email: williams@winstonartaroup.com C: 646-512-1824 www.winstonartgroup.com From: Phoebe Williams Sent: Monday, July 24, 2023 10:26 AM To: Lisa Schiff Cc: Elizabeth von Habsburg ; Jack Mur Subject: Questions on Some Artworks Hi Lisa, I'm reaching out because l've been trying to reconcile all of the inventory we've come across so far. There some works that Ineed more information on, so I consolidated all of them onto one sheet to ask for your help on. This spreadsheet shows works that were found by putting together by combining the inventory lists you provided, as well as UOVO's list, DAX's list, and our own lists from cataloguing everything ourselves at 56 Leonard and 45 White, A few questions: 1. There were many works on DAX's and UOVO's lists that did not appear on any of the lists you sent over-I would like to verify whether these are SFA, or if they belong to anyone else (or are yours personally) - Whose These" a. These are found on the first tab titled "Unlisted Are 2. "Missing" There are also works that you marked as on the SFA General inventory PDF John sent us a couple Works" weeks ago (which was very helpfull) -these are on the tab called "5FA Missing 3. I added all of the works from your personal lists, consignment lists, and to be returned lists -any works that did "Missing" not have a location , I listed as . I know they might not actually be missing, but if you could note where they are, that would be a great help. I know this is a lot , so if it's easier to go through this on a phone call or if you would prefer to make edits yourself and send it back to me, just let me knowl I know you had mentioned getting in touch with Albert, too, so happy to speak with him as well if this is something he can help on. You have been so helpful so far, so I would appreciate your insight! Thank you, All the best, Phoebe Phoebe Williams FILED: NEW YORK COUNTY CLERK 12/26/2023 12:19 PM INDEX NO. 655672/2023 NYSCEF NO. 510009/2023 INDEX NYSCEF: IFILED DOC. : NO. 16 NEW YORK COUNTY CLERK 08/30/2023 12: 37 PM RECEIVED 12/26/2023 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 08/30/2023 Associate Winston Art Group Tower 56 56th 245 Floor 126 East Street, New York, NY 10022 Email: williams@winstonartgroup.com C: 646-512-1824 www.winstonartgroup.com