Asia Economic Institute et al v. Xcentric Ventures LLC et al

Filing 142

Opposition (with exhibits) Opposition re: MOTION for Sanctions Fed.R.Civ.P. 11 135 filed by Plaintiffs Asia Economic Institute, Iliana Llaneras, Raymond Mobrez. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Borodkin, Lisa)

Asia Economic Institute et al v. Xcentric Ventures LLC et al Gmail - Meet and Confer

Doc. 142 Att. 3 https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt...

Lisa Borodkin <[e-mail]>

Meet and Confer
Daniel Blackert <[e-mail]> Sat, Aug 14, 2010 at 1:05 PM To: Maria Speth <[e-mail]>, david gingras <[e-mail]> Cc: Lisa Borodkin <[e-mail]> I am writing this email to meet and confer with you regarding several issues. 1-We will respond to your Rule 11 Motion by amending our First Amended Complaint ("FAC"). We have analyzed our FAC very closely and will strike out certain paragraphs, however we do not plan to strike every paragraph mentioned in your Rule 11 Motion as we believe that many of your allegations which you characterize as untrue are, in reality, backed up by the evidence we have presented. 2-We will respond to your Motion to Dismiss by amending our FAC and striking out our wire fraud cause of action and then simultaneously moving to remand to State Court. 3-Likewise, we believe that by striking out our wire fraud claim your Motion to Dismiss essentially becomes moot as it only addresses the aspects of our wire fraud claim. 4-We will also file a Motion for reconsideration regarding the RICO/extortion cause of action. 5-We plan to make these filings on Monday so I would like to know your response to these issues and the possibility of resolving them absent Court intervention. 6-I am attaching the proposed amendments and requesting that you stipulate to review the issues above and consider stipulating to any of them. This would save the Court time and convenience, especially since we are dropping the wire fraud claim, your Motion to Dismiss is essentially and technically moot, so you may want to withdraw it; I think Judge Wilson will look favorably upon this.

7-Are you available any time either tomorrow (I know it is not a business day and I understand if you are unavailable but at your convenience I am available anytime before 3:30 PM) or Monday for a telephonic meet and confer? Thanks you and I look forward to resolving the issues addressed above, Daniel F. Blackert, Esq.

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Gmail - Meet and Confer

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