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

Filing 87

EX PARTE APPLICATION to Continue the determination of, or denying, Defendants' Motion for Summary Judgment from July 12, 2010 to At the Court's discretion Re: MOTION for Summary Judgment as to Entire Case 40 , EX PARTE APPLICATION to Enforce Order to Compel Continued Deposition of Defendant Edward Magedson, EX PARTE APPLICATION for Sanctions Local Rule 83.7, Local Rule 37-4, and this Court's inherent authority filed by Plaintiffs Asia Economic Institute, Iliana Llaneras, Raymond Mobrez. (Attachments: # 1 Exhibit 1 to Declaration of Lisa J. Borodkin, # 2 Exhibit 2 to Declaration of Lisa J. Borodkin, # 3 Exhibit 3 to Declaration of Lisa J. Borodkin, # 4 Exhibit 4 to Declaration of Lisa J. Borodkin, # 5 Exhibit 5 to Declaration of Lisa J. Borodkin, # 6 Exhibit 6 to Declaration of Lisa J. Borodkin, # 7 Exhibit 7 to Declaration of Lisa J. Borodkin, # 8 Exhibit 8 to Declaration of Lisa J. Borodkin, # 9 Exhibit 9 to Declaration of Lisa J. Borodkin, # 10 Exhibit 10 to Declaration of Lisa J. Borodkin, # 11 Exhibit 11 to Declaration of Lisa J. Borodkin, # 12 Exhibit 12 to Declaration of Lisa J. Borodkin, # 13 Exhibit 13 to Declaration of Lisa J. Borodkin, # 14 Exhibit 14 to Declaration of Lisa J. Borodkin, # 15 Exhibit 15 to Declaration of Lisa J. Borodkin, # 16 Exhibit 16 to Declaration of Lisa J. Borodkin, # 17 Exhibit 17 to Declaration of Lisa J. Borodkin, # 18 Exhibit 18 to Declaration of Lisa J. Borodkin, # 19 Exhibit 19 to Declaration of Lisa J. Borodkin, # 20 Exhibit 20 to Declaration of Lisa J. Borodkin, # 21 Exhibit 21 to Declaration of Lisa J. Borodkin, # 22 Exhibit 22 to Declaration of Lisa J. Borodkin, # 23 Exhibit 23 to Declaration of Lisa J. Borodkin, # 24 Exhibit 24 to Declaration of Lisa J. Borodkin, # 25 Exhibit 25 to Declaration of Lisa J. Borodkin, # 26 Exhibit 26 to Declaration of Lisa J. Borodkin, # 27 Exhibit 27 to Declaration of Lisa J. Borodkin, # 28 Exhibit 28 to Declaration of Lisa J. Borodkin, # 29 Exhibit 29 to Declaration of Lisa J. Borodkin, # 30 Exhibit 30 to Declaration of Lisa J. Borodkin, # 31 Exhibit 31 to Declaration of Lisa J. Borodkin, # 32 Exhibit 32 to Declaration of Lisa J. Borodkin, # 33 Exhibit 33 to Declaration of Lisa J. Borodkin, # 34 Exhibit 34 to Declaration of Lisa J. Borodkin, # 35 Exhibit 35 to Declaration of Lisa J. Borodkin, # 36 Exhibit 36 to Declaration of Lisa J. Borodkin, # 37 Exhibit 37 to Declaration of Lisa J. Borodkin)(Borodkin, Lisa)

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Gmasla Economic Institute et al v.Cal. 10-cv-1360) Draft Rule 26f Report A i i - AEI et al. v. Xcentric (C.D. Xcentric Ventures LLC et al https://mail.google.com/mail/?ui=2&ik=0d9198f21b&Dow=pt&q=d10i... viec. 87 Att. av Lisa Borodkin <lborodkin@gmail.com> AEI et al. v. Xcentric (C.D. Cal. 10-cv-1360) Draft Rule 26f Report Lisa Borodkin <lborodkin@gmail.com> Fri, May 7, 2010 at 11:41 PM To: "<david@ripoffreport.com>" <david@ripoffreport.com> Cc: Lisa Borodkin <lisa_borodkin@post.harvard.edu>, Maria Crimi Speth <mcs@jaburgwilk.com>, Daniel Blackert <blackertesq@yahoo.com> David, I appreciate your answer on the jury question. I am very concerned by your email. What is it that you think I need to contact the State Bar or consult counsel about immediately? Do you mean before you send a demand letter on Monday, or is this something more urgent? If you have anything to tell me about my personal ethical obligations, or reason to recommend that I retain counsel, please tell me directly what you are talking about and do not assume that my co-counsel has filled me in. I do not have all the facts. If it concerns the State Bar, be assured that I take any such matters extremely seriously. Lisa On May 7, 2010, at 9:50 PM, "David Gingras" <david@ripoffreport.com> wrote: Lisa, Prior to your departure from the depo this afternoon, I told you that I would give you a response to the jury trial issue by the end of the day. In order to fulfill that promise, I wanted to let you know our position if this case goes to trial, we believe it is appropriate for the matter to be tried to a jury as the court's trial setting order already indicates. As for the Rule 26(f) report, for reasons that I am sure Dan has explained to you by now, I believe it is inappropriate to have any further discussions about any substantive aspect of this case unless and until you and Dan have an opportunity to meet and confer with your clients re: their intentions going forward. I also strongly recommend that both you and Dan immediately contact the State Bar of California and/or seek independent legal counsel regarding your personal ethical obligations under the California Rules of Professional Conduct and California Business & Professions Code in light of today's developments. For now, my intent is to send you and Dan a comprehensive demand letter on Monday which sets forth Defendants' positions as to numerous legal and ethical issues in light of today's developments. Until that letter is sent, and until you have a chance to review and respond to it, I believe it is inappropriate to discuss any further aspects of this case. I will forward my letter to you on Monday and we can then discuss where things stand and how this case will be proceeding, if at all. 1 of 2 Dock7/t8/.2010ia.com e s Just 3:49 AM Gmail - AEI et al. v. Xcentric (C.D. Cal. 10-cv-1360) Draft Rule 26f Report https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=davi... David Gingras, Esq. General Counsel Xcentric Ventures, LLC http://ww w.ripoffreport.com/ David@RipoffReport.com <image001.jpg> [Quoted text hidden] [Quoted text hidden] [Quoted text hidden] 2 of 2 7/8/2010 3:49 AM

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