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. Xcentric Ventures LLC et al A i i - AEI x. Xcentric: Further Deposition https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&Att.peth... Doc. 87 q=s 24 Lisa Borodkin <lborodkin@gmail.com> AEI x. Xcentric: Further Deposition Lisa Borodkin <lborodkin@gmail.com> Sat, Jun 26, 2010 at 12:20 AM To: david@ripoffreport.com Cc: Maria Crimi Speth <mcs@jaburgwilk.com>, Daniel Blackert <blackertesq@yahoo.com> David, Taking your week is fine. I have appreciated your quick responses in the past and hope you will let us know sooner if you are able. We'd like to take the depositions as soon as you are ready. Will you again agree to split costs of the transcript of the July 24, 2010 proceedings to avoid any confusion? Thanks. Lisa On Sat, Jun 26, 2010 at 12:14 AM, David Gingras <david@ripoffreport.com> wrote: Lisa, To add my 2 cents First, Magistrate Walsh gave us a week to review this and respond, so please don't jump the gun and ask to make a call to the court before we've had a chance to really review this and give you our position. We will look at all of this and give you our position by next Friday. Second, I am 100% certain that you're still asking for many things you already have. For instance, re: the documents you list, putting aside the other objections we had, probably more than half of these are things you already have (we know this because they are docs Tina Norris gave you). Beyond this, I see a lot of other points that Maria and I need to review and discuss with Ed before we're in a position to know exactly where the legitimate disputes are. David Gingras, Esq. General Counsel Xcentric Ventures, LLC http://ww w.ripoffreport.com/ 1 of 4 Dockets.Justia.com 7/8/2010 5:08 PM Gmail - AEI x. Xcentric: Further Deposition https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... David@RipoffReport.com PO BOX 310, Tempe, AZ 85280 Tel.: (480) 668-3623 Fax: (480) 248-3196 From: Lisa Borodkin [mailto:lborodkin@gmail.com] Sent: Friday, June 25, 2010 5:52 PM To: Maria Crimi Speth Cc: Lisa Borodkin; <david@ripoffreport.com>; Daniel Blackert Sub ject: Re: AEI x. Xcentric: Further Deposition Maria, That is not true. There were other unanswered questions that I omitted as irrelevant. Sorry, I meant to delete the question about the phone vendor. The rest are, we believe, relevant to trial. Let's call Magistrate Walsh on Monday if you disagree. Lisa On Jun 25, 2010, at 5:35 PM, "Maria Crimi Speth" <mcs@jaburgwilk.com> wrote: Lisa: I am not sure if you misunderstood the Magistrate, or have chosen to disregard his ruling. Your letter merely lists every question that was not answered. The Magistrate expressed that he had no interest in reviewing a 3-page list of every single question that was not answered. He asked us (both sides) to work together to narrow these issues. Instead, you have just listed everything. How is that helpful? Can you please send, as instructed by the Magistrate, a list of the items that were not answered, that are relevant to the claims to be tried in August, and that you really believe you need answered for the trial. Maria Crimi Speth, Esq. Jaburg & Wilk, P.C. 3200 N. Central Ave., Suite 2000 Phoenix, AZ 85012 2 of 4 7/8/2010 5:08 PM Gmail - AEI x. Xcentric: Further Deposition https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... 602-248-1089 602-248-0522 (fax) www.jaburgwilk.com This communication is intended only for the individual or entity to whom it is directed. It may contain information that is privileged, confidential, or otherwise exempt from disclosure under applicable law. Dissemination, distribution, or copying of this communication by anyone other than the intended recipient, or a duly designated employee or agent of such recipient, is prohibited. If you have received this communication in error, please notify us immediately by telephone at (602) 248-1000, or via e-mail, and delete this message and all attachments thereto. From: lborodkin@gmail.com [mailto:lborodkin@gmail.com] On Behalf Of Lisa Borodkin Sent: Friday, June 25, 2010 5:11 PM To: <david@ripoffreport.com>; Maria Crimi Speth; Paul Berra Cc: Daniel Blackert; kristi@asiaecon.org; alexandra@asiaecon.org Subject: Re: AEI x. Xcentric: Further Deposition Counsel: Here is the letter ordered by the Court yesterday regarding additional subject areas for oral examination. P lease note that there are no line numbers on the rough transcript from the Magedson deposition. Accordingly, they are referenced by page number only. We would also like to schedule the deposition of Ben Smith for the same day. Please let me know a few dates that work for both of them. Thanks, Lisa -Lisa J. Borodkin lisa@lisaborodkin.com 323-337-7933 No virus found in this incoming message. Checked by AVG - www.avg.com Version: 9.0.830 / Virus Database: 271.1.1/2959 - Release Date: 06/24/10 23:35:00 -- 3 of 4 7/8/2010 5:08 PM Gmail - AEI x. Xcentric: Further Deposition https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... Lisa J. Borodkin lisa@lisaborodkin.com 323-337-7933 4 of 4 7/8/2010 5:08 PM

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