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)

Download PDF
Gmasla Economic Institute et al v. Xcentric Ventures LLC et al A i i - XCentric Ventures case https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&Att.peth... Doc. 87 q=s 26 Lisa Borodkin <lborodkin@gmail.com> XCentric Ventures case Lisa Borodkin <lborodkin@gmail.com> Fri, Jul 2, 2010 at 1:02 PM To: david@ripoffreport.com Cc: Maria Crimi Speth <mcs@jaburgwilk.com>, "paul@berra.org" <paulsberra@gmail.com>, Daniel Blackert <blackertesq@yahoo.com> David, This confirms that Dan and I just left a telephone message for you at your office requesting a time for you before 4:30 today when you are free to call Magistrate Walsh together to resolve the issue of Mr. Magedson's continued 30(b)(6) and personal deposition. For the record, I wanted to give you advance notice of two issues in particular: 1. Your letter is late. It was due yesterday, Thursday, July 1, 2010. Please find attached the relevant pages of the transcript from the June 24, 2010 proceeding. I hope you will avoid any prejudiceto Plaintiffs caused by your late response by accommodating our need for a call with Magistrate Walsh today. 2. Plaintiffs are entitled to have a prepared, knowledgeable witness for any 30(b)(6) deposition. If Mr. Magedson is not knowledgeable about the topics, Xcentric's obligation is to produce a witness who is. I look forward to your call. Due to Magistrate Walsh being unavailable all next week, we need to have this issue resolved today. If I do not hear from you by a reasonable time, I will call myself. Lisa [Quoted text hidden] 2 attachments Pages from transcript of 6 24 10 hearing.pdf 33K Page 30 from 6 24 10 hearing transcript.pdf 32K 1 of 1 Dockets.Justia.com 7/8/2010 5:14 PM Gmail - XCentric Ventures case https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... Lisa Borodkin <lborodkin@gmail.com> XCentric Ventures case Lisa Borodkin <lborodkin@gmail.com> Fri, Jul 2, 2010 at 1:08 PM To: Maria Crimi Speth <mcs@jaburgwilk.com> Cc: david@ripoffreport.com, "paul@berra.org" <paulsberra@gmail.com>, Daniel Blackert <blackertesq@yahoo.com> Maria, Y our letter was late. You did not follow the Magistrate's Order. Please let us know when you can talk. If we can resolve it telephonically among ourselves, we will. Lisa On Fri, Jul 2, 2010 at 1:05 PM, Maria Crimi Speth <mcs@jaburgwilk.com> wrote: Lisa: Once again, you are forgetting or ignoring the Magistrate's request to us. He asked us to work together to list the items that really are in dispute. You have made no attempt to provid to us your position on this. All you did was list every question that he did not answer, and many that he did. You left it up to David to address every single instance, including those that we know you don't dispute or that you know were answered. David has carefully done that and set forth our position. This was time consuming but we had to do it to comply with the Magistrate's request. It was more time consuming than it needed to be because you didn't narrow it. Now, twenty-one minutes after you received David's letter, you want to immediately call the Magistrate even though you haven't responded to David's letter. We need to confer on this and narrow the issues. I know you ordered the transcript of the hearing. Please read the section on this issue and follow the Magistrate's request. Maria Crimi Speth, Esq. Jaburg & Wilk, P.C. 3200 N. Central Ave., Suite 2000 Phoenix, AZ 85012 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: Lisa Borodkin [mailto:lborodkin@gmail.com] Sent: Friday, July 02, 2010 12:46 PM To: david@ripoffreport.com Cc: Maria Crimi Speth; paul@berra.org; Daniel Blackert 1 of 3 7/8/2010 5:12 PM Gmail - XCentric Ventures case https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... Subject: Re: XCentric Ventures case Hi David, Thanks for your letter. What time are you available for a conference call to Magistrate Walsh today? We need to do one before we break for the holiday. Lisa On Fri, Jul 2, 2010 at 12:22 PM, David Gingras <david@ripoffreport.com> wrote: Lisa, Per Magistrate Walsh's order, attached is our response to your letter re: unanswered deposition questions. For purposes of clarity and ease of reference, I have attached a copy of your letter to this email as well. Have a good holiday weekend. David Gingras, Esq. General Counsel Xcentric Ventures, LLC http://ww w.ripoffreport.com/ David@RipoffReport.com PO BOX 310, Tempe, AZ 85280 Tel.: (480) 668-3623 Fax: (480) 248-8326 -Lisa J. Borodkin lisa@lisaborodkin.com 323-337-7933 -Lisa J. Borodkin 2 of 3 7/8/2010 5:12 PM Gmail - XCentric Ventures case https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... lisa@lisaborodkin.com 323-337-7933 3 of 3 7/8/2010 5:12 PM

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?