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 - XCentric Ventures case https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&Att.peth... Doc. 87 q=s 28 Lisa Borodkin <lborodkin@gmail.com> XCentric Ventures case David Gingras <david@ripoffreport.com> Reply-To: david@ripoffreport.com To: Lisa Borodkin <lborodkin@gmail.com> Cc: Maria Crimi Speth <mcs@jaburgwilk.com>, "paul@berra.org" <paulsberra@gmail.com>, Daniel Blackert <blackertesq@yahoo.com> Lisa, Fri, Jul 2, 2010 at 1:18 PM The judge's order was inconsistent the transcript specifically said we had a week to respond, and then he said July 1 which is less than a week, so I think the court was confused. Both Maria and I recalled the comment about us having a week to respond, and I think we all expected that one week meant today. st David Gingras, Esq. General Counsel Xcentr ic Ventures, LLC 1 of 4 Dockets.Justia.com 7/8/2010 5:15 PM Gmail - XCentric Ventures case https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... http://www.ripoffreport.com/ David@Ripoff Report .com PO BOX 310, Tempe, AZ 85280 Tel.: (480) 668-3623 Fax: (480) 248-8326 From: Lisa Borodkin [mailto:lborodkin@gmail.com] Sent: Friday, July 02, 2010 1:16 PM To: david@ripoffreport.com Cc: Maria Crimi Speth; paul@berra.org; Daniel Blackert Subject: Re: XCentric Ventures case David, Had your letter been timely, I might agree. However, your violation of Magistrate's Walsh's Order does not allow us sufficient time. P lease let me know when you want to talk with us. If you continue to avoid this, I will call Magistrate Walsh and explain what happened. Lisa On Fri, Jul 2, 2010 at 1:12 PM, David Gingras <david@ripoffreport.com> wrote: Lisa, I concur with what Maria has said, and I'm sorry about the confusion re: the dates....both Maria and I thought the judge was giving us a week to respond rather than 6 days, so I'm sor ry if the letter was a few hours later than expected. In terms of substance, I agree with Maria's position we can't agree to call the court with you until you tell us what your position is specifically, what in my letter do you disagree w ith? You know what your position is but we don't, and it's not appropriate for us to hear it for the first time on the phone today. You have our position in writing, and we are entitled to see your position in writing as well. David Gingras, Esq. General Counsel Xcentr ic Ventures, LLC htt p: / /w ww .r ipoff repor t. com/ David@Ripoff Report .com PO BOX 310, Tempe, AZ 85280 Tel.: (480) 668-3623 Fax: (480) 248-8326 From: Maria Crimi Speth [mailto:mcs@jaburgwilk.com] Sent: Friday, July 02, 2010 1:05 PM To: Lisa Borodkin; david@ripoffreport.com Cc: paul@berra.org; Daniel Blackert Subject: RE: XCentric Ventures case 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 pr ovid 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. 2 of 4 7/8/2010 5:15 PM Gmail - XCentric Ventures case https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... 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 t his 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 appl icabl e 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 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 Xcentr ic Ventures, LLC htt p: / /w ww .r ipoff repor t. com/ David@Ripoff Report .com PO BOX 310, Tempe, AZ 85280 Tel.: (480) 668-3623 Fax: (480) 248-8326 -- 3 of 4 7/8/2010 5:15 PM Gmail - XCentric Ventures case https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=speth... Lisa J. Borodkin lisa@lisaborodkin.com 323-337-7933 -Lisa J. Borodkin lisa@lisaborodkin.com 323-337-7933 4 of 4 7/8/2010 5:15 PM

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