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

Filing 91

REPLY Support 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 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 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 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 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 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 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 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 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 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 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 87 filed by Plaintiffs Asia Economic Institute, Iliana Llaneras, Raymond Mobrez. (Attachments: # 1 Exhibit 38 to Supplemental Declaration of Lisa J. Borodkin, # 2 Exhibit 39 to Supplemental Declaration of Lisa J. Borodkin, # 3 Exhibit 40 to Supplemental Declaration of Lisa J. Borodkin, # 4 Exhibit 41 to Supplemental Declaration of Lisa J. Borodkin, # 5 Exhibit 42 to Supplemental Declaration of Lisa J. Borodkin, # 6 Exhibit 43 to Supplemental Declaration of Lisa J. Borodkin, # 7 Exhibit 44 to Supplemental Declaration of Lisa J. Borodkin, # 8 Exhibit 45 to Supplemental Declaration of Lisa J. Borodkin, # 9 Exhibit 46 to Supplemental Declaration of Lisa J. Borodkin, # 10 Exhibit 47 to Supplemental Declaration of Lisa J. Borodkin, # 11 Exhibit 48 to Supplemental Declaration of Lisa J. Borodkin)(Borodkin, Lisa)

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

Doc. 91 Att. 4

Gmail - RE: AEI v. Xcentric - ED's Depo

https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=gingr...

Lisa Borodkin <[e-mail]>

RE: AEI v. Xcentric - ED's Depo
Lisa Borodkin <[e-mail]> Mon, Jun 7, 2010 at 5:45 PM To: [e-mail] Cc: Maria Crimi Speth <[e-mail]>, Daniel Blackert <[e-mail]> David and Maria, Please see attached Notice of Deposition for Mr. Magedson's deposition tomorrow. Lisa On Mon, Jun 7, 2010 at 3:07 PM, Lisa Borodkin <[e-mail]> wrote: Y es, we have flights. See you tomorrow. Lisa

On Mon, Jun 7, 2010 at 1:57 PM, David Gingras <[e-mail]> wrote: We're available assuming you are.

David Gingras, Esq. General Counsel Xcentric Ventures, LLC http://ww w.ripoffreport.com/ [e-mail]

PO BOX 310, Tempe, AZ 85280 Tel.: [phone] Fax: [phone] From: Lisa Borodkin [mailto:[e-mail]] Sent: Monday, June 07, 2010 1:51 PM To: [e-mail]; Maria Crimi Speth Cc: Daniel Blackert Subject: Re: AEI v. Xcentric - ED's Depo

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Gmail - RE: AEI v. Xcentric - ED's Depo

https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=gingr...

Hi David and Maria,

Can we confirm that we are still on for Mr. Magedson's deposition for 9:30 a.m. tomorrow?

Lisa On Jun 4, 2010, at 5:02 PM, Lisa Borodkin <[e-mail]> wrote: Hi David and Maria, We'd like to schedule the deposition of Edward Magedson for Tuesday, June 8 at 9:30 a.m. Please find attached a subpoena for a few documents for Mr. Magedson to bring with him. At this time we're going to hold off on deposing Ben Smith. Thanks very much for offering to make him available. Lisa On Thu, Jun 3, 2010 at 3:06 PM, David Gingras <[e-mail]> wrote: Lisa, P er our phone conversation a few minutes ago, I spoke to Ed and he can be available for his individual depo either Tuesday, June 8 or Wednesday, June 9. However, I have not yet been able to reach Ben Smith to see what his schedule is like, and my impression from yesterday was that you wanted to take Ben and Ed on the same day, if possible. Anyway, I left a voicemail for Ben and will let you know when I hear back from him. Right now, I am hoping that he's free and that we can get this done on Tuesday which I think you said was your preferred date. David Gingras, Esq. General Counsel Xcentric Ventures, LLC http://www.ripoffreport.com/ [e-mail] http://www.ripoffreport.com/ P O BOX 310, Tempe, AZ 85280 Tel.: [phone] Fax: [phone]

-----Original Message----From: Lisa Borodkin [mailto:[e-mail]] Sent: Thursday, June 03, 2010 9:49 AM To: [e-mail]; Maria Crimi Speth

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Gmail - RE: AEI v. Xcentric - ED's Depo

https://mail.google.com/mail/?ui=2&ik=0d9198f21b&view=pt&q=gingr...

Cc: Daniel Blackert; [e-mail]; [e-mail] Subject: AEI v. Xcentric Hi David and Maria, Just a reminder that pursuant to my discussion with David yesterday we are expecting your final approval for filing on the joint stipulation by 11:00 am today. Lisa No virus found in this incoming message. Checked by AVG - www.avg.com Version: 9.0.819 / Virus Database: 271.1.1/2910 - Release Date: 06/02/10 23:25:00

-Lisa J. Borodkin [e-mail] 323-337-7933 <Magedson Depo Subpoena.pdf>
No virus found in this incoming message. Checked by AVG - www.avg.com Version: 9.0.829 / Virus Database: 271.1.1/2923 - Release Date: 06/06/10 23:35:00

-Lisa J. Borodkin [e-mail] 323-337-7933

-Lisa J. Borodkin [e-mail] 323-337-7933
Plaintiff Notice of Deposition of Magedson.pdf 32K

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