Mikhlyn et al v. Bove et al

Filing 225

First MOTION for Sanctions by Anna Bove Collections, Inc., Anna Bove Company, LLC, Anna Bove Embroidery Supplies, Inc., Ana Bove, Polina Dolginov. (Attachments: # 1 Exhibit Exh. 1, # 2 Exhibit Exh. 2, # 3 Exhibit Exh. 3, # 4 Exhibit Exh. 4) (Berger, Jonathan)

Ana Bove, Polina Dolginov (pro se Defendants)
June 16, 2011

Sent To:
Judge Ramon E. Reyes
United States District Court
225 Cadman Plaza East
Brooklyn, NY 11201
Re: Mikhlyn, et al. v. Bove, et al.; Case No. 1:08-cv-3367
Dear Judge Reyes:
We file this letter in response to Plaintiffs' recent submission,
dated June 15, 2011 [Doc #219].
We'd like to express our concern about the allegedly unproduced
thousands of documents, which Mr. Wertheim mentioned. Plaintiffs
filed this “joint” letter without providing Defendants a copy for
review. And although Defendants don't oppose the extension request,
Defendants wish to clarify some other important issues, which are
described incorrectly in Mr. Wertheim's letter.
Within the course of this litigation, while Mr. Kogan was still our
attorney, we gave him the following 4 types of CDs:
1.
2.
3.
4.

Attorney-Client privileged communications
For Boris K. Eyes Only (Skype chats).
Confidential correspondence with clients
Attorney Eyes only (trade secret)

All of this information, which was turned over to our former lawyer,
Mr. Kogan, was provided on six CDs listed below. (*In each line,
there is a date for each of the appropriate CDs, indicating when it
was created and turned over to Mr. Kogan).
1.СD10
2.СD18
3.СD18
4.СD21
chats.

–

10.11.2009
01.25.2010
03.01.2010
02.26.2010

Attorney Client Privilege
Attorney Client Privilege (first version)
Attorney Client Privilege (second version)
For Boris K. Attorney Eyes Only Skype

5.СD19 - 01.25.2010 Attorney Eyes Only (trade secret)
1

6.CD20 - 01.25.2010

Attorney

Eyes Only

We don't know what Mr. Kogan did with those CDs. CD10, CD18 and CD20
was returned to us by Mr. Kogan. CD19 and CD21 were never returned to
us by Mr. Kogan. Therefore, we assumed copies of CD19 and CD20 Mr.
Kogan has forwarded to them, to Plaintiffs.
Mr. Kogan also didn't send these CDs to Levinson
because the Berger firm doesn't have them.

Berger. We know this

If Mr. Wertheim believes that Mr. Kogan didn't provide them, then we
are willing to go through our copies, and produce whatever is
appropriate, as soon as possible.
Except of that, we also seek to receive from Plaintiffs the documents
which Plaintiffs sent to IRS office, about their tax reports;
And also: Documents and Plaintiffs' correspondence with IRS regarding
the 1099 and 1096 forms which Ana Bove sent for Mikhlyns' family to
IRS;
And also: Documents
Plaintiffs;

concerning

the QuickBook

report provided

by

And also: Resolve the issue of bad physical state of some financial
documents which Plaintiffs produced in Discovery;

Thank you for your consideration!
Respectfully submitted,
pro se Defendants Ana Bove, Polina Dolginov.

Polina Dolginov

oC. ,f£.

20,-{-/

Dated

cc

to:

Mr. Eric Wertheim ([e-mail])
Mr. Daniel Akselrod ([e-mail])

2