Case 5:18-md-02834-BLF Document 671-2 Filed 05/07/21 Page 1 of 5
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`Exhibit 2
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`Case 5:18-md-02834-BLF Document 671-2 Filed 05/07/21 Page 2 of 5
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`From:
`To:
`Cc:
`Subject:
`Date:
`
`Jeffrey Gersh
`Todd Gregorian; Michael Sherman
`Viviana Boero Hedrick; David Hadden; Chieh Tung; jlamken@mololamken.com
`RE: In Re: PersonalWeb Technologies, LLC
`Thursday, April 22, 2021 9:08:09 PM
`
`Todd
`
`We do not represent Pweb in the post judgment proceedings. You have no authority to serve us
`with any documents relating thereto.
`
`Jeff
`
`
`Jeffrey F. Gersh
`Partner, Stubbs Alderton & Markiles, LLP
`818.444.9222 (voice/text/fax) | jgersh@stubbsalderton.com
`www.stubbsalderton.com | Attorney Bio
`15260 Ventura Blvd., 20th FL, Sherman Oaks, CA 91403
`
`
`
`The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an
`attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or an agent
`responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination,
`distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the
`original message.
`From: Todd Gregorian <TGregorian@fenwick.com>
`Sent: Wednesday, April 21, 2021 7:46 AM
`To: Jeffrey Gersh <jgersh@stubbsalderton.com>; Michael Sherman <masherman@stubbsalderton.com>
`Cc: Viviana Boero Hedrick <vhedrick@stubbsalderton.com>; David Hadden <DHadden@fenwick.com>; Chieh Tung
`<ctung@fenwick.com>; jlamken@mololamken.com
`Subject: RE: In Re: PersonalWeb Technologies, LLC
`
`[EXTERNAL EMAIL] This email is from an external sender, and not from Stubbs Alderton & Markiles.
`Do not click on links or attachments unless you are sure of the sender.
`
`Jeff and Michael,
`
`It is a bit disappointing, given PersonalWeb’s aggression in demanding responses to its own issues throughout the case,
`that it now will not provide the courtesy of a timely response. In addition to the matters discussed below, I have the
`following additional issues to address:
`
`
`By now you have seen our discovery requests in aid of enforcement. While PersonalWeb has the usual period to
`provide a formal response to those, I would ask you separately to identify by close of business today any
`PersonalWeb bank or financial accounts, including current balances, so that our enforcement of the judgment is not
`further delayed.
`
`Amazon and Twitch intend to apply ex parte to take the debtor’s examination of PersonalWeb. Please let me know
`if PersonalWeb will oppose this relief, and if so, on what grounds. I am available to confer after 2pm today or
`tomorrow before noon.
`
`
`Thank you,
`
`Todd Gregorian
`Fenwick | Partner | 415-875-2402 | tgregorian@fenwick.com
`
`
`
`
`Case 5:18-md-02834-BLF Document 671-2 Filed 05/07/21 Page 3 of 5
`
`
`
`From: Todd Gregorian
`Sent: Monday, April 19, 2021 6:36 PM
`To: 'Jeffrey Gersh' <jgersh@stubbsalderton.com>; 'Michael Sherman' <masherman@stubbsalderton.com>
`Cc: 'Viviana Boero Hedrick' <vhedrick@stubbsalderton.com>; David Hadden <DHadden@fenwick.com>
`Subject: RE: In Re: PersonalWeb Technologies, LLC
`
`Jeff,
`
`Following up on my request. Please let us know whether PersonalWeb will pay the judgment or post a bond, and answer
`my other questions below.
`
`
`Todd Gregorian
`Fenwick | Partner | 415-875-2402 | tgregorian@fenwick.com
`
`
`
`From: Todd Gregorian
`Sent: Saturday, April 17, 2021 12:28 PM
`To: Jeffrey Gersh <jgersh@stubbsalderton.com>; Michael Sherman <masherman@stubbsalderton.com>
`Cc: Viviana Boero Hedrick <vhedrick@stubbsalderton.com>; David Hadden <DHadden@fenwick.com>
`Subject: RE: In Re: PersonalWeb Technologies, LLC
`
`Jeff,
`
`Please let me know what PersonalWeb currently plans to do, if anything, to secure the judgment. Amazon is not willing to
`leave the judgment unsecured during the appeal. I think it is in the interest of both sides to avoid incurring additional
`expenses around this issue, and Amazon reserves the right to seek reimbursement of any such expense that PersonalWeb
`forces it to incur by failing to secure the judgment. But it would be much simpler if PersonalWeb posted a bond
`voluntarily.
`
`Finally, for the purposes of meeting and conferring regarding this issue and related potential motion practice, please let me
`know: (1) whether PersonalWeb currently has sufficient funds to pay the judgment in full; and (2) if not, what assets and
`what amount of cash does PersonalWeb have available to it to secure the judgment?
`
`Thank you,
`
`Todd Gregorian
`Fenwick | Partner | 415-875-2402 | tgregorian@fenwick.com
`
`
`
`From: Jeffrey Gersh <jgersh@stubbsalderton.com>
`Sent: Monday, April 5, 2021 3:48 PM
`To: Todd Gregorian <TGregorian@fenwick.com>; Michael Sherman <masherman@stubbsalderton.com>
`Cc: Viviana Boero Hedrick <vhedrick@stubbsalderton.com>; David Hadden <DHadden@fenwick.com>
`Subject: RE: In Re: PersonalWeb Technologies, LLC
`
`Todd
`Sorry for any delay in responding to your question. At this time the client is considering its
`options and no decision one way or the other has been made. Please feel free to follow-up with
`me at the end of the week or early next week.
`
`Regards
`
`
`
`Case 5:18-md-02834-BLF Document 671-2 Filed 05/07/21 Page 4 of 5
`
`
`JG
`
`
`Jeffrey F. Gersh
`Partner, Stubbs Alderton & Markiles, LLP
`818.444.9222 (voice/text/fax) | jgersh@stubbsalderton.com
`www.stubbsalderton.com | Attorney Bio
`15260 Ventura Blvd., 20th FL, Sherman Oaks, CA 91403
`
`
`
`The information contained in this e-mail message is intended only for the personal and confidential use of the recipient(s) named above. This message may be an
`attorney-client communication and/or work product and as such is privileged and confidential. If the reader of this message is not the intended recipient or an agent
`responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination,
`distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately by e-mail, and delete the
`original message.
`From: Todd Gregorian <TGregorian@fenwick.com>
`Sent: Monday, April 5, 2021 11:02 AM
`To: Michael Sherman <masherman@stubbsalderton.com>; Jeffrey Gersh <jgersh@stubbsalderton.com>
`Cc: Viviana Boero Hedrick <vhedrick@stubbsalderton.com>; David Hadden <DHadden@fenwick.com>
`Subject: RE: In Re: PersonalWeb Technologies, LLC
`
`
`Just following up on the below. Could you let me know your client’s plan, so that Amazon does not incur any unnecessary
`enforcement expense?
`-t
`
`From: Todd Gregorian
`Sent: Wednesday, March 31, 2021 10:23 AM
`To: Michael Sherman <masherman@stubbsalderton.com>; Jeffrey Gersh <jgersh@stubbsalderton.com>
`Cc: Viviana Boero Hedrick <vhedrick@stubbsalderton.com>; David Hadden <DHadden@fenwick.com>
`Subject: In Re: PersonalWeb Technologies, LLC
`
`Counsel,
`
` saw that PersonalWeb intends to appeal the fee order. Does it intend to post a bond to extend the automatic stay of
`enforcement? By when will it post?
`
`Thanks,
`-t
`
`From: ECFdocuments@pacerpro.com <ECFdocuments@pacerpro.com>
`Sent: Wednesday, March 31, 2021 10:11 AM
`To: Allen Wang <allen.wang@fenwick.com>; Shannon Turner <sturner@fenwick.com>; Tracey Boomer
`<tboomer@fenwick.com>; Todd Gregorian <TGregorian@fenwick.com>; Saina Shamilov <sshamilov@fenwick.com>; Irma
`Campos <ICampos@fenwick.com>; David Hadden <DHadden@fenwick.com>; Chieh Tung <ctung@fenwick.com>; Ravi
`Ranganath <rranganath@fenwick.com>; Vicky Pieretti <VPieretti@fenwick.com>; Melanie Mayer
`<mmayer@fenwick.com>; Sara McPhee <smcphee@fenwick.com>; Lit KM PacerPro <litkmpacerpro@fenwick.com>;
`Shane Redden <sredden@fenwick.com>; Sandy Sanford <ssanford@fenwick.com>; Julie Tosches <jtosches@fenwick.com>
`Subject: [23984-00507] In Re: PersonalWeb Technologies, LLC et al (closed 10/29/2020) (Doc# 653, N.D. Cal. 5:18-md-
`02834-BLF)
`
`** EXTERNAL EMAIL **
`
` I
`
`In Re: PersonalWeb Technologies, LLC et al (closed 10/29/2020)
`
`
`
`Case 5:18-md-02834-BLF Document 671-2 Filed 05/07/21 Page 5 of 5
`
`Docket entry number: 653
`NOTICE OF APPEAL to the Federal Circuit as to [648] Order, by PersonalWeb Technologies, LLC.
`Filing fee $ 505, receipt number 0971-15774628. Appeal Record due by 4/30/2021. (Sherman, Michael)
`(Filed on 3/31/2021) (Entered: 03/31/2021)
`Date entered: 2021-03-31
`
`VIEW CASE
`https://app.pacerpro.com/cases/7370994
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