Case 5:18-md-02834-BLF Document 671-7 Filed 05/07/21 Page 1 of 7
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`Exhibit 7
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`Case 5:18-md-02834-BLF Document 671-7 Filed 05/07/21 Page 2 of 7
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`From:
`To:
`Cc:
`Subject:
`Date:
`
`Ronald Richards
`Todd Gregorian; Morani Stelmach
`Michael Sherman; Viviana Boero Hedrick; Lamken, Jeffrey; Jeffrey Gersh
`RE: PERSONALWEB TECHONLOGIES INC.
`Tuesday, April 27, 2021 3:25:15 PM
`
`[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.
`
`Mr. Gregorian,
`
` I
`
` am following federal law. See Rule 69.
`
`
`There are serious consequences under California law for falsely obtaining enforcement without compliance with service. I will not reiterate
`them hear to avoid an uncivil email but you should review them carefully before you try and seek remedial efforts while ignoring Rule 69 and
`CCP 708.170(2)(b).
`
`As I have repeatedly said, we will respond to all lawfully served post judgment discovery orders.
`
` I
`
` believe you have an obligation to alert a busy federal judge of nuanced California procedure which is typically handled by the mag court.
`
`
`Submitting ex parte applications representing they are unopposed or impliedly unopposed to obtain orders that could be abused or
`improperly used creates issues.
`
` I
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` would like to avoid them so if you are not going to follow Rule 69 set forth below applying CCP 708 et. seq, please tell me and I will know
`what to do.
`
`All rights reserved.
`
`
`
`
`
`Sincerely,
`
`Ronald Richards, Esq.
`Law Offices of Ronald Richards & Associates, A.P.C.
`310-556-1001 Office
`310-277-3325 Fax
`www.ronaldrichards.com
`
`Mailing Address:
`P.O. Box 11480
`Beverly Hills, CA 90213
` ®
`
`
` **A multi jurisdictional practice with bar admissions on the East and West Coast**
` ***CONFIDENTIALITY NOTICE*** This electronic mail transmission has been sent by an attorney. This
`message and any files or text attached to it are intended only for the recipients named above, and contain
`
`

`

`Case 5:18-md-02834-BLF Document 671-7 Filed 05/07/21 Page 3 of 7
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`
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`information that may be confidential or privileged. If you are not an intended recipient, you must not read,
`copy, use or disclose this communication. Please also notify the sender by replying to this message, and then
`delete all copies of it from your system. Thank you.
`________________________________
`THINK GREEN. PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS MESSAGE. THANK YOU.
`Rule 69. Execution
`Primary tabs
`(a) In GEnERal.
`(1) Money Judgment; Applicable Procedure. a money judgment is enforced by a writ of
`execution, unless the court directs otherwise. The procedure on execution—and in
`proceedings supplementary to and in aid of judgment or execution—must accord with the
`procedure of the state where the court is located, but a federal statute governs to the
`extent it applies.
`(2) Obtaining Discovery. In aid of the judgment or execution, the judgment creditor or
`a successor in interest whose interest appears of record may obtain discovery from any
`person—including the judgment debtor—as provided in these rules or by the procedure of
`the state where the court is located.
`
`
`
`From: Todd Gregorian <TGregorian@fenwick.com>
`Sent: Tuesday, April 27, 2021 2:58 PM
`To: Ronald Richards <ron@ronaldrichards.com>; Morani Stelmach <morani@ronaldrichards.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Viviana Boero Hedrick <vhedrick@stubbsalderton.com>;
`Lamken, Jeffrey <jlamken@mololamken.com>; Jeffrey Gersh <jgersh@stubbsalderton.com>
`Subject: RE: PERSONALWEB TECHONLOGIES INC.
`
`Mr. Richards,
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`The Court has now entered the order to appear, setting the debtor’s examination for May 25. I do understand that the
`California Code of Civil Procedure has separate service requirements for creating a judgment lien on personal property.
`But we are in federal court, and both the order to appear and the order directing PersonalWeb to produce documents were
`properly served on PersonalWeb through ECF. I have now served them on you separately via email as PersonalWeb’s
`chosen counsel for this matter.
`
`Please let me know whether PersonalWeb intends to comply, or if instead it plans to maintain its objection that the Court’s
`orders are ineffective absent additional service.
`
`
`Todd Gregorian
`Fenwick | Partner | 415-875-2402 | tgregorian@fenwick.com
`
`
`
`
`From: Jeffrey Gersh <jgersh@stubbsalderton.com>
`Sent: Tuesday, April 27, 2021 2:33 PM
`To: Ronald Richards <ron@ronaldrichards.com>; Todd Gregorian <TGregorian@fenwick.com>; Morani Stelmach
`
`

`

`Case 5:18-md-02834-BLF Document 671-7 Filed 05/07/21 Page 4 of 7
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`<morani@ronaldrichards.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Viviana Boero Hedrick <vhedrick@stubbsalderton.com>;
`Lamken, Jeffrey <jlamken@mololamken.com>
`Subject: RE: PERSONALWEB TECHONLOGIES INC.
`
`** EXTERNAL EMAIL **
`
`I understand.
`
`Thank you.
`
`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: Ronald Richards <ron@ronaldrichards.com>
`Sent: Tuesday, April 27, 2021 2:18 PM
`To: Jeffrey Gersh <jgersh@stubbsalderton.com>; Todd Gregorian <TGregorian@fenwick.com>; Morani Stelmach
`<morani@ronaldrichards.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Viviana Boero Hedrick <vhedrick@stubbsalderton.com>;
`Lamken, Jeffrey <jlamken@mololamken.com>
`Subject: RE: PERSONALWEB TECHONLOGIES INC.
`
`[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.
`
`Mr. Gersh,
`
`You are not authorized to do anything post judgment. The case is on appeal. There is no jurisdiction with this Court
`pending the appeal except for collateral post judgment matters per Code.
`
`If Mr. Gregorian, who I do not know personally but feels free to call me by my first name and the wrong one at that, does
`not serve my office, please forward any documents.
`
`Your office is only engaged for the appeal. Please confirm receipt and acknowledgment of the above.
`
`
`
`
`
`Sincerely,
`
`Ronald Richards, Esq.
`
`

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`Case 5:18-md-02834-BLF Document 671-7 Filed 05/07/21 Page 5 of 7
`
`Law Offices of Ronald Richards & Associates, A.P.C.
`310-556-1001 Office
`310-277-3325 Fax
`www.ronaldrichards.com
`
`Mailing Address:
`P.O. Box 11480
`Beverly Hills, CA 90213
` ®
`
`
` **A multi jurisdictional practice with bar admissions on the East and West Coast**
` ***CONFIDENTIALITY NOTICE*** This electronic mail transmission has been sent by an attorney. This
`message and any files or text attached to it are intended only for the recipients named above, and contain
`information that may be confidential or privileged. If you are not an intended recipient, you must not read,
`copy, use or disclose this communication. Please also notify the sender by replying to this message, and then
`delete all copies of it from your system. Thank you.
`________________________________
`THINK GREEN. PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS MESSAGE. THANK YOU.
`
`
`
`
`
`From: Jeffrey Gersh <jgersh@stubbsalderton.com>
`Sent: Tuesday, April 27, 2021 2:16 PM
`To: Todd Gregorian <TGregorian@fenwick.com>; Ronald Richards <ron@ronaldrichards.com>; Morani Stelmach
`<morani@ronaldrichards.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Viviana Boero Hedrick <vhedrick@stubbsalderton.com>;
`Lamken, Jeffrey <jlamken@mololamken.com>
`Subject: RE: PERSONALWEB TECHONLOGIES INC.
`
`Todd
`
`As I told you before and I will tell you again, we are not counsel for Personal Web in any of the
`post judgment collection proceedings, only the appeals. Nothing has changed. We have never
`agreed to accept service for the client, verbally or otherwise.
`
`JG
`
`
`Jeffrey F. Gersh
`Partner, Stubbs Alderton & Markiles, LLP
`818.444.9222 (voice/text/fax) | jgersh@stubbsalderton.com
`
`

`

`Case 5:18-md-02834-BLF Document 671-7 Filed 05/07/21 Page 6 of 7
`
`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: Tuesday, April 27, 2021 2:03 PM
`To: Ronald Richards <ron@ronaldrichards.com>; Morani Stelmach <morani@ronaldrichards.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Jeffrey Gersh <jgersh@stubbsalderton.com>; Viviana Boero
`Hedrick <vhedrick@stubbsalderton.com>; Lamken, Jeffrey <jlamken@mololamken.com>
`Subject: RE: PERSONALWEB TECHONLOGIES INC.
`
`[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.
`
`Ron,
`
`Please let me know when you are retained. Until then we will continue to deal with PersonalWeb’s counsel of record (the
`Stubbs Alderton attorneys cc’ed), who have not withdrawn from the case. The Court has ordered that PersonalWeb
`produce its bank and financial account information by May 7 and its remaining financial records within 30 days.
`
`
`Todd Gregorian
`Fenwick | Partner | 415-875-2402 | tgregorian@fenwick.com
`
`
`
`From: Ronald Richards <ron@ronaldrichards.com>
`Sent: Monday, April 26, 2021 3:39 PM
`To: Todd Gregorian <TGregorian@fenwick.com>
`Cc: Morani Stelmach <morani@ronaldrichards.com>
`Subject: PERSONALWEB TECHONLOGIES INC.
`
`** EXTERNAL EMAIL **
`
`Dear Mr. Gregorian,
`
`Our firm is going to be retained in the next day or two to handle any post judgment matters you bring. This is not my only
`file but we will respond as quickly as possible to any demands upon legal service.
`
`As you know, post judgment matters are handled by the magistrate and we are not going to appear in the underlying case
`except for post judgment motions if for some reason we need to involve the Court.
`
`Hopefully that won’t be necessary.
`
`Presently the case is on appeal and the divestiture rule applies.
`
`There is no rush to do anything pending the outcome of that appeal.
`
`Once we are retained, I am happy to have a call with you to discuss this matter.
`
`
`Sincerely,
`
`

`

`Case 5:18-md-02834-BLF Document 671-7 Filed 05/07/21 Page 7 of 7
`
`
`Ronald Richards, Esq.
`Law Offices of Ronald Richards & Associates, A.P.C.
`310-556-1001 Office
`310-277-3325 Fax
`www.ronaldrichards.com
`
`Mailing Address:
`P.O. Box 11480
`Beverly Hills, CA 90213
` ®
`
`
` **A multi jurisdictional practice with bar admissions on the East and West Coast**
` ***CONFIDENTIALITY NOTICE*** This electronic mail transmission has been sent by an attorney. This
`message and any files or text attached to it are intended only for the recipients named above, and contain
`information that may be confidential or privileged. If you are not an intended recipient, you must not read,
`copy, use or disclose this communication. Please also notify the sender by replying to this message, and then
`delete all copies of it from your system. Thank you.
`________________________________
`THINK GREEN. PLEASE CONSIDER THE ENVIRONMENT BEFORE YOU PRINT THIS MESSAGE. THANK YOU.
`
`
`
`
`