Case 5:18-md-02834-BLF Document 688-6 Filed 05/25/21 Page 1 of 4
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`Exhibit D
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`Exhibit D
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`Case 5:18-md-02834-BLF Document 688-6 Filed 05/25/21 Page 2 of 4
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`From:
`To:
`Cc:
`Subject:
`Date:
`
`Michael Sherman
`Todd Gregorian
`Jeffrey Gersh; Viviana Boero Hedrick; Ronald Richards Esq. (ron@ronaldrichards.com)
`FW: PWeb v. Amazon
`Wednesday, May 19, 2021 6:52:03 PM
`
`Todd – so no one is wasting the Court’s time on this, what possibly could be the basis on which you
`will be opposing a motion to withdraw when the client has told you through his new attorney he has
`engaged other counsel and we have no authority to act? Please send me whatever authority you
`have to support your position.
`Thanks
`Michael
`
`From: Todd Gregorian <TGregorian@fenwick.com>
`Sent: Wednesday, May 19, 2021 6:45 PM
`To: Michael Sherman <masherman@stubbsalderton.com>
`Cc: Jeffrey Gersh <jgersh@stubbsalderton.com>; Viviana Boero Hedrick
`<vhedrick@stubbsalderton.com>
`Subject: RE: PWeb v. Amazon
`
`[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.
`
`Michael,
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`We intend to oppose the motion to withdraw and decline your request. As you know, your client can
`easily put a stop to all post-judgment activity by posting a supersedeas bond.
`
`Todd Gregorian
`Fenwick | Partner | 415-875-2402 | tgregorian@fenwick.com
`
`
`
`From: Michael Sherman <masherman@stubbsalderton.com>
`Sent: Wednesday, May 19, 2021 8:43 PM
`To: Todd Gregorian <TGregorian@fenwick.com>
`Cc: Jeffrey Gersh <jgersh@stubbsalderton.com>; Viviana Boero Hedrick
`<vhedrick@stubbsalderton.com>
`Subject: PWeb v. Amazon
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`** EXTERNAL EMAIL **
`
`Dear Todd:
`
` I
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` had called you earlier today and left my mobile vm number, both on
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`
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`Case 5:18-md-02834-BLF Document 688-6 Filed 05/25/21 Page 3 of 4
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`my vm message to you and in my follow up e-mail. This is what I had
`planned on sharing with you:
`
`The Court’s statements at last week’s CMC lead our office to conclude
`that PersonalWeb may not need counsel to represent it in post-
`judgment collection matters and could represent itself. That resulted in
`our filings of last week and this week, ie., to substitute PersonalWeb for
`our law offices.
`
`In today’s Court order the Court denied any motion to substitute
`counsel. We do not read anything into today’s Court order as
`prohibiting our firm’s withdrawal, in contrast to substitution.
`Accordingly, we will be filing a motion to withdraw, and I anticipate that
`motion being filed tomorrow or Friday morning, at the latest.
`
`Because, as between our law firm and PersonalWeb, our law firm has
`been told it lacks authority to engage in any post-judgment collection
`activities on behalf of PersonalWeb – a directive you are aware of – our
`law office is not in a position to provide any interrogatory responses or
`responses to document requests, directed to post-judgment collection
`issues. Given our client’s retention of other counsel to deal with these
`matters, Stubbs Alderton & Markiles, LLP is not in a position to provide
`discovery responses; we have no direction from our client on the issue
`and lack authority as a practical matter.
`
`Given the Court’s sua sponte order of earlier today, it does not seem as
`though Judge Freeman is going to permit moss to grow on these
`issues. In light of all that has transpired and that will be transpiring, as
`a matter of professional courtesy I ask that you hold in temporary
`abeyance the issues of responses to written discovery. Thank you for
`your consideration.
`
`
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`Case 5:18-md-02834-BLF Document 688-6 Filed 05/25/21 Page 4 of 4
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`
`Michael
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`
`
`
`
` ,
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` (2) “substitution” of counsel to PersonalWeb would not be permitted,
`and (3) the Court has not decided in its order of earlier today that our
`law firm would be prohibited from withdrawing as counsel for
`PersonalWeb at the trial court level.
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` V-card
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` Bio
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` Website
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`
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`Michael A. Sherman
`Partner
`masherman@stubbsalderton.com
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`
`The information
`contained in this e-
`mail message is
`intended only for
`the personal and
`confidential use of
`the recipient(s)
`1316 3rd Street Promenade, Suite 107
`named above.
`Santa Monica, CA 90401
`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.
`To ensure compliance with requirements imposed by the U.S. Internal Revenue Service, we inform you that any tax advice contained in
`this communication (including any attachments) was not intended or written to be used, and cannot be used, by any taxpayer for the
`purpose of (1) avoiding tax-related penalties under the U.S. Internal Revenue Code or (2) promoting, marketing or recommending to
`another party any tax-related matters addressed herein.
`
`
`Stubbs Alderton & Markiles, LLP
`15260 Ventura Blvd., 20th Floor
`Sherman Oaks, CA 91403
`
`Bus/Text/Fax: 818.444.4528
`
`
`
`
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