`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 1 of 10
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`EXHIBIT D
`EXHIBIT D
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`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 2 of 10
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`Christopher Lavin
`From:
`Michael Sherman <masherman@stubbsalderton.com>
`Sent:
`Tuesday, December 6, 2022 9:29 AM
`To:
`Todd Gregorian; Christopher Lavin
`Cc:
`Jeffrey Gersh; McCormick, Patrick Emerson
`Subject:
`RE: PWeb - Amazon - Document issues
`
`** EXTERNAL EMAIL **
`
`I anticipate responding later this week/early next week – certainly not later than December 12
`
`
`Michael A. Sherman
`Partner, Stubbs Alderton & Markiles, LLP
`Chair, Business Litigation Practice
`818.444.4528 (voice/text/fax) | 818.631.9109 (Mobile) | masherman@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: Tuesday, December 6, 2022 8:39 AM
`To: Michael Sherman <masherman@stubbsalderton.com>; Christopher Lavin <CLavin@fenwick.com>
`Cc: Jeffrey Gersh <jgersh@stubbsalderton.com>; McCormick, Patrick Emerson <PMcCormick@lewisroca.com>
`Subject: RE: PWeb ‐ Amazon ‐ Document issues
`
`
`WARNING: This email originated outside of Stubbs Alderton & Markiles, LLP. Do not click on any links or
`attachments unless you know the sender.
`
`Michael,
`
`When should we expect to get your response with the requested information?
`
`Thank you,
`‐t
`
`From: Todd Gregorian
`Sent: Monday, December 5, 2022 2:51 PM
`To: Michael Sherman <masherman@stubbsalderton.com>; Christopher Lavin <CLavin@fenwick.com>
`Cc: Jeffrey Gersh <jgersh@stubbsalderton.com>; McCormick, Patrick Emerson <PMcCormick@lewisroca.com>
`Subject: RE: PWeb ‐ Amazon ‐ Document issues
`
`Michael,
`
`1
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`
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`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 3 of 10
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` I
`
` do not follow your message but do not believe that it requires a response. Please provide the requested information
`so that we may meet and confer on the outstanding disputes. We will work in good faith with you to reach agreements
`where possible, but we need the information to understand what Stubbs has collected and what it has excluded from its
`collection.
`
`Thank you,
`‐t
`
`
`
`From: Michael Sherman <masherman@stubbsalderton.com>
`Sent: Monday, December 5, 2022 2:47 PM
`To: Christopher Lavin <CLavin@fenwick.com>
`Cc: Jeffrey Gersh <jgersh@stubbsalderton.com>; McCormick, Patrick Emerson <PMcCormick@lewisroca.com>; Todd
`Gregorian <TGregorian@fenwick.com>
`Subject: RE: PWeb ‐ Amazon ‐ Document issues
`
`** EXTERNAL EMAIL **
`
`Just so we are clear, by November 14 we had expended enormous time in implementing a search protocol and had
`already considered and rejected the scores of search terms that Lewis Roca had passed on to us earlier (from your
`offices) which made zero sense as applied to our law firm search; this is the whipsawing I was referring to earlier. To be
`even clearer, we proceeded efficiently and quickly, however I must point out that neither myself nor my firm hold
`ourselves out as “short order cooks”.
`
`
`
`
`
`
`Michael A. Sherman
`Partner, Stubbs Alderton & Markiles, LLP
`Chair, Business Litigation Practice
`818.444.4528 (voice/text/fax) | 818.631.9109 (Mobile) | masherman@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: Christopher Lavin <CLavin@fenwick.com>
`Sent: Monday, December 5, 2022 2:39 PM
`To: Michael Sherman <masherman@stubbsalderton.com>
`Cc: Jeffrey Gersh <jgersh@stubbsalderton.com>; McCormick, Patrick Emerson <PMcCormick@lewisroca.com>; Todd
`Gregorian <TGregorian@fenwick.com>
`Subject: RE: PWeb ‐ Amazon ‐ Document issues
`
`
`2
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`
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`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 4 of 10
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`WARNING: This email originated outside of Stubbs Alderton & Markiles, LLP. Do not click on any links or
`attachments unless you know the sender.
`
`Michael,
`
`Here’s the list of seven initial priority categories that we provided to Lewis Roca on Nov. 10‐11, which we were informed
`that Stubbs Alderton has had since Nov. 14th:
`
`
`Initial Priority Categories:
`
`
`1. Any responsive documents or communications for which Mr. Markiles is a custodian, sender, recipient.
`2. Documents concerning the corporate or investment structure of PersonalWeb, including the purpose of its
`structure vis a vis its investors and principals, and any advice provided by Stubbs Alderton or other professionals
`concerning those subjects.
`Information on the loans between PersonalWeb and the secured creditors, including but not limited to, why
`PersonalWeb entered into the loans, negotiations of the loans, extensions of the loans, and the decisions to
`foreclose on the loans, including any advice provided by Stubbs Alderton or other professionals concerning
`those subjects.
`Information on the receivership, including the possibly of entering into a receivership, the decision to enter into
`receivership, purpose of the receivership, and winding‐up/termination of the receivership, including any advice
`provided by Stubbs Alderton or other professionals concerning those subjects.
`5. Documents responsive to ROG No. 9, i.e., communications regarding a potential for a fee award against
`PersonalWeb in seeking to monetize its patent assets. ROG No. 9 asks for an identification of these
`communications by Bates number, and they are also responsive to at least RFPs 22, 29, 35, 41, and 42, and
`potentially others.
`6. Any communications between Stubbs Alderton and Ronald Richards.
`7. All agreements between Stubbs Alderton and PersonalWeb or its principals.
`
`3.
`
`4.
`
`
`We look forward to receiving your responses.
`
`Regards,
`Chris
`
`Chris Lavin
`Fenwick | Associate | +1 415‐875‐2287 | CLavin@fenwick.com | Admitted to practice in California.
`
`From: Michael Sherman <masherman@stubbsalderton.com>
`Sent: Monday, December 5, 2022 1:16 PM
`To: Christopher Lavin <CLavin@fenwick.com>
`Cc: Jeffrey Gersh <jgersh@stubbsalderton.com>; McCormick, Patrick Emerson <PMcCormick@lewisroca.com>; Todd
`Gregorian <TGregorian@fenwick.com>
`Subject: RE: PWeb ‐ Amazon ‐ Document issues
`
`** EXTERNAL EMAIL **
`
`Thank you for your transmission, Chris. I have read it once, very quickly, and one thing did jump out at me, namely,
`what you refer to as “the seven priority categories.” Pardon me, however we’ve not communicated directly on these
`matters at all up until the past few business days. Can you please provide clarity as to what you mean by “seven priority
`categories”? It is true that I have had some interaction with the Lewis Roca attorneys on related issues, and I’m
`generally aware of a hugely burdensome list of key word searches that Lewis Roca had provided us that our law firm
`could not (and did not) execute on, and then I have general awareness of Lewis Roca passing on other messages
`3
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`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 5 of 10
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`purporting to tell us what you want, while we were mid‐stream in our document review and we were not at that point
`about to be whipsawed and provided different “marching orders”. But what means “the seven priority
`categories”? Once I know what you mean, we will consider.
`
`
`
`Michael A. Sherman
`Partner, Stubbs Alderton & Markiles, LLP
`Chair, Business Litigation Practice
`818.444.4528 (voice/text/fax) | 818.631.9109 (Mobile) | masherman@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: Christopher Lavin <CLavin@fenwick.com>
`Sent: Monday, December 5, 2022 1:02 PM
`To: Michael Sherman <masherman@stubbsalderton.com>
`Cc: Jeffrey Gersh <jgersh@stubbsalderton.com>; McCormick, Patrick Emerson <PMcCormick@lewisroca.com>; Todd
`Gregorian <TGregorian@fenwick.com>
`Subject: RE: PWeb ‐ Amazon ‐ Document issues
`
`
`WARNING: This email originated outside of Stubbs Alderton & Markiles, LLP. Do not click on any links or
`attachments unless you know the sender.
`
`Michael,
`
`Please provide Stubbs Alderton’s written positions on the following issues:
`
`According to PersonalWeb, Stubbs Alderton conducted its search as follows:
`
`SAM’s Parameters:
`1. SAM searched its mail‐server in the mailboxes for the following users:
`• Ana Escamilla
`• Blaine O’Malley
`• Christopher Wolffe
`• David Harris
`• Greg Akselrud
`• Heather Cory
`• James Ponce
`• James Sedivy
`• Jeffrey Gersh
`• Jonathan Friedman
`• Karine Akopchikyan
`• Liz Saal De Casas
`• Louis Wharton
`• Michael Sherman
`• Monique Gonzaque‐Dirks
`
`4
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`
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`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 6 of 10
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`• Murray Markiles
`• Neil Elan
`• Nicholas Feldman
`• Roberta Myers
`• Sandy Seth
`• Sean Greaney
`• Stanley Thompson
`• Stephanie Hughes
`• Stephen Carroll
`• Tami Solomon
`• Ted Maceiko
`• Virginia Miller
`• Viviana Hedrick
`• Wes Monroe
`
`2. And, the keywords:
`• “Personal Web”
`• “personalweb”
`• “ pw ”
`• “ pw.”
`
`3. And SAM searched for the following participants (to/from/cc/bcc):
`• anything@brilliantdigital.com
`• anything@pweb.com
`• anything@ronaldrichards.com
`• mmarkiles@ecamail.com
`• Kevin Bermeister
`
`
`
`
`
`
`
`(1) Are these parameters correct as PersonalWeb has reported them?
`
`(2) It’s unclear how Stubbs Alderton collected responsive documents – for a document to have been collected, does
`it have to hit on (1) (user), (2) (keyword), AND (3) (participant)?
`
`(3) Why did Stubbs only search email and not its other paper and electronic files?
`
`(4) How many documents that hit on a keyword were withheld because Stubbs Alderton was purportedly acting on
`behalf of a different client? Will such documents be logged?
`
`(5) How are any documents pertaining to Stubbs Alderton’s work for both PersonalWeb and another entity, e.g.,
`Claria or ECA, being treated? Are they being provided to PersonalWeb for possible production, or withheld
`because although they are responsive and belong to PersonalWeb, another related entity has an interest in
`them? If they’re being treated as the latter, will such documents be logged? On this issue, we would remind
`you that any party to a joint representation or common interest communication may waive the privilege, which
`PersonalWeb has done here.
`
`(6) There is no basis for Stubbs Alderton’s artificial July 30, 2021 date cut‐off – the requests are continuing in nature
`through at least the present day. Please confirm that Stubbs Alderton will search for and produce documents
`through the present, or explain the basis for the cutoff.
`
`For the following issues we can discuss on a call without the need for an advance written response, but would
`appreciate one if you know your position:
`
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`5
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`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 7 of 10
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`(7) Will Stubbs Alderton agree to conduct a search for the seven priority categories that Amazon has identified? If
`not, why not?
`
`(8) The keywords limited to PersonalWeb, PW, and the like, are insufficient – they do not capture responsive
`documents that don’t literally mention PersonalWeb by name (and moreover, do not even capture “PWeb,” an
`often‐used shorthand that we’ve seen in PersonalWeb documents). We would like Stubbs Alderton to conduct a
`broader set of search terms based on our priority categories – if we propose such search terms, will Stubbs
`Alderton incorporate them into its search for documents?
`
`(9) The participants e‐mail domains for the PersonalWeb investors (i.e., brilliantdigital.com and ecamail.com) are
`also insufficient. Why were the e‐mail domains for Claria (clariainnovations.com) and Monto (Note: Ronnie
`Dyne used @stbm.com.au) not included? Please confirm that Stubbs Alderton will search Claria and Monto ‐
`related e‐mail domains.
`
`
`We can discuss scheduling a call after we receive Stubbs Alderton’s positions.
`
`Further, I attach the Court’s order, dated December 2, 2022.
`
`Regards,
`Chris
`
`Chris Lavin
`Fenwick | Associate | +1 415‐875‐2287 | CLavin@fenwick.com | Admitted to practice in California.
`
`‐‐‐‐‐Original Message‐‐‐‐‐
`From: Michael Sherman masherman@stubbsalderton.com
`Sent: Friday, December 2, 2022 10:11 AM
`To: Todd Gregorian TGregorian@fenwick.com
`Cc: Jeffrey Gersh jgersh@stubbsalderton.com; Patrick Emerson McCormick, CIPP/US (pmccormick@lewisroca.com)
`pmccormick@lewisroca.com; Christopher Lavin CLavin@fenwick.com
`Subject: RE: PWeb ‐ Amazon ‐ Document issues
`
`
`** EXTERNAL EMAIL **
`
`Todd
`
`Your tone is offensive and your content erroneous. For over a month SAM has received multiple, inconsistent and at
`times incomprehensible, relayed statements about what Amazon would like. You know full well how to get in touch
`with both me and my partner Jeff Gersh; I have no idea why you chose not to.
`
`Send me all your questions, directly.
`
`MAS
`
`
`
`‐‐‐‐‐Original Message‐‐‐‐‐
`From: Todd Gregorian <TGregorian@fenwick.com>
`Sent: Friday, December 2, 2022 9:49 AM
`To: Michael Sherman <masherman@stubbsalderton.com>
`
`6
`
`
`
`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 8 of 10
`
`Cc: Jeffrey Gersh <jgersh@stubbsalderton.com>; Patrick Emerson McCormick, CIPP/US (pmccormick@lewisroca.com)
`<pmccormick@lewisroca.com>; Christopher Lavin <CLavin@fenwick.com>
`Subject: Re: PWeb ‐ Amazon ‐ Document issues
`
`WARNING: This email originated outside of Stubbs Alderton & Markiles, LLP. Do not click on any links or attachments
`unless you know the sender.
`________________________________
`
`Michael,
`
`We will take a call at that time provided Stubbs provides written answers to our questions in advance. We have
`attempted for a month to get fulsome information about your collection and have been met only with stonewalling and
`delay. Let me know if you need us to relay our questions to you again. We otherwise await your response.
`
`Thanks,
`‐t
`
`On Dec 1, 2022, at 3:08 PM, Michael Sherman <masherman@stubbsalderton.com> wrote:
`
`
`** EXTERNAL EMAIL **
`
`Todd
`
`Willing to schedule a call to discuss. I do think it is unfair to conflate anything approaching lack of candor with the fact
`that over the approximate two weeks leading to the Thanksgiving Holiday, myself, Jeff Gersh and several office
`support/paralegals expended hundreds of hours, pulling an enormous quantity of information that we transmitted to
`Lewis Roca on November 23.
`
`Both Jeff and I would be available on Monday for a call if you wish. Before that time we will attempt to review the
`myriad of questions. Best time for both of us would be at 2:30pm on Monday.
`
`Michael
`
`
`
`Michael A. Sherman
`Partner, Stubbs Alderton & Markiles, LLP Chair, Business Litigation Practice
`818.444.4528 <tel:8184444528%09%09%09> (voice/text/fax) | 818.631.9109 <tel:8186319109%09%09%09> (Mobile) |
`masherman@stubbsalderton.com <mailto:masherman@stubbsalderton.com%09%09%09>
`https://urldefense.com/v3/__https://linkprotect.cudasvc.com/url?a=https*3a*2f*2fwww.stubbsalderton.com&c=E,1,gd
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`eJJchWJLWgjCww_eZRvWuvTXTh9n2LPvk3AZCoxz9XsJVhG2kpFn5ZJsK8KTnIO$
`<https://urldefense.com/v3/__https://www.stubbsalderton.com__;!!HJT62s_lzg!ywxR7LyleoHCSKEq3Tjy‐
`Mfjcsz6j2OguxlHMWKda6AF6qNKj0PBdI3GReQ7SLOycjqdjXX0ECUHbofCfFm‐eeWiTas$> | Attorney
`Bio<https://urldefense.com/v3/__https://stubbsalderton.com/attorney/michael‐
`sherman__;!!HJT62s_lzg!ywxR7LyleoHCSKEq3Tjy‐
`Mfjcsz6j2OguxlHMWKda6AF6qNKj0PBdI3GReQ7SLOycjqdjXX0ECUHbofCfFm‐q0uFVWU$>
`15260 Ventura Blvd., 20th FL, Sherman Oaks, CA
`91403<https://urldefense.com/v3/__https://goo.gl/maps/jAKqdopWJbPom6QF6__;!!HJT62s_lzg!ywxR7LyleoHCSKEq3Tj
`y‐Mfjcsz6j2OguxlHMWKda6AF6qNKj0PBdI3GReQ7SLOycjqdjXX0ECUHbofCfFm‐HQADGEY$>
`
`7
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`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 9 of 10
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`<https://urldefense.com/v3/__https://twitter.com/StubbsAlderton__;!!HJT62s_lzg!ywxR7LyleoHCSKEq3Tjy‐
`Mfjcsz6j2OguxlHMWKda6AF6qNKj0PBdI3GReQ7SLOycjqdjXX0ECUHbofCfFm‐wJfe1gU$>
`<image002.gif>
` <https://urldefense.com/v3/__https://www.linkedin.com/in/michael‐sherman‐
`954a9689/__;!!HJT62s_lzg!ywxR7LyleoHCSKEq3Tjy‐
`Mfjcsz6j2OguxlHMWKda6AF6qNKj0PBdI3GReQ7SLOycjqdjXX0ECUHbofCfFm‐prNriBk$>
`<image003.gif>
`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: Thursday, December 1, 2022 3:00 PM
`To: Jeffrey Gersh <jgersh@stubbsalderton.com>
`Cc: Michael Sherman <masherman@stubbsalderton.com>; Patrick Emerson McCormick, CIPP/US
`(pmccormick@lewisroca.com) <pmccormick@lewisroca.com>; Christopher Lavin <CLavin@fenwick.com>
`Subject: RE: PWeb ‐ Amazon ‐ Document issues
`
`
`WARNING: This email originated outside of Stubbs Alderton & Markiles, LLP. Do not click on any links or attachments
`unless you know the sender.
`
`________________________________
`Jeff,
`
`Patrick has reached out to us to let us know the report of 200 documents was due to a technical error. We plan to
`correct that with the Court, including also reporting updated information regarding PersonalWeb’s production separate
`from the Stubbs Alderton collection. The other issues with Stubbs’ collection we still plan to address with the Court. We
`have posed numerous questions to PersonalWeb concerning the Stubbs collection, only several of which have been
`answered by Stubbs. Everyone here would appreciate a bit more candor from your firm.
`
`Why don’t you provide the information that we have requested of you through Lewis Roca, and we can then schedule a
`call to see if we can reach agreement on an adequate search and production. If so, Amazon will withdraw its status
`conference request.
`
`Thank you,
`‐t
`
`From: Jeffrey Gersh <jgersh@stubbsalderton.com<mailto:jgersh@stubbsalderton.com>>
`Sent: Thursday, December 1, 2022 2:52 PM
`To: Todd Gregorian <TGregorian@fenwick.com<mailto:TGregorian@fenwick.com>>; Christopher Lavin
`<CLavin@fenwick.com<mailto:CLavin@fenwick.com>>
`Cc: Michael Sherman <masherman@stubbsalderton.com<mailto:masherman@stubbsalderton.com>>; Patrick Emerson
`McCormick, CIPP/US (pmccormick@lewisroca.com<mailto:pmccormick@lewisroca.com>)
`<pmccormick@lewisroca.com<mailto:pmccormick@lewisroca.com>>
`Subject: PWeb ‐ Amazon ‐ Document issues
`
`** EXTERNAL EMAIL **
`Todd & Chris
`
`
`8
`
`
`
`Case 5:18-md-02834-BLF Document 828-5 Filed 01/03/23 Page 10 of 10
`
`I reached out to both of you (Todd yesterday and Chris today) to briefly discuss the recent request that you filed seeking
`a status conference relating to the documents SAM provided to PWeb’s counsel, Lewis Roca. From my reading of what
`you filed, I believe there is a misunderstanding of what SAM provided to Lewis Roca on November 23, 2022 vs what you
`received. It appears that you only received 200 documents when you were expecting much more. We provided over
`20,000 documents (3.65 GB I believe) to Lewis Roca on November 23, as Michael said we would. For some reason
`something happened in the transmission of documents that we learned about yesterday which is why I reached out to
`Todd. We are in the process of reproducing those documents in a manner that will hopefully avoid whatever the
`problem was that resulted in you not receiving what was provided to Lewis Roca.
`
`Please call me to discuss
`
`Jeff
`
`<image004.png>
`Jeffrey F. Gersh
`Partner, Stubbs Alderton & Markiles, LLP
`818.444.9222 <tel:8184449222%09%09%09> (voice/text/fax) | jgersh@stubbsalderton.com
`<mailto:jgersh@stubbsalderton.com%09%09%09>
`https://urldefense.com/v3/__https://linkprotect.cudasvc.com/url?a=https*3a*2f*2fwww.stubbsalderton.com&c=E,1,Y
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`LCgXoRR6vZOJZcaaEiwTKxCuZV7bUsXN9Izr‐QNP‐0tUFeUNpgric‐8$> | Attorney
`Bio<https://urldefense.com/v3/__https:/stubbsalderton.com/attorney/jeff‐
`gersh__;!!HJT62s_lzg!x6b8yNIF_VpOsY8LDAbYvDTRCkYJpPSmLCgXoRR6vZOJZcaaEiwTKxCuZV7bUsXN9Izr‐QNP‐
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`15260 Ventura Blvd., 20th FL, Sherman Oaks, CA
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