EXHIBIT 5 

 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 1 of 22
1

From: Conway, Shanti Sadtler

Sent: Tuesday, September 22, 2020 1:57 PM

To: Stephanie Vazquez

Cc: Brian Gilchrist; Shelley Hotz; #SHGroup-1Hotel; Gavin Gaukroger; Luis Torres; Christina 

M. Perry

Subject: RE: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group 

Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

Dear Stephanie -- I’m writing to follow up on the below. If we do not receive a response, including 

amended/supplemental discovery responses, we will have no choice but to move to compel. 

Best Regards, 

Shanti 

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Conway, Shanti Sadtler 

Sent: Friday, September 18, 2020 2:05 PM 

To: 'Stephanie Vazquez' <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: RE: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU 

Dear Stephanie, 

As the Association’s Board President, Mr. Bostany presumably would have these documents as well. It is possible that 

Mr. Bostany could have documents that the Association does not have. We have no way of knowing. The simple 

solution here, and what is required under the Federal Rules, is for Mr. Bostany to agree to search for and produce any 

responsive documents that are in his possession, custody, or control. We understand from your below response that he 

is refusing to do so. 

Do you have an update as to Defendants’ amended/supplemental responses to the Interrogatories and RFAs? 

Best Regards, 

Shanti 

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 2 of 22
2

-----------------------------------------------------

shanti.conway@kirkland.com

From: Stephanie Vazquez <svazquez@allendyer.com> 

Sent: Friday, September 18, 2020 1:51 PM 

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: RE: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU 

Hello Shanti, Regardi ng Mr. Bostany’s responses to RF P Nos . 6-7 , 13-15, 33, a nd 36, Mr. Bosta ny stands by the obje ctions provide d for each re sponse. T hese requests are for docume nts that are all clearly Association records not personal records of Mr. Bostany. S 

Hello Shanti, 

Regarding Mr. Bostany’s responses to RFP Nos. 6-7, 13-15, 33, and 36, Mr. Bostany stands by the objections provided for 

each response. These requests are for documents that are all clearly Association records not personal records of Mr. 

Bostany. See Requests for Production at Issue below: 

6. DOCUMENTS sufficient to show all investors, shareholders, stakeholders, condominium association 

members, BOARD members, or others having an interest in the ASSOCIATION, the ASSOCIATION’S GOODS AND 

SERVICES, and/or the ASSOCIATION’S CLAIMED MARK. 

7. DOCUMENTS sufficient to show the founding or formation of the ASSOCIATION and the scope of its 

authority. 

13. DOCUMENTS sufficient to show all annual sales for the ASSOCIATION’S GOODS AND SERVICES in the 

United States. 

14. DOCUMENTS sufficient to show all annual expenditures by the ASSOCIATION in connection with 

advertising, promoting, and/or marketing the ASSOCIATION’S GOODS AND SERVICES and/or the ASSOCIATION’S 

CLAIMED MARK. 

15. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO any MARKET RESEARCH or SURVEY 

CONCERNING or REFERRING OR RELATING TO the ASSOCIATION’S CLAIMED MARK, the term “1,” and/or SH 

GROUP’S MARKS in the United States. 

33. All DOCUMENTS CONCERNING or REFERRING OR RELATING TO any profits earned by the ASSOCIATION 

from the sale of goods and services under the ASSOCIATION’S CLAIMED MARK in the United States. 

36. All DOCUMENTS referenced, relied upon or otherwise consulted in preparing the PETITION FOR 

CANCELLATION. 

Plaintiff has served these same requests on the Association in RFP 6-7, 13-15, 36 and 39 and the Association has agreed 

to search and produce documents as provided in its response to each request. It is unclear what more Plaintiff is seeking 

to gain as the Association has already agreed to search for and produce existing responsive documents. We hope this 

resolves your concerns. 

Best regards, 

Stephanie Vazquez

Registered Patent Attorney 

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 3 of 22
3

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorney-client privilege 

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addressee or an authorized 

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, dissemination, distribution, 

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Thank you.

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Thursday, September 17, 2020 1:42 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: RE: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU 

Dear Stephanie, 

With respect to Mr. Bostany’s responses to RFP Nos. 6-7, 13-15, 33, and 36, is your position that such documents are not 

in Mr. Bostany’s possession, custody, or control? If that is the case, can you please confirm that there are no documents 

that are response to RFP Nos. 6-7, 13-15, 33, and 36 that are in Mr. Bostany’s possession, custody, or control? Please 

clarify so we can assess whether a motion to compel is needed. 

With respect to the RFAs and Interrogatories, your prior email had said September 16, and I confirmed that date in my 

subsequent email, which you did not correct. Accordingly, we expected those amended/supplemental responses 

yesterday. Regardless, we look forward to receiving them today. 

Best Regards, 

Shanti 

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Stephanie Vazquez <svazquez@allendyer.com> 

Sent: Thursday, September 17, 2020 11:34 AM 

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: RE: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU 

Hello Shanti, 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 4 of 22
4

As you know, my September 10th email stated that we anticipated needing until Thursday to serve Defendants’ 

amended responses to the RFA and Interrogatories. The amended responses to the RFA and Interrogatories have been 

presented to our clients for approval and we will serve those once approved. Regarding Mr. Bostany’s responses to RFP 

No. 6-7, 13-15, 33, and 36, the service email sent on September 15th which included Mr. Bostany’s amended responses 

to the RFP, clearly notifies Plaintiff that “responses to Requests for Production No. 6-7, 13-15, 33 and 36 directed to Mr. 

Bostany were not amended. Mr. Bostany wishes to maintain his original responses.” 

Best regards, 

Stephanie Vazquez

Registered Patent Attorney 

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorney-client privilege 

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addressee or an authorized 

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, dissemination, distribution, 

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Thank you.

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Thursday, September 17, 2020 7:44 AM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: RE: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU 

Dear Stephanie, 

We have not received Defendants’ supplemental/amended responses to the RFAs and Interrogatories, although you 

agreed to provide them by yesterday, September 16. We also still await Mr. Bostany’s amended responses to RFP Nos. 

6-7, 13-15, 33, and 36, which you agreed to serve by September 14, and which I followed up about in my below email on 

September 15. You have provided not responded or provided any explanation as to the delay for these various 

responses. When will you serve them? 

 

 

Best Regards, 

Shanti 

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 5 of 22
5

-----------------------------------------------------

shanti.conway@kirkland.com

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Tuesday, September 15, 2020 10:37 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: RE: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU 

Dear Stephanie, 

As reflected in your letter of August 31, 2020, Mr. Bostany agreed to amend his objections and responses to RFP Nos. 6-

7, 13-15, 33, and 36, and search for and produce any responsive documents. This is not reflected in the amended 

responses that were served this evening. In particular, Mr. Bostany’s responses to RFP Nos. 6-7, 13-15, 33, and 36 still 

do not state whether or not he will search for and produce responsive documents, but rather only provide 

objections. Please correct the responses accordingly. 

Best Regards, 

Shanti 

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Monday, September 14, 2020 7:49 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: Re: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU 

Dear Stephanie,

What is the cause of the delay? It appears that each time you agree to get us something by a certain date you do not, which is not 

productive. If not tonight, when will you provide the responses? 

Best Regards, 

Shanti 

On Sep 14, 2020, at 7:38 PM, Stephanie Vazquez <svazquez@allendyer.com> wrote: 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 6 of 22
6

Hello Shanti,

We are experiencing some unanticipated delays in getting the amended responses to the Requests for 

Production directed to the Association and Mr. Bostany approved by our clients. In the event we cannot 

get those to you this evening we will continue our efforts to get them served to you by tomorrow.

Best regards,

<image001.png> Stephanie Vazquez

Registered Patent Attorney

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorney-client privilege 

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addressee or an authorized 

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, dissemination, distribution, 

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Thank you.

From: "Conway, Shanti Sadtler" <shanti.conway@kirkland.com> 

Date: Thursday, September 10, 2020 at 8:08 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>, Shelley Hotz <shotz@allendyer.com>, 

#SHGroup-1Hotel <shgroup-1hotel@kirkland.com>, Gavin Gaukroger 

<ggaukroger@bergersingerman.com>, Luis Torres <LTorres@bergersingerman.com>, "Christina 

M. Perry" <CPerry@bergersingerman.com> 

Subject: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global 

IP Holdings - FLSD Case No. 1:20-cv-22423-UU

Thank you, Stephanie. We look forward to receiving the amended/supplemental responses by 

September 14 and 16, as applicable. 

Best Regards,

Shanti

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Stephanie Vazquez <svazquez@allendyer.com> 

Sent: Thursday, September 10, 2020 3:20 PM 

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 7 of 22
7

<shgroup-1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU

 

Hello Shanti,

We will work to get the amended responses to you as soon as possible. We can serve amended 

responses to the Requests for Production directed to the Association and Mr. Bostany by September 

14th, as agreed to. However, as we have agreed to amend/supplement more of the Defendants’ 

responses to solve the remaining issues concerning the interrogatory requests and the requests for 

admission, we do anticipate needing some additional time, until Thursday, September 16, for our clients 

to review and approve these amended responses to the Interrogatory Requests and Requests for 

Admission directed to the Association and Mr. Bostany.

Best regards,

<image002.png> Stephanie Vazquez

Registered Patent Attorney

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorney-client privilege 

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addressee or an authorized 

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, dissemination, distribution, 

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Thank you.

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Thursday, September 10, 2020 2:31 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel 

<shgroup-1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP 

Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Dear Stephanie,

We appreciate Defendants’ agreement to amend/supplement its various discovery responses. Can you 

please confirm that you will provide such amended/supplemental responses by September 14, along 

with the other amended/supplemental responses Defendants have agreed to provide?

Best Regards,

Shanti

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 8 of 22
8

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Stephanie Vazquez <svazquez@allendyer.com> 

Sent: Thursday, September 10, 2020 2:21 PM 

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel 

<shgroup-1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU

 

Hello Shanti,

In regard to the remaining issues outlined in your September 1st correspondence, the Association 

agrees to provide amended responses to RFA 4-17. Defendants also agree to serve amended responses 

to RFA Nos. 2-3, 18-38, 89-90 directed to the Association and to RFA Nos. 4, 6, 21-41, 93-94 directed to 

Mr. Bostany.

Regarding Interrogatory No. 2 to Mr. Bostany, we maintain our objection that the interrogatory as 

presented is overly board but will endeavor to provide an amended response. 

Lastly, regarding Interrogatories 3-5 and 7 directed to the Association, we maintain that they have been 

fully answered in compliance with Rule 33 and that it is equally as burdensome for the parties to sort 

through the records. However, in an effort to avoid unnecessary motion practice the Association agrees 

to serve amended responses to Interrogatories 3-5 and 7.

Best regards,

<image002.png> Stephanie Vazquez

Registered Patent Attorney

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorney-client privilege 

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addressee or an authorized 

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, dissemination, distribution, 

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Thank you.

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 9 of 22
9

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Wednesday, September 9, 2020 9:05 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel 

<shgroup-1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP 

Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Dear Stephanie -- I’m following up on the below as you agreed to get back to us today. Please let us 

know.

Best Regards,

Shanti

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Stephanie Vazquez <svazquez@allendyer.com> 

Sent: Friday, September 4, 2020 12:12 PM 

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel 

<shgroup-1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: RE: 2399 Collins Avenue Condominium Association adv. SH Group Global IP Holdings - FLSD 

Case No. 1:20-cv-22423-UU

 

Hello Shanti,

We agree to your requested one-week extension of the motion to compel deadline (to September 16th) 

and will advise as to the remaining issues by September 9th.

Best regards,

<image002.png> Stephanie Vazquez

Registered Patent Attorney

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorney-client privilege 

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addressee or an authorized 

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, dissemination, distribution, 

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Thank you.

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 10 of 22
10

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Friday, September 4, 2020 11:10 AM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; #SHGroup-1Hotel 

<shgroup-1hotel@kirkland.com>; Gavin Gaukroger <ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry <CPerry@bergersingerman.com> 

Subject: [EXTERNAL] Re: 2399 Collins Avenue Condominium Association adv. SH Group Global IP 

Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Thanks, Stephanie. Given that you are still discussing the open issues, the holiday and the current deadline of 

September 9 to move to compel, can we agree to extend the motion to compel deadline by a week (to September 

16), per the Local Rules, and that you’ll let us know about the open issues by September 9 at the latest? 

 

Best Regards, 

Shanti 

 

On Sep 4, 2020, at 10:10 AM, Stephanie Vazquez <svazquez@allendyer.com> wrote: 

Hello Shanti,

We have been discussing the remaining issues with our clients. We expect to have a 

decision as to which of the remaining responses at issue we will amend by early next 

week after the holiday.

Best regards,

<image001.png> Stephanie Vazquez

Registered Patent Attorney

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorney-client pr

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addressee or an aut

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, dissemination, distribu

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Thank you.

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Thursday, September 3, 2020 8:32 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz <shotz@allendyer.com>; 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 11 of 22
11

#SHGroup-1Hotel <shgroup-1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres <LTorres@bergersingerman.com>; 

Christina M. Perry <CPerry@bergersingerman.com> 

Subject: [EXTERNAL] Re: 2399 Collins Avenue Condominium Association adv. SH Group 

Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Dear Brian and Stephanie, 

 

Following up on the below, when do you expect to be able to let us know about the open issues? 

 

Best Regards, 

Shanti 

 

On Sep 1, 2020, at 9:39 PM, Conway, Shanti Sadtler 

<shanti.conway@kirkland.com> wrote: 

Dear Brian and Stephanie,

Thank you for speaking with us today about the open issues related to 

your clients’ responses to SH Group’s discovery requests. Below is a 

summary of the topics we discussed. We did not resolve the pending 

issues, and we requested that Defendants reconsider their objections 

and agree to amend/supplement their responses. As discussed on the 

call, please let us know whether Defendants will provide such 

amended/supplemental responses by Thursday so we can determine 

whether a motion to compel will be necessary.

 (1) Defendants’ Objections to Requests for Admission as 

Seeking “Legal Conclusions” (Association’s Responses to RFA 

Nos. 2-3, 18-38, 89-90; Bostany’s Responses to RFA Nos. 4, 6, 

21-42, 93-94).

o We stated that Defendants’ refusal to respond to the 

RFAs are improper as the requests properly seek 

admissions regarding the application of facts to the 

law. We also noted that the Association has served 

numerous similar RFAs, to which SH Group has 

responded, so we are surprised by your position. For 

instance, your August 31st letter claims that RFAs 

asking about “use in commerce” seek a pure legal 

conclusion, yet the Association also asked RFAs about 

“use in commerce,” to which SH Group substantively 

responded. (See, e.g., Association’s RFAs to SH Group 

Nos. 6-65.)

o You responded that SH Group has also made objections 

as to legal conclusions in their responses. (We checked 

after our call and do not see any such refusals to 

respond on that basis in the RFAs.) You reiterated 

Defendants’ position that the RFAs require pure legal 

conclusions and Defendants are thus not required to 

respond.

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 12 of 22
12

 (2) Bostany’s Objections and Response to Interrogatory No. 2 

concerning those with knowledge of Bostany’s contractual 

obligations

o We explained that the requested information regarding 

knowledge of Mr. Bostany’s contractual obligations is 

relevant to, among other things, the tortious 

interference claim against the Association, and that Mr. 

Bostany should be able to provide a substantive 

response. It also is generally relevant to identifying 

people with discoverable knowledge and information in 

the case.

o You stated that the request is very broad such that it is 

possible that all unit owners could know about the 

contractual obligations if they signed similar 

documents. We stated that what the Interrogatory 

asks for is people with knowledge of Bostany’s 

contractual obligations (not the obligations of others), 

but if others know that he signed the same documents 

and is thus subject to the same obligations, then yes 

that would be relevant. We also stated that the fact 

that many people have knowledge is not a basis to not 

respond.

o You stated that Defendants would like a copy of the 

“agreements” that SH Group alleges are at issue and 

that they don’t know what the agreements are. We 

stated that the agreements are specified in the 

Complaint, including their titles and dates, as well as 

quoted excerpts, and that Defendants also have quoted 

the agreements in submissions to the court, so we 

don’t believe there’s any lack of clarity that would 

prevent a substantive response to the interrogatory. 

 (3) The Association’s Responses to Interrogatories Nos. 3-5 

and 7 Regarding References to Trademark Applications

o We stated that we would like complete answers to 

these interrogatories in one place, and that that should 

not be burdensome to provide. You responded that it 

is proper to refer to documents. In response, we noted 

that Rule 33(d) allows parties to refer to documents if it 

is equally as burdensome to the responding party to 

sort through a lot of documents and provide the 

response, and in any event the documents then need 

to be produced by the responding party and then a 

supplemental response with bates numbers 

provided. We do not think that Rule 33(d) applies here.

 (4) The Association’s Responses to Requests for Admission 

Nos. 4-17 Regarding USPTO Records

o We explained that the Association’s refusal to respond 

to RFAs where they can investigate and answer based 

on their investigation is not proper. You responded 

that the RFAs relate to SH Group’s trademark filings, 

which Defendants don’t have knowledge of and that 

other information may be learned in discovery. In 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 13 of 22
13

response, we said that Rule 36 requires an investigation 

and that here, a response can be provided based on 

that investigation as the trademark records are 

public. We stated that the unknown possibility of 

finding out something contradictory or additional 

during discovery is not a basis to not respond to an 

RFA; that is the purpose of being able to amend or 

supplement responses later. 

With respect to all other issues raised in our August 20th letter, as 

reflected in your August 31st letter and our subsequent emails, we 

understand that Defendants will provide amended/supplemental 

responses by September 14. As we previously noted, SH Group reserves 

its right to move to compel based on any failure to provide such 

amended/supplemental responses as well as the sufficiency of such 

responses.

Best Regards,

Shanti 

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Tuesday, September 1, 2020 10:26 AM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz 

<shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Subject: RE: 2399 Collins Avenue Condominium Association adv. SH 

Group Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Thanks, Stephanie. We look forward to receiving 

amended/supplemental responses on September 14. On the call at 

3:30 pm today, we can discuss the remaining issues where Defendants 

have not agreed to amend their responses. 

Best Regards,

Shanti

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 14 of 22
14

-----------------------------------------------------

shanti.conway@kirkland.com

From: Stephanie Vazquez <svazquez@allendyer.com> 

Sent: Tuesday, September 1, 2020 10:23 AM 

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz 

<shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Subject: RE: 2399 Collins Avenue Condominium Association adv. SH 

Group Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Hello Shanti,

We believe September 14th will be sufficient time for our clients to 

serve their amended responses as described in our correspondence 

yesterday. Do you still wish to move forward with the meet and confer 

call this afternoon at 3:30 PM? Please let us know. Thank you.

Best regards,

<image001.png> Stephanie Vazquez

Registered Patent Attorney

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorn

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addresse

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, disseminat

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Tha

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Monday, August 31, 2020 8:17 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz 

<shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 15 of 22
15

Subject: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association 

adv. SH Group Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Dear Stephanie,

Thank you for your email. We understand from your correspondence 

today that Defendants will make the various amendments/supplements 

you have agreed to. We need to have a specific date by which your 

clients will provide those amended/supplemented 

responses. Accordingly, as part of the ongoing good faith efforts to 

resolve these issues without court intervention, we believe that your 

clients’ amended/supplemental responses should be served no later 

than September 14. Please confirm that your clients will provide their 

amended/supplemental responses by that day. Please note, SH Group 

reserves its right to move to compel at any time at or after September 

14, if the deficiencies in your clients’ discovery responses remain 

uncured. 

Best Regards,

Shanti

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Stephanie Vazquez <svazquez@allendyer.com> 

Sent: Monday, August 31, 2020 6:07 PM 

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz 

<shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Subject: RE: 2399 Collins Avenue Condominium Association adv. SH 

Group Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Hello Shanti,

We would work on getting those responses back to you as soon as 

possible. We need to confer with our clients to see how quickly they can 

review and approve the amended responses.

Best regards,

<image001.png> Stephanie Vazquez

Registered Patent Attorney

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 16 of 22
16

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorn

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addresse

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, disseminat

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Tha

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Monday, August 31, 2020 5:05 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz 

<shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Subject: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association 

adv. SH Group Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Thanks, Stephanie. By when will Defendants serve 

supplemental/amended discovery responses, per your below email and 

letter dated today?

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Stephanie Vazquez <svazquez@allendyer.com> 

Sent: Monday, August 31, 2020 4:50 PM 

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz 

<shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Subject: RE: 2399 Collins Avenue Condominium Association adv. SH 

Group Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Thank you, Shanti. Regarding the issues raised in Section IV concerning 

Interrogatories 8 and 9 directed to the Association and Interrogatory 6 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 17 of 22
17

directed to Mr. Bostany, we do not agree with your position that it is 

improper to reference D.E. 22, however we agree to amend those 

responses in an effort to avoid unnecessary motion practice.

Best regards,

<image001.png> Stephanie Vazquez

Registered Patent Attorney

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorn

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addresse

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, disseminat

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Tha

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Monday, August 31, 2020 4:17 PM 

To: Stephanie Vazquez <svazquez@allendyer.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz 

<shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Subject: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association 

adv. SH Group Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Thanks, Stephanie. I’ll plan to call your office then. If you prefer a dial 

in, please send one. Please also let us know your response to Section IV 

of our letter so we can consider that in advance of the call.

Best Regards,

Shanti

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Stephanie Vazquez <svazquez@allendyer.com> 

Sent: Monday, August 31, 2020 4:11 PM 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 18 of 22
18

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Brian Gilchrist <bgilchrist@allendyer.com>; Shelley Hotz 

<shotz@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Subject: RE: 2399 Collins Avenue Condominium Association adv. SH 

Group Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Hello Shanti,

We are available for a call to meet and confer tomorrow at 3:30 PM.

Best regards,

<image001.png> Stephanie Vazquez

Registered Patent Attorney

Allen, Dyer, Doppelt + Gilchrist, PA

1221 Brickell Avenue | Suite 2400 | Miami, FL 33131

(305) 374-8303 | phone 

(305) 374-8306 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorn

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addresse

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, disseminat

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Tha

From: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Sent: Monday, August 31, 2020 3:57 PM 

To: Shelley Hotz <shotz@allendyer.com> 

Cc: Stephanie Vazquez <svazquez@allendyer.com>; Brian Gilchrist 

<bgilchrist@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Subject: [EXTERNAL] RE: 2399 Collins Avenue Condominium Association 

adv. SH Group Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Dear Stephanie,

Thank you for your response. It appears that you have not responded, 

however, to Section IV of our August 20th letter, which discussed the 

Association’s deficient responses to Interrogatory Nos. 8 and 9 and Mr. 

Bostany’s deficient response to Interrogatory No. 6. Please let us know 

your position today.

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 19 of 22
19

Please also let me know if you are available for a call to meet and confer 

tomorrow at 1:00 or 3:30 pm.

Best Regards,

Shanti

Shanti Sadtler Conway 

-----------------------------------------------------

KIRKLAND & ELLIS LLP

601 Lexington Avenue, New York, NY 10022

T +1 212 446 5933 M +1 781 571 9211

F +1 212 446 4900

-----------------------------------------------------

shanti.conway@kirkland.com

From: Shelley Hotz <shotz@allendyer.com> 

Sent: Monday, August 31, 2020 2:08 PM 

To: Conway, Shanti Sadtler <shanti.conway@kirkland.com> 

Cc: Stephanie Vazquez <svazquez@allendyer.com>; Brian Gilchrist 

<bgilchrist@allendyer.com>; #SHGroup-1Hotel <shgroup1hotel@kirkland.com>; Gavin Gaukroger 

<ggaukroger@bergersingerman.com>; Luis Torres 

<LTorres@bergersingerman.com>; Christina M. Perry 

<CPerry@bergersingerman.com> 

Subject: 2399 Collins Avenue Condominium Association adv. SH Group 

Global IP Holdings - FLSD Case No. 1:20-cv-22423-UU

 

Counsel: 

Attached is a letter to your attention concerning the referenced matter. 

Please let us know if you have any problems receiving the attached file. 

Thank you, 

Shelley 

<image002.png>

<image003.png>

Shelley Hotz

Florida Registered Paralegal

Allen, Dyer, Doppelt + Gilchrist, PA

255 South Orange Avenue | Suite 1401 | Orlando, FL 32801

(407) 841-2330 | phone 

(407) 841-2343 | fax

website | vCard | map | email

Note: The information in this e-mail message is intended for the confidential use of the addressees only. The information is subject to the attorn

and/or may be attorney work-product. Recipients should not file copies of this e-mail with publicly accessible records. If you are not an addresse

agent responsible for delivering this e-mail to a designated addressee, you have received this e-mail in error, and any further review, disseminat

copying or forwarding of this e-mail is strictly prohibited. If you received this e-mail in error, please notify us immediately at (407) 841-2330. Tha

 

The information contained in this communication is confidential, may be attorney-client 

privileged, may constitute inside information, and is intended only for the use of the 

addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 20 of 22
20

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly 

prohibited and may be unlawful. If you have received this communication in error, please 

notify us immediately by return email or by email to postmaster@kirkland.com, and destroy 

this communication and all copies thereof, including all attachments. 

 

The information contained in this communication is confidential, may be attorney-client 

privileged, may constitute inside information, and is intended only for the use of the 

addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly 

prohibited and may be unlawful. If you have received this communication in error, please 

notify us immediately by return email or by email to postmaster@kirkland.com, and destroy 

this communication and all copies thereof, including all attachments. 

 

The information contained in this communication is confidential, may be attorney-client 

privileged, may constitute inside information, and is intended only for the use of the 

addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly 

prohibited and may be unlawful. If you have received this communication in error, please 

notify us immediately by return email or by email to postmaster@kirkland.com, and destroy 

this communication and all copies thereof, including all attachments. 

 

The information contained in this communication is confidential, may be attorney-client 

privileged, may constitute inside information, and is intended only for the use of the 

addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly 

prohibited and may be unlawful. If you have received this communication in error, please 

notify us immediately by return email or by email to postmaster@kirkland.com, and destroy 

this communication and all copies thereof, including all attachments. 

 

The information contained in this communication is confidential, may be attorney-client privileged, may 

constitute inside information, and is intended only for the use of the addressee. It is the property of Kirkland & 

Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of this communication or 

any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, 

please notify us immediately by return email or by email to postmaster@kirkland.com, and destroy this 

communication and all copies thereof, including all attachments. 

 

The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, 

and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you 

have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, 

and destroy this communication and all copies thereof, including all attachments. 

 

The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, 

and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you 

have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, 

and destroy this communication and all copies thereof, including all attachments. 

 

The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, 

and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you 

have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, 

and destroy this communication and all copies thereof, including all attachments. 

 

The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, 

and is intended only for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. 

Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you 

have received this communication in error, please notify us immediately by return email or by email to postmaster@kirkland.com, 

and destroy this communication and all copies thereof, including all attachments. 

 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 21 of 22
21

The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only 

for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of 

this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us 

immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. 

 

The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only 

for the use of the addressee. It is the property of Kirkland & Ellis LLP or Kirkland & Ellis International LLP. Unauthorized use, disclosure or copying of 

this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us 

immediately by return email or by email to postmaster@kirkland.com, and destroy this communication and all copies thereof, including all attachments. 

Case 1:20-cv-22423-UU Document 42-5 Entered on FLSD Docket 10/01/2020 Page 22 of 22