From: White, Conor

To: "Randy Pulman"

Cc: Rukavina, Davor; MaryAnn Villa; Vasek, Julian; Jamie Gonzales

Subject: RE: UFS Discovery Upload Link

Date: Wednesday, March 20, 2024 9:06:00 AM

Randy,

Following up on this - please advise if you have received any updates from your client. Thank you.

Regards,

From: Randy Pulman <RPulman@pulmanlaw.com> 

Sent: Friday, March 8, 2024 3:17 PM

To: White, Conor <cwhite@munsch.com>

Cc: Rukavina, Davor <drukavina@munsch.com>; MaryAnn Villa <mvilla@pulmanlaw.com>; Vasek, Julian

<jvasek@munsch.com>; Jamie Gonzales <JGonzales@pulmanlaw.com>

Subject: RE: UFS Discovery Upload Link

External Email: Use caution with links and attachments.

Conor:

The client confirms that payroll stops on the dates reflected in the income statement we sent to you which I

believe as April 2023 when the entity ceased operations.

With respect to the bank statements prior to 2022, the client changed accounting systems and no longer has

access to those statements. I suspect those statements will have to be retrieved from the Bank. I will ask the

client to go back and try to find the June 2023 statement which we apparently did not produce.

With respect to the tax returns, I will have to confirm its existence with the client, but I suspect that this was

a wholly owned pass-through entity which prepared no separate tax return. I will go back to the client and

confirm whether a tax return was prepared.

RAP

Randall A. Pulman

Pulman, Cappuccio & Pullen, LLP

2161 NW Military Highway, Suite 400

San Antonio, Texas 78213

210-222-9494

210-892-0420(direct)

210-892-1610(fax)

rpulman@pulmanlaw.com

www.pulmanlaw.com

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From: White, Conor <cwhite@munsch.com> 

Case 23-03088-mvl Doc 13-3 Filed 04/26/24 Entered 04/26/24 15:38:47 Desc

Exhibit C Page 1 of 4
Sent: Thursday, March 7, 2024 12:53 PM

To: Randy Pulman <RPulman@pulmanlaw.com>

Cc: Rukavina, Davor <drukavina@munsch.com>; MaryAnn Villa <mvilla@pulmanlaw.com>; Vasek, Julian

<jvasek@munsch.com>; Jamie Gonzales <JGonzales@pulmanlaw.com>

Subject: RE: UFS Discovery Upload Link

Thank you, Randy. I forgot to mention, but if you could just get confirmation that UFS canceled its payroll

account in April of 2023 (we don’t have any after then) and inquire on statements for January and February

of this year, as well. Appreciate the assistance.

Conor P. White

Munsch Hardt Kopf & Harr, P.C.

500 N. Akard Street, Suite 4000 / Dallas, Texas 75201-6605

Direct: +1.214.880.1085 / cwhite@munsch.com / munsch.com

From: Randy Pulman <RPulman@pulmanlaw.com> 

Sent: Thursday, March 7, 2024 12:35 PM

To: White, Conor <cwhite@munsch.com>

Cc: Rukavina, Davor <drukavina@munsch.com>; MaryAnn Villa <mvilla@pulmanlaw.com>; Vasek, Julian

<jvasek@munsch.com>; Jamie Gonzales <JGonzales@pulmanlaw.com>

Subject: RE: UFS Discovery Upload Link

External Email: Use caution with links and attachments.

I have passed this back to the client and will let you know.

Randall A. Pulman

Pulman, Cappuccio & Pullen, LLP

2161 NW Military Highway, Suite 400

San Antonio, Texas 78213

210-222-9494

210-892-0420(direct)

210-892-1610(fax)

rpulman@pulmanlaw.com

www.pulmanlaw.com

PULMAN, CAPPUCCIO & PULLEN, LLP. E-MAIL NOTICE - This transmission may be: (1) subject to the

Attorney-Client Privilege, (2) an Attorney Work Product, or (3) strictly confidential. If you are not the intended

recipient of this message, you may not disclose, print, copy or disseminate this information. If you have received

this message in error, please reply and notify the sender (only) and delete the message. Unauthorized

interception of this e-mail is a violation of federal criminal law.

From: White, Conor <cwhite@munsch.com> 

Sent: Thursday, March 7, 2024 12:26 PM

To: Randy Pulman <RPulman@pulmanlaw.com>

Cc: Rukavina, Davor <drukavina@munsch.com>; MaryAnn Villa <mvilla@pulmanlaw.com>; Vasek, Julian

<jvasek@munsch.com>; Jamie Gonzales <JGonzales@pulmanlaw.com>

Subject: RE: UFS Discovery Upload Link

Case 23-03088-mvl Doc 13-3 Filed 04/26/24 Entered 04/26/24 15:38:47 Desc

Exhibit C Page 2 of 4
Randy,

We’ve had a chance to look over the documents provided in the link and irrespective of the emails we

discussed, it looks like we’re still missing several groups of key documents requested in the RFPs. Some of

the notable ones, for example, include bank statements prior to 2022 (and for June of 2023) and UFS’s tax

returns.

When do you anticipate being able to supplement the missing bank statements or other documents?

Regards,

Conor P. White

Munsch Hardt Kopf & Harr, P.C.

500 N. Akard Street, Suite 4000 / Dallas, Texas 75201-6605

Direct: +1.214.880.1085 / cwhite@munsch.com / munsch.com

From: Jamie Gonzales <JGonzales@pulmanlaw.com> 

Sent: Wednesday, March 6, 2024 2:12 PM

To: White, Conor <cwhite@munsch.com>; Randy Pulman <RPulman@pulmanlaw.com>

Cc: Rukavina, Davor <drukavina@munsch.com>; MaryAnn Villa <mvilla@pulmanlaw.com>

Subject: RE: UFS Discovery Upload Link

External Email: Use caution with links and attachments.

I have uploaded documents to the ShareFile link. There should be 64 pdf files and 7 Excel worksheets for a

total of 71 documents. The pdf files have a bates label on them with Seidel UFS 1-655. Let me know if you

have any questions. Thank you.

Jamie Gonzales

Legal Assistant to

Randall Pulman

Shari P. Pulman

Pulman, Cappuccio & Pullen, LLP

2161 NW Military Hwy, Suite 400

San Antonio, Texas 78213

Telephone: (210) 222-9494, ext. 101

Facsimile: (210) 892-1610

www.jgonzales@pulmanlaw.com

www.pulmanlaw.com

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From: White, Conor <cwhite@munsch.com> 

Case 23-03088-mvl Doc 13-3 Filed 04/26/24 Entered 04/26/24 15:38:47 Desc

Exhibit C Page 3 of 4
Sent: Wednesday, March 6, 2024 1:25 PM

To: Randy Pulman <RPulman@pulmanlaw.com>; Jamie Gonzales <JGonzales@pulmanlaw.com>

Cc: Rukavina, Davor <drukavina@munsch.com>

Subject: UFS Discovery Upload Link

Randy,

Thanks for your call earlier. Below is a link to a ShareFile where you should be able to upload the documents

collected so far. Please let me know if you have any issues accessing or uploading docs to the link.

https://munsch.sharefile.com/i/i66b35ded0fb44c7b

Regards,

Conor P. White

Munsch Hardt Kopf & Harr, P.C.

500 N. Akard Street, Suite 4000 / Dallas, Texas 75201-6605

Direct: +1.214.880.1085 / cwhite@munsch.com / munsch.com

Notice: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any

unauthorized review, use, disclosure or distribution is prohibited. Nothing contained in this message or in any attachment shall constitute a

contract or electronic signature under the Electronic Signatures in Global and National Commerce Act, any version of the Uniform Electronic

Transactions Act or any other statute governing electronic transactions.

Case 23-03088-mvl Doc 13-3 Filed 04/26/24 Entered 04/26/24 15:38:47 Desc

Exhibit C Page 4 of 4