1

From: MF <mforteza@protonmail.com> 

Sent: Thursday, August 24, 2023 6:30 PM 

To: Allen, Justin A. <jaallen@varnumlaw.com> 

Cc: Jason Weiss <jason@jswlawyer.com>; Doyle, Brion B. <bbdoyle@varnumlaw.com>; Stefan John 

<stefan@jswlawyer.com>; Shameka Cuellar <shameka@jswlawyer.com>; William Reid <wreid@reiddennis.com> 

Subject: RE: Response to 26(f) Letter | CASE NO. : 4:23-CV-00401-ALM-KPJ 

I am in agreement with the proposed scheduling order. Thank you. 

Sent with Proton Mail secure email. 

------- Original Message ------- 

On Thursday, August 24th, 2023 at 3:34 PM, Allen, Justin A. <jaallen@varnumlaw.com> wrote: 

Ms. Forteza, 

 

The Court has also requested that a proposed scheduling order be filed with the 26(f) Joint 

Statement. To that end, we have prepared the attached proposed order. Please review and let us know 

if you are in agreement with the proposed dates contained therein. The Court has asked that we have 

on file tomorrow. 

Case 4:23-cv-00401-ALM-KPJ Document 37-3 Filed 12/22/23 Page 1 of 8 PageID #: 184
2

 

Thanks, 

Justin 

 

 

Justin A. Allen

Associate

Direct: 616-336-6249

Email: jaallen@varnumlaw.com

Varnum LLP

333 Bridge Street NW, Suite 1700

Grand Rapids, Michigan 49504

varnumlaw.com

****************************** 

CONFIDENTIAL 

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

viewing and use of the intended recipients. If you are not an intended recipient, you are hereby notified that any use, disclosure, or copying is 

strictly prohibited and may be unlawful. If you have received this communication in error, please immediately notify he sender at 616-336-6000. 

****************************** 

 

 

 

From: Allen, Justin A. 

Sent: Wednesday, August 23, 2023 1:44 PM 

To: MF <mforteza@protonmail.com> 

Cc: Jason Weiss <jason@jswlawyer.com>; Doyle, Brion B. <bbdoyle@varnumlaw.com>; Stefan John 

<stefan@jswlawyer.com>; Shameka Cuellar <shameka@jswlawyer.com>; William Reid 

<wreid@reiddennis.com> 

Subject: RE: Response to 26(f) Letter | CASE NO. : 4:23-CV-00401-ALM-KPJ 

 

Thank you, we will get on file. 

 

 

Justin A. Allen

Associate

Direct: 616-336-6249

Email: jaallen@varnumlaw.com

Varnum LLP

333 Bridge Street NW, Suite 1700

Grand Rapids, Michigan 49504

varnumlaw.com

****************************** 

CONFIDENTIAL 

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

viewing and use of the intended recipients. If you are not an intended recipient, you are hereby notified that any use, disclosure, or copying is

Case 4:23-cv-00401-ALM-KPJ Document 37-3 Filed 12/22/23 Page 2 of 8 PageID #: 185
3

strictly prohibited and may be unlawful. If you have received this communication in error, please immediately notify he sender at 616-336-6000. 

****************************** 

 

 

 

From: MF <mforteza@protonmail.com> 

Sent: Wednesday, August 23, 2023 6:04 AM 

To: Allen, Justin A. <jaallen@varnumlaw.com> 

Cc: Jason Weiss <jason@jswlawyer.com>; Doyle, Brion B. <bbdoyle@varnumlaw.com>; Stefan John 

<stefan@jswlawyer.com>; Shameka Cuellar <shameka@jswlawyer.com>; William Reid 

<wreid@reiddennis.com> 

Subject: RE: Response to 26(f) Letter | CASE NO. : 4:23-CV-00401-ALM-KPJ 

 

Mr. Allen,

I reviewed and approve the final version of the report. Thank you.

Sincerely,

Maricel

Sent with Proton Mail secure email. 

------- Original Message ------- 

On Tuesday, August 22nd, 2023 at 8:42 PM, Allen, Justin A. <jaallen@varnumlaw.com> wrote: 

Ms. Forteza, 

 

Attached is a final version of the Rule 26f Joint Report for your review and 

approval. The additions here are adding Mepco to the initial paragraph and then under 

item 2, where we have added the additional cases in which you are the Plaintiff and 

Mepco is a Defendant. 

 

With your approval we will get on file. 

Case 4:23-cv-00401-ALM-KPJ Document 37-3 Filed 12/22/23 Page 3 of 8 PageID #: 186
4

 

Thanks, 

Justin 

 

 

Justin A. Allen

Associate

Direct: 616-336-6249

Email: jaallen@varnumlaw.com

Varnum LLP

333 Bridge Street NW, Suite 1700

Grand Rapids, Michigan 49504

varnumlaw.com

****************************** 

CONFIDENTIAL 

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

viewing and use of the intended recipients. If you are not an intended recipient, you are hereby notified that any use, disclosure, or copying is 

strictly prohibited and may be unlawful. If you have received this communication in error, please immediately notify he sender at 616-336-6000. 

****************************** 

 

 

 

From: Allen, Justin A. 

Sent: Tuesday, August 22, 2023 4:40 PM 

To: Jason Weiss <jason@jswlawyer.com>; MF <mforteza@protonmail.com> 

Cc: Doyle, Brion B. <bbdoyle@varnumlaw.com>; Stefan John <stefan@jswlawyer.com>; 

Shameka Cuellar <shameka@jswlawyer.com> 

Subject: RE: Response to 26(f) Letter | CASE NO. : 4:23-CV-00401-ALM-KPJ 

 

Thanks Jason and not at all! We will finalize and get on file. 

 

 

Justin A. Allen

Associate

Direct: 616-336-6249

Email: jaallen@varnumlaw.com

Varnum LLP

333 Bridge Street NW, Suite 1700

Grand Rapids, Michigan 49504

varnumlaw.com

****************************** 

CONFIDENTIAL 

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

viewing and use of the intended recipients. If you are not an intended recipient, you are hereby notified that any use, disclosure, or copying is 

strictly prohibited and may be unlawful. If you have received this communication in error, please immediately notify he sender at 616-336-6000. 

****************************** 

Case 4:23-cv-00401-ALM-KPJ Document 37-3 Filed 12/22/23 Page 4 of 8 PageID #: 187
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From: Jason Weiss <jason@jswlawyer.com> 

Sent: Tuesday, August 22, 2023 4:34 PM 

To: Allen, Justin A. <jaallen@varnumlaw.com>; MF <mforteza@protonmail.com> 

Cc: Doyle, Brion B. <bbdoyle@varnumlaw.com>; Stefan John <stefan@jswlawyer.com>; 

Shameka Cuellar <shameka@jswlawyer.com> 

Subject: RE: Response to 26(f) Letter | CASE NO. : 4:23-CV-00401-ALM-KPJ 

 

Agreeable, thanks and sorry for my delayed response here. 

Jason S. Weiss, Esq. 

Weiss Law Group, P.A.

5531 N. University Drive, Suite 103

Coral Springs, FL 33067

Tel: 954.573.2800

Fax: 954.573.2798

www.jswlawyer.com

www.linkedin.com/in/jason-s-weiss

STATEMENT OF CONFIDENTIALITY AND PRIVILEGE AND TAX 

ADVICE 

The information contained in this e-mail communication may be confidential and 

privileged. It is intended only for the use of the individual or entity identified. If 

Case 4:23-cv-00401-ALM-KPJ Document 37-3 Filed 12/22/23 Page 5 of 8 PageID #: 188
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you are not the intended recipient, please do not disseminate, distribute, or copy. 

Instead, please notify us at 954-573-2800 and immediately delete this message.

Pursuant to Internal Revenue Service Circular 230, we are required to advise you 

that if there is any tax advice contained in this email, it was neither written nor 

intended by the sender or this firm to be used, and cannot be used, by the 

addressee, recipient, or any taxpayer, for the purpose of avoiding penalties that 

may be imposed by or under United States law, including but not limited to the 

Internal Revenue Code.

From: Allen, Justin A. <jaallen@varnumlaw.com> 

Sent: Tuesday, August 22, 2023 4:28 PM 

To: MF <mforteza@protonmail.com>; Jason Weiss <jason@jswlawyer.com> 

Cc: Doyle, Brion B. <bbdoyle@varnumlaw.com>; Stefan John <stefan@jswlawyer.com>; 

Shameka Cuellar <shameka@jswlawyer.com> 

Subject: RE: Response to 26(f) Letter | CASE NO. : 4:23-CV-00401-ALM-KPJ 

 

Thank you. Jason, please let me know if you are agreeable and we will work with our 

local counsel to file. 

 

 

Justin A. Allen

Associate

Direct: 616-336-6249

Email: jaallen@varnumlaw.com

Varnum LLP

333 Bridge Street NW, Suite 1700

Grand Rapids, Michigan 49504

varnumlaw.com

****************************** 

CONFIDENTIAL 

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

viewing and use of the intended recipients. If you are not an intended recipient, you are hereby notified that any use, disclosure, or copying is 

strictly prohibited and may be unlawful. If you have received this communication in error, please immediately notify he sender at 616-336-6000. 

****************************** 

 

 

 

From: MF <mforteza@protonmail.com> 

Sent: Monday, August 21, 2023 11:23 PM 

To: Allen, Justin A. <jaallen@varnumlaw.com>; Jason Weiss <jason@jswlawyer.com> 

Cc: Doyle, Brion B. <bbdoyle@varnumlaw.com>; Stefan John <stefan@jswlawyer.com>; 

Case 4:23-cv-00401-ALM-KPJ Document 37-3 Filed 12/22/23 Page 6 of 8 PageID #: 189
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Shameka Cuellar <shameka@jswlawyer.com> 

Subject: Re: Response to 26(f) Letter | CASE NO. : 4:23-CV-00401-ALM-KPJ 

 

Mr. Allen,

I have reviewed the revised 26(f) report. I appreciate your input. I have no 

objections to your revisions. Jason Weiss is copied in this email, so he can review 

the revised report. If Mr. Weiss has no objections, you may file it in court at your 

earliest convenience. Thank you.

SIncerely,

Maricel

Sent with Proton Mail secure email. 

------- Original Message ------- 

On Monday, August 21st, 2023 at 6:15 AM, Allen, Justin A. <jaallen@varnumlaw.com> 

wrote: 

Ms. Forteza, 

 

Attached is Mepco's proposed contribution to the 26f joint report. For 

the most part these additions are related to Mepco's portion only, but 

please review and if we are in agreement we will have our local counsel 

file a finalized version of the attached with the Court. 

 

Thanks, 

Justin 

 

 

Justin A. Allen

Associate

Direct: 616-336-6249

Email: jaallen@varnumlaw.com 

Varnum LLP

333 Bridge Street NW, Suite 1700

Grand Rapids, Michigan 49504

varnumlaw.com

Case 4:23-cv-00401-ALM-KPJ Document 37-3 Filed 12/22/23 Page 7 of 8 PageID #: 190
8

****************************** 

CONFIDENTIAL 

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

viewing and use of the intended recipients. If you are not an intended recipient, you are hereby notified that any use, disclosure, or copying is

strictly prohibited and may be unlawful. If you have received this communication in error, please immediately notify he sender at 616-336-6000. 

****************************** 

 

 

 

 

Case 4:23-cv-00401-ALM-KPJ Document 37-3 Filed 12/22/23 Page 8 of 8 PageID #: 191