EXHIBIT E 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 1 of 21
Joshua Wurtzel 

From: 

Sent: 

To: 

Cc: 

Subject: 

Chris Meyers <ChrisM@wb-law.com> 

Friday, May 24, 2019 6:38 PM 

Joshua Wurtzel; Dennis Wilenchik 

Bradley J. Nash; Henk Taylor; Wyo Tech adv Wells Fargo (e57659d03+matter1136246401 

@maildrop.clio.com); Chase Turrentine; Tyler Swensen; Leo Beus; Victoria Stevens 

RE: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SDT, 

05-17-19 Supplemental Response to BG SDT 

Josh - Ok. This has to stop. We're getting nowhere, besides cluttering everyone's inboxes. Lisa and I will call you next 

week when she gets back to the office to sort this out. We will also get you the checks you are requesting. 

No more e-mails, please. 

Have a good weekend. Thanks, 

www.wb-law.com 

Chris Meyers 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

The information transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged 

material. Any interception, review, retransmission, dissemination or other use of this information by persons or entities other than the 

intended recipient is prohibited by law and may subject them to criminal or civil liability. If you received this communication in error, 

please contact us immediately at (602) 606-2810, and delete the communication from any computer or network system. 

From: Joshua Wurtzel [mailto:jwurtzel@schlamstone.com] 

Sent: Friday, May 24, 2019 3:35 PM 

To: Dennis Wilenchik; Chris Meyers 

Cc: Bradley J. Nash; Henk Taylor; Wyo Tech adv Wells Fargo (e57659d03+matter1136246401@maildrop.clio.com); Chase 

Turrentine; Tyler Swensen; Leo Beus; Victoria Stevens 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SDT, 05-17-19 

Supplemental Response to BG SDT 

Then if all the payments on the documents I cited below were from Wyo Tech or Inductance, then your production is 

missing account source info and client and matter info for each one of those payments, and you need to supplement. 

Joshua Wurtzel 

1 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 2 of 21
Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

SCHLAM STONE & DOLAN LlP 

CommercialDivisionBlog.com 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

From: Dennis Wilenchik <diw@wb-law.com> 

Sent: Friday, May 24, 2019 6:31 PM 

To: Joshua Wurtzel <jwurtzel@schlamstone.com>; Chris Meyers <ChrisM@wb-law.com> 

Cc: Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) <e57659d03+matter1136246401@maildrop.clio.com>; Chase 

Turrentine <chaset@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Leo Beus <lbeus@beusgilbert.com>; Victoria 

Stevens <VictoriaS@wb-law.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SDT, 05-17-19 

Supplemental Response to BG SDT 

Josh I don't believe that is the case. I believe the funds in question were from wyo 

and inductance and that is what you were requesting. They were applied to accounts 

as shown on the invoices. So forgive me but it seems rather simple to me. However, 

as I said, I am copying Lisa with this and on Tuesday she can get with you to 

explain anything further on how she received and applied funds and walk you 

through it better and get cancelled checks from the client if that helps. Have a good 

weekend 

Sincerely Yours, 

www.wb-law.com 

Dennis Wilenchik 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

2 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 3 of 21
ATTORNEY/CLIENT COMMUNICATION 

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intended recipient is prohibited by law and may subject them to criminal or civil liability. If you received this communication in error, 

please contact us immediately at (602) 606-2810, and delete the communication from any computer or network system. 

From: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Sent: Friday, May 24, 2019 3:21 PM 

To: Dennis Wilenchik <diw@wb-law.com>; Chris Meyers <ChrisM@wb-law.com> 

Cc: Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) <e57659d03+matter1136246401@maildrop.clio.com>; Chase 

Turrentine <chaset@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Leo Beus <lbeus@beusgilbert.com>; Victoria 

Stevens <VictoriaS@wb-law.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SDT, 05-17-19 

Supplemental Response to BG SDT 

Dennis, 

Please review the chart I sent earlier today and the bates numbers I cited. There are payments you identified in your 

production but for which you have not produced documents showing the client for whose benefit or the matter for 

which the payment was made. I explained to Chris what he should get to gather documents showing that, and he said he 

would check. Obviously when the retainers were deposited they were earmarked for specific clients and matters, even if 

for multiple clients and matters. 

And as you will see if you look at the bates numbers I cited below from your production, there are a number of 

payments the payor of which Chris said your firm doesn't know. He acknowledged that they could be Wyo Tech or 

Inductance, and agreed that-based on the record-keeping system your firm has-the only way to tell who made these 

payments is by looking at the bank records. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

SCHLAM STONE & DOLAN LLP 

CommercialDivisionBlog.com 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

From: Dennis Wilenchik <diw@wb-law.com> 

Sent: Friday, May 24, 2019 6:09 PM 

To: Joshua Wurtzel <jwurtzel@schlamstone.com>; Chris Meyers <ChrisM@wb-law.com> 

Cc: Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) <e57659d03+matter1136246401@maildrop.clio.com>; Chase 

Turrentine <chaset@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Leo Beus <lbeus@beusgilbert.com>; Victoria 

3 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 4 of 21
Stevens <VictoriaS@wb-law.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SOT, 05-17-19 

Supplemental Response to BG SOT 

Josh- I don't want to debate anything either. I am telling you simply I have 

repeatedly asked my people to get whatever we have that explains money received 

from WY-IEC which went into trust and removals and applications to whatever 

accounts they were applied to contemporaneously as shown on invoices applying 

monies to balances. That is all I know that is remotely relevant and responsive. 

However, I want to make clear we are not trying in any way to be evasive as I don't 

care how the monies were applied and don't think its even relevant to anything so I 

am trying to cooperate repeatedly with you to get what you need answered. 

However, at some point we have to say that is all we have to give. That is why if 

you want to speak to my bookkeeper to explain this better with Chris its ok with 

me, and we will ask the client or bank to get checks if that helps any although I 

don't know why and don't think that is part of how we viewed the subpoena but its 

fine. thanks 

Sincerely Yours, 

www.wb-law.com 

Dennis Wilenchik 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

The information transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged 

material. Any interception, review, retransmission, dissemination or other use of this information by persons or entities other than the 

intended recipient is prohibited by law and may subject them to criminal or civil liability. If you received this communication in error, 

please contact us immediately at (602) 606-2810, and delete the communication from any computer or network system. 

From: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Sent: Friday, May 24, 2019 2:22 PM 

4 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 5 of 21
To: Dennis Wilenchik <diw@wb-law.com>; Chris Meyers <ChrisM@wb-law.com> 

Cc: Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) <e57659d03+matter1136246401@maildrop.clio.com>; Chase 

Turrentine <chaset@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Leo Beus <lbeus@beusgilbert.com>; Victoria 

Stevens <VictoriaS@wb-law.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SOT, 05-17-19 

Supplemental Response to BG SDT 

Dennis, 

I disagree concerning your compliance with the subpoena, but we obviously don't have to debate that. And if you review 

the chart and documents cited below, I think you will see what I am saying. 

As I explained to Chris, the subpoena doesn't require you to get checks or other information from the bank. But if that is 

the only place the information is available, then you must collect and review those documents. Thus, given what Tyler 

and Chris told me about your firm's internal record keeping and document-maintenance system, it seems to me that you 

must get your bank records from your bank to be able to identify source account information for many of these 

payments. 

Your firm represented Dennis Danzik in his case in Arizona federal court against CWT Canada, Resource Recovery, Jean 

Noelting, Bruce MacFarlane, and Brian Appel. This case was brought in 2017 and dismissed by Judge Campbell in 2018 

on res judicata grounds. Your firm also represented Dennis Danzik in the Arizona judgment-collection action in Arizona 

state court. And you have appeared on his behalf in the NY action during the motion to vacate and also in Wyoming 

bankruptcy court last week. 

Have a good holiday. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

SCHLAM STONE & [)OLAN LlP 

CommercialDivisionBlog.com 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

From: Dennis Wilenchik <diw@wb-law.com> 

Sent: Friday, May 24, 2019 5:11 PM 

To: Joshua Wurtzel <jwurtzel@schlamstone.com>; Chris Meyers <ChrisM@wb-law.com> 

Cc: Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) <e57659d03+matter1136246401@maildrop.clio.com>; Chase 

Turrentine <chaset@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Leo Beus <lbeus@beusgilbert.com>; Victoria 

Stevens <VictoriaS@wb-law.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SOT, 05-17-19 

Supplemental Response to BG SDT 

5 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 6 of 21
Although I feel we have done everything to fully cooperate despite what you say 

Josh, and have shown the amts received from Wyo- iec and application to accounts, 

we will nevertheless fully cooperate and get checks from the client or from the bank 

if necessary if that helps. Lisa is out at a funeral in Nebraska and tyler has been out 

for the week as am I but we will try to get you that asap. I still don't understand the 

relevance of any of this but that's fine. Also, I didn't recall any representation of 

Danzik in federal court in az. If that was some brief representation it escaped my 

recall so we will look at that, but it should not effect anything here. Thank you and 

have a good holiday 

Sincerely Yours, 

www.wb-law.com 

Dennis Wilenchik 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

The information transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged 

material. Any interception, review, retransmission, dissemination or other use of this information by persons or entities other than the 

intended recipient is prohibited by law and may subject them to criminal or civil liability. If you received this communication in error, 

please contact us immediately at (602) 606-2810, and delete the communication from any computer or network system. 

From: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Sent: Friday, May 24, 2019 1:19 PM 

To: Chris Meyers <ChrisM@wb-law.com> 

Cc: Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; Wyo Tech adv Wells Fargo 

( es 7659d03+matter1136246401@ma ild rop.clio.com} <eS 7659d03+matter1136246401@ma ild rap.cl io.com>; Denn is 

Wilenchik <diw@wb-law.com>; Chase Turrentine <chaset@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Leo 

Beus <lbeus@beusgilbert.com>; Victoria Stevens <VictoriaS@wb-law.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SDT, 05-17-19 

Supplemental Response to BG SDT 

Chris, 

6 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 7 of 21
To follow up on our meet and confer today, I explained to you that Wilenchik still has not produced documents showing 

the source account, client, or matter for several of the Inductance and Wyo Tech payments. The information that is 

missing for each payment is reflected in the chart below. You explained to me that Wilenchik would get big retainers 

from Wyo Tech and Inductance and then use those funds for various matters and clients. I then responded that, even if 

that is the case, those retainer payments would have had to be earmarked for particular matters and clients, even if for 

multiple matters and clients. You agreed to go back and check on this. 

I also explained that the source account for particular payments would be easy to determine by looking at the cancelled 

check that corresponds to that payment (or wire confirmation). You said that Wilenchik does not keep copies of checks 

it deposits. I responded that Wilenchik could still get copies of these checks from its bank. You said that Wilenchik does 

not have on line banking (though you weren't positive about this and said you would check). But I explained that, even if 

that is true, Wilenchik could still get copies of its statements and cancelled checks from its bank-either by going to the 

bank and requesting them or by setting up an on line account. You admitted that Wilenchik had not done this in 

responding to this subpoena. 

I further explained that there are several payments reflected on the documents Wilenchik produced on May 22, 2019 

that do not match any of the other documents Wilenchik produced. I asked you who made these payments, explaining 

that if it were Wyo Tech or Inductance, then Wilenchik is missing documents showing the source account and client and 

matter for these payments. You conceded that you did not know who made these payments, even though Wilenchik 

included documents showing these payments in its production-which asked only for Wyo Tech and Inductance 

payments. You acknowledged that they could be Wyo Tech or Inductance payments, and conceded that the only way to 

tell-absent better record keeping at your firm-would be to review bank records. 

I then explained that, even if Wilenchik does not have physical possession of its bank records and copies of these 

cancelled checks, it can get them from its bank, so they are thus considered to be in Wilenchik's custody or control-and 

subject to production. You said you would go back and ask your boss whether Wilenchik will agree to request and review 

its own bank records and provide the missing information from that. For your reference, the documents Wilenchik 

produced that show payments that we cannot tie to Wyo Tech or Inductance payments we know about are bates 

stamped WB000204, 282,283,285,303,304,305,306,307,308,309,312,313,314,315,316,317,318,319,320,323, 

324 and 325. 

Please get back to me today. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

SCHLAM STONE & DOLAN LILP 

CommercialDivisionBlog.com 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

From: Joshua Wurtzel 

Sent: Friday, May 24, 2019 1:50 PM 

To: Chris Meyers <ChrisM@wb-law.com> 

Cc: Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) <e57659d03+matter1136246401@maildrop.clio.com> 

7 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 8 of 21
Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SDT, 05-17-19 

Supplemental Response to BG SDT 

I can call you. Please see the chart below, which should aid our discussion and will show what is missing. I will call you in 

a few so you can look at this first. 

8 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 9 of 21
Date Payor Source Amount Client Matter 

Account 

Ker, Carrigan, 

May 22, 2017 Wyo Tech $10,000 DAS, Elizabeth Ker/Carrigan 

NOT GIVEN Danzik 

(WYOTECH00004629) (WYOTECH00004629) (WYOTECH00004629) (WB0000 12-says 

(WB000012-says July July31) 

31) 

Danzik (?) 

(WB0000 11 ?) 

Oct. 31, 2017 NOT GIVEN $70,000 Ker, Carrigan, NOT GIVEN DAS, Elizabeth NOT GIVEN 

(WB0000l 1) (WB0000 11 ?) (WB0000l 1) Danzik (?) 

(WB0000 12 ?-shows 

$4,573.09 on Oct. 31) 

Nov. 30, 2017 Inductance Inductance $100,000 Act. No. 9245 NOT GIVEN NOT GIVEN 

(WYOTECH00004631) (WYOTECH00004631) 

(WYOTECH00004631) 

(WYOTECH00004631) 

Dec. 15, 2017 Inductance $100,000 Danzik/ADV Danzik/ADV 

(WB00000I, (WB00000I, NOT GIVEN CWT CWT (WB00000I, 

WB000009) WB000009) WB000009) (WB000009) (WB000009) 

Jan.22,2018 Inductance Inductance $100,000 Danzik/ADV Danzik/ADV 

(WB000002, (WB000002, Act. No. 9245 (WB000002, CWT CWT 

WB000009, WB000009, 

(WYOTECH00004632) 

WB000009, 

WYOTECH00004632) WYOTECH00004632) WYOTECH00004632) 

(WB000009) (WB000009) 

Apr. 9, 2018 Inductance Inductance $100,000 Act. No. 9245 NOT GIVEN NOT GIVEN 

(WYOTECH00004633) (WYOTECH0000463 3) 

(WYOTECH00004633) (WYOTECH00004633) 

Wyo 

Aug. 7, 2018 Inductance Inductance $25,000 Wyo Tech Tech/Wells 

Act. No. 9245 Fargo 

(WYOTECH00004634) (WYOTECH00004634) 

(WYOTECH00004634) 

(WYOTECH00004634) (WB000003) 

(WB000007-says 

Aug. 31) 

Aug. 21, 2018 Inductance Inductance $100,000 Act. No. 9245 NOT GIVEN NOT GIVEN 

(WYOTECH00004635) (WYOTECH00004635) 

(WYOTECH00004635) 

(WYOTECH00004635) 

Sept. 1 7, 2018 Inductance Wyo 

$100,000 Wyo Tech Tech/Wells 

(WB000004, (WB000004, NOT GIVEN Fargo (WB000004) (WB0000II) WB0000II) WB0000II) 

(WB0000l 1) 

9 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 10 of 21
Jan. 14, 2019 

(WB000005, 

WB0000l l) 

Joshua Wurtzel 

Inductance 

(WB000005, 

WB0000l l) 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

iwurtzel@schlamstone.com 

NOT GIVEN 

SCHLAM STONE & DOLAN ltP 

CommercialDivisionBlog.com 

$100,000 

(WB000005, 

WB0000II) 

Wyo Tech 

(WB0000II) 

Wyo Tech 

(WB0000II) 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

From: Chris Meyers <ChrisM@wb-law.com> 

Sent: Friday, May 24, 2019 1:48 PM 

To: Joshua Wurtzel <iwurtzel@schlamstone.com> 

Cc: Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) <e57659d03+matter1136246401@maildrop.clio.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SOT, 05-17-19 

Supplemental Response to BG SOT 

I'm available to discuss. Do you want me to call your cell phone still? 

Thanks, 

www.wb-law.com 

Chris Meyers 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

The information transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged 

material. Any interception, review, retransmission, dissemination or other use of this information by persons or entities other than the 

intended recipient is prohibited by law and may subject them to criminal or civil liability. If you received this communication in error, 

please contact us immediately at (602) 606-2810, and delete the communication from any computer or network system. 

10 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 11 of 21
From: Joshua Wurtzel [mailto:jwurtzel@schlamstone.com] 

Sent: Friday, May 24, 2019 9:21 AM 

To: Chris Meyers 

Cc: Bradley J. Nash; Henk Taylor; Wyo Tech adv Wells Fargo (e57659d03+matter1136246401@maildrop.clio.com) 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SDT, 05-17-19 

Supplemental Response to BG SDT 

OK. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

SCHLAM STONE & DOLAM LlP 

Commercial Division Blog.com 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

From: Chris Meyers <ChrisM@wb-law.com> 

Sent: Friday, May 24, 2019 12:17 PM 

To: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Cc: Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) <e57659d03+matter1136246401@maildrop.clio.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SOT, 05-17-19 

Supplemental Response to BG SOT 

Josh - I just realized that I have a 9:30 conference call set in another matter, which my assistant reminded me of. I will 

call you immediately afterwards. 

Sorry for the confusion. 

www.wb-law.com 

Chris Meyers 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

11 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 12 of 21
ATTORNEY/CLIENT COMMUNICATION 

The information transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged 

material. Any interception, review, retransmission, dissemination or other use of this information by persons or entities other than the 

intended recipient is prohibited by law and may subject them to criminal or civil liability. If you received this communication in error, 

please contact us immediately at (602) 606-2810, and delete the communication from any computer or network system. 

From: Joshua Wurtzel (mailto:jwurtzel@schlamstone.com] 

Sent: Friday, May 24, 2019 7:44 AM 

To: Chris Meyers 

Cc: Leo Beus; Dennis Wilenchik; Tyler Swensen; Chris Feasel; Victoria Stevens; Bradley J. Nash; Henk Taylor 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SOT, 05-17-19 

Supplemental Response to BG SDT 

Please call my cell then. 516-528-9944. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

SCHLAM STONE & DOLAN llP 

Commercial Division Blog.com 

This e-mail, including all attachments, is for the use of the intended recipients only. It may contain legally privileged or 

confidential information. If you are not the intended recipient, please permanently delete this message and all copies or 

printouts, and please notify me immediately. 

From: Chris Meyers <ChrisM@wb-law.com> 

Sent: Friday, May 24, 2019 10:44 AM 

To: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Cc: Leo Beus <lbeus@beusgilbert.com>; Dennis Wilenchik <diw@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; 

Chris Feasel <chrisf@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; Bradley J. Nash 

<bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com> 

Subject: Re: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SOT, 05-17-19 

Supplemental Response to BG SDT 

When I get into the office. Around 930 

www.wb-law.com 

Chris Meyers 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

12 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 13 of 21
ATTORNEY/CLIENT COMMUNICATION 

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On May 24, 2019, at 7:39 AM, Joshua Wurtzel <jwurtzel@schlamstone.com> wrote: 

Following up-specifically with Chris concerning what time we are speaking today. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

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From: Joshua Wurtzel 

Sent: Thursday, May 23, 2019 10:29 PM 

To: Leo Beus <lbeus@beusgilbert.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Chris Feasel 

<chrisf@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; Bradley J. Nash 

<bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; ChrisM@wb-law.com 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SDT, 05-

17-19 Supplemental Response to BG SDT 

Thanks Leo. Can you please confirm that the client for whose benefit these payments were made was 

Dennis Danzik? That is what Tyler told me, and that is to whom the bills you produced are directed, but 

please confirm. Also, when you say the New York and Arizona litigation, which litigations are you 

referring to? In NY I assume it is the main case in which my clients have a judgment against Danzik, but 

please confirm. In Arizona, there are several litigations involving Dennis Danzik, so please let me know 

which one. 

Chris: please let me know when you will call me tomorrow to discuss Wilenchik's production. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

13 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 14 of 21
iwu rtzel@sch la mstone .com 

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delete this message and all copies or printouts, and please notify me immediately. 

From: Leo Beus <lbeus@beusgilbert.com> 

Sent: Thursday, May 23, 2019 8:49 PM 

To: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Chris Feasel 

<chrisf@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; Leo Beus <lbeus@beusgilbert.com>; 

Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor <HTaylor@rrulaw.com>; ChrisM@wb-law.com 

Subject: FW: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SOT, 05-

17-19 Supplemental Response to BG SOT 

I was copied on your emails of 2:21 p.m. and 4:52 p.m. I reviewed our response to the subpoena that 

covered the dates between and January 1, 2016 and October 18, 2017 and we had received no money 

during that time period. The first check we received was dated March 15, 2018. The second check was 

dated May 10, 2018. Those are the only two checks we've had and it's on the New York and Arizona 

litigation. 

If you wish any additional information, let me know. But I am resending the supplemental response and 

I would be happy to answer any questions you have. 

If that does not clarify it adequately, please let me know. 

Very truly yours, 

Leo R. Beus 

Leo R. Beus 

BEUS GILBERT PLLC 

701 North 44th Street I Phoenix, AZ 85008 

Direct: 480.429.3001 I Main: 480.429.3000 I Fax: 480.429.3111 

Email: lbeus@beusgilbert.com 

Secretary: Pat Gaghagen I 480.429.3101 I pgaghagen@beusgilbert.com 

This message may contain confidential and privileged information. If it has been sent to you in error, 

please reply to advise the sender of the error and then immediately delete this message. 

From: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Sent: Thursday, May 23, 2019 4:52 PM 

To: Chris Meyers <ChrisM@wb-law.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Chris Feasel 

<chrisf@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) 

<e57659d03+matter1136246401@maildrop.clio.com>; Leo Beus <lbeus@beusgilbert.com>; Jeffrey M. 

14 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 15 of 21
Eilender <jeilender@schlamstone.com>; Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor 

<HTaylor@rrulaw.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SDT, 05-

17-19 Supplemental Response to BG SDT 

Chris, 

I am not harassing you-I am explaining why I do not believe you have complied with the court's order, 

and giving you an opportunity to explain why I am wrong. At most, the invoices show payments applied 

to particular invoices, but they do not show what particular payments are being applied. Nor do the 

documents you produced show for what clients or matters the funds that were paid to you from Wyo 

Tech and Inductance were earmarked. I understood from Tyler that funds would get paid into your 

attorney-escrow account as a retainer, so I am entitled to see documents showing for what matters and 

clients those funds were earmarked when initially deposited. Nothing you produced shows that. 

I am happy to get on the phone and discuss, but I will need a written representation explaining this. Let 

me know what time you will call me in the office tomorrow morning or early afternoon. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

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This e-mail, including all attachments, is for the use of the intended recipients only. It may contain 

legally privileged or confidential information. If you are not the intended recipient, please permanently 

delete this message and all copies or printouts, and please notify me immediately. 

From: Chris Meyers <ChrisM@wb-law.com> 

Sent: Thursday, May 23, 2019 7:46 PM 

To: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Chris Feasel 

<chrisf@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) 

<e57659d03+matter1136246401@maildrop.clio.com>; lbeus@beusgilbert.com; Jeffrey M. Eilender 

<jeilender@schlamstone.com>; Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor 

<HTaylor@rrulaw.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SDT, 05-

17-19 Supplemental Response to BG SDT 

Josh, 

Did you miss the part when I said "But we have complied with the subpoena and produced the 

responsive documents" below? I reiterate that to our knowledge, we have produced all documentation 

in our possession that is responsive to the subpoenas. Given the gravity of the Court's May 16 Order, we 

are continuing to search to determine if any other documents remain. However, our firm administrator 

(bookkeeper) is out on bereavement leave for a funeral today and tomorrow. Regardless, I have no 

reason to believe that we have not produced all responsive documents at this time. 

15 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 16 of 21
Additionally, we are not making anything complicated. Instead, you are misunderstanding our duties 

under the subpoena, which is one thing: to produce all responsive documents. We have no obligation 

to explain anything to you whatsoever. You are also just assuming, because you do not understand our 

bookkeeping system, that other responsive documents must exist. However, that is not the case. If you 

want an answer as to how the funds were applied to the cases we are handling you, you need to look at 

the invoices which were produced to you. 

As a professional courtesy, we are willing to hold a teleconference with you to explain how the 

documents produced fit into the bigger picture. But you need to stop harassing us about this issue 

immediately. 

www.wb-law.com 

Chris Meyers 

Attorney at Law 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

The information transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged 

material. Any interception, review, retransmission, dissemination or other use of this information by persons or entities other than ti 

intended recipient is prohibited by law and may subject them to criminal or civil liability. If you received this communication in err 

please contact us immediately at (602) 606-2810, and delete the communication from any computer or network system. 

From: Joshua Wurtzel [mailto:jwurtzel@schlamstone.com] 

Sent: Thursday, May 23, 2019 2:21 PM 

To: Chris Meyers 

Cc: Dennis Wilenchik; Tyler Swensen; Chris Feasel; Victoria Stevens; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com); lbeus@beusgilbert.com; Jeffrey M. Eilender; 

Bradley J. Nash; Henk Taylor 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to WB SOT, 05-

17-19 Supplemental Response to BG SOT 

Chris, 

I am not asking whether you are hiding anything. I am asking you to confirm, for both you and Beus 

Gilbert (or Beus Gilbert for itself), that every payment that was made by Wyo Tech or Inductance to 

either Wilenchik or Beus Gilbert is reflected in the recent productions, and that none are missing. If this 

is not correct, then let me know; otherwise, I will assume it is correct and that you are representing to 

me that the productions include documents showing all payments. 

Concerning Wilenchik's production, this is a very simple issue, so I'm not sure why it has become so 

complicated. You identified a handful of payments from Wyo Tech and Inductance. You were also 

required to produce documents showing which clients and which matters those payments were applied 

16 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 17 of 21
to. After spending a significant amount of time reviewing the documents you produced, I do not see 

how the documents show to which clients and to which matters each of the payments you identified as 

coming from Wyo Tech or Inductance were applied. I am thus giving you an opportunity to explain to me 

in writing how I am wrong. While I am happy to have a phone conference, I ultimately need documents 

showing which clients and matters these documents went to. And that is what the court's order 

requires. If you think you have produced documents showing this and I am missing something, please 

respond in writing directing me to this. I am also happy to speak by phone. I am available the rest of 

today and will make myself available tomorrow in the morning or early afternoon your time. But until I 

get either documents that show which clients and matters each payment you identified were applied to, 

or you can give me something satisfactory in writing, then I don't see how Wilenchik has complied with 

the court's order. 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

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This e-mail, including all attachments, is for the use of the intended recipients only. It may contain 

legally privileged or confidential information. If you are not the intended recipient, please permanently 

delete this message and all copies or printouts, and please notify me immediately. 

From: Chris Meyers <ChrisM@wb-law.com> 

Sent: Thursday, May 23, 2019 12:30 PM 

To: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; Tyler Swensen <TylerS@wb-law.com>; Chris Feasel 

<chrisf@wb-law.com>; Victoria Stevens <VictoriaS@wb-law.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) 

<e57659d03+matter1136246401@maildrop.clio.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental Response to WB SOT, 05-

17-19 Supplemental Response to BG SOT 

Josh - Please keep me copied on all future e-mails. We are in depositions all day today, but will follow 

up with you shortly. Also, both firms have complied with the subpoena and produced all documentation 

we are even aware of and in fact conducted a thorough investigation on that issue. In short, we are not 

hiding anything, nor do we have any reason to. If you need us to walk you through the documentation 

to understand it better, we are willing to do so as a courtesy. But we have complied with the subpoena 

and produced the responsive documents. 

Please let me know if you would like to conduct a teleconference on this. Again, we won't be able to do 

it today, but will shortly. 

Thanks, 

www.wb-law.com 

Chris Meyers 

Attorney at Law 

17 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 18 of 21
The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

The infonnation transmitted by this e-mail is intended only for the addressee and may contain confidential and/or privileged 

material. Any interception, review, retransmission, dissemination or other use of this information by persons or entities other than ti 

intended recipient is prohibited by law and may subject them to criminal or civil liability. If you received this communication in err 

please contact us immediately at (602) 606-2810, and delete the communication from any computer or network system. 

Begin forwarded message: 

From: Joshua Wurtzel <jwurtzel@schlamstone.com> 

Date: May 22, 2019 at 7:49:56 PM MST 

To: Victoria Stevens <VictoriaS@wb-law.com>, "Jeffrey M. Eilender" 

<jeilender@schlamstone.com>, "Bradley J. Nash" <bnash@schlamstone.com>, "Henk 

Taylor" <HTaylor@rrulaw.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>, Chase Turrentine <chaset@wb-law.com>, 

Tyler Swensen <TylerS@wb-law.com>, "Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com)" 

<e57659d03+matter1136246401@maildrop.clio.com> 

Subject: RE: Emailing: 05-17-19 Wyo Resp to 1st Rogs, 05-17-19 Supplemental 

Response to WB SDT, 05-17-19 Supplemental Response to BG SDT 

Counsel, 

We have reviewed all Wilenchik's and Beus Gilbert's productions. 

Concerning Beus Gilbert's production, it is not clear to me what matters and clients the 

two payments from Inductance were for. The invoices are directed to Dennis Danzik and 

refer to the "New York and Arizona Litigation." As you know, there are several Danzikrelated litigations in New York and Arizona, so I need either a document or written 

representation from Beus Gilbert stating what specific matters and what clients these 

payments were for. Tyler mentioned on the phone that these two payments were for 

Dennis Danzik. If that is the case, I need something in writing from Beus Gilbert saying 

that, and also identifying what specific matters. 

Concerning Wilenchik's productions, I still cannot tell what payments were for what 

clients and matters. The written responses identify several payments from Wyo Tech 

and Inductance, and in response to the requests for documents showing which clients 

and matters these payments were for, the responses refer to documents produced in 

Wilenchik's initial production (which came before we filed our amended motion for an 

order to show cause, and which do not show which payments were for which clients 

and matters), and then also refer to the invoices you produced on May 21. But looking 

at those invoices and the other documents you refer to in the written responses, I 

cannot tell which matters and which clients any given payment went to. For payments 

18 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 19 of 21
from Wyo Tech, you identify payments shown on WYOTECH00004629 and 

WYO00004634; see also, WB000004, WB000009, and WB000011-which total seven 

payments. (Note: WYO00004634 is a payment from Inductance, not Wyo Tech.) And for 

payments from Inductance, you identify payments shown on WYOTECH00004631, 

WYOTECH00004632, WYOTECH00004633, WYOTECH00004634, WYOTECH00004635, 

WB000001, WB000002, WB000004 and WB00000S, WB000009, and WB000011-which 

are at least five payments, though potentially more, since I can't tell which from the 

Wilenchik production are duplicative of the payments you cite from the Wyo Tech 

production (and if there are payments in the Wilenchik production but not in the Wyo 

Tech production, then that raises issues with Wyo Tech's production). In any event, 

none of the documents you produced show which clients or matters these payments 

were applied to. Tyler explained that the money went into escrow and was then applied 

to a particular invoice as the funds were used; but when the funds initially went into 

escrow, they had to be earmarked for a specific client-so I need to know what client(s) 

and matter(s) each payment was earmarked for, and what client(s) and matter(s) those 

funds were ultimately used for. If you believe the documents show this information, 

then please point me to the specific documents. If not, then please produce something 

showing this information. Wilenchik has not complied with the subpoenas if this 

information is missing. 

Further, based on your amended written responses, I assume Wilenchik's and Beus 

Gilbert's written responses identify the bates numbers of the documents that show ALL 

payments to either firm from Wyo Tech and Inductance, and that neither Wyo Tech nor 

Inductance made any payments to Wilenchik or Beus Gilbert at any time other than the 

payments reflected in the documents referred to in Wilenchik's and Beus Gilbert's 

written responses; is this correct? In other words, are there other payments that are 

missing from your production for either firm? 

Joshua Wurtzel 

Schlam Stone & Dolan LLP 

26 Broadway 

New York, NY 10004 

Tel.: (212) 344-5400 (x 324) 

jwurtzel@schlamstone.com 

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CommercialDivisionBlog.com 

This e-mail, including all attachments, is for the use of the intended recipients only. It 

may contain legally privileged or confidential information. If you are not the intended 

recipient, please permanently delete this message and all copies or printouts, and 

please notify me immediately. 

From: Victoria Stevens <VictoriaS@wb-law.com> 

Sent: Friday, May 17, 2019 11:12 PM 

To: Jeffrey M. Eilender <jeilender@schlamstone.com>; Joshua Wurtzel 

<jwurtzel@schlamstone.com>; Bradley J. Nash <bnash@schlamstone.com>; Henk Taylor 

<HTaylor@rrulaw.com> 

Cc: Dennis Wilenchik <diw@wb-law.com>; Chase Turrentine <chaset@wb-law.com>; 

Tyler Swensen <TylerS@wb-law.com>; Wyo Tech adv Wells Fargo 

(e57659d03+matter1136246401@maildrop.clio.com) 

<e57659d03+matter1136246401@maildrop.clio.com> 

19 

Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 20 of 21
Subject: Emailing: 05-17-19 Wyo Resp to 1st Rags, 05-17-19 Supplemental Response to 

WB SDT, 05-17-19 Supplemental Response to BG SDT 

Importance: High 

Counsel: 

Please find attached the Responses to Discovery. Note that the Response to 

Interrogatories and the Supplemental Response to the Subpoena Duces Tecum for Beus 

Gilbert will be signed as soon as we can accomplish that. Based upon your conversations 

with counsel, I am giving you unredacted copies of W&B internal documents, which will 

be marked confidential and bates stamped. We are releasing these in good faith and 

that you will use them in accordance with the terms of the protective order. 

www.wb-law.com 

Victoria Stevens 

Senior Paralegal 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

P 602-606-2810 F 602-606-2811 

ATTORNEY/CLIENT COMMUNICATION 

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Case 2:17-cv-04140-DWL Document 154-5 Filed 05/29/19 Page 21 of 21