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J. Henk Taylor (016321)

RYAN RAPP & UNDERWOOD, P.L.C.

3200 N. Central Ave, Suite 2250

Phoenix, Arizona 85012

Telephone: (602) 280-1000

Facsimile: (602) 265-1495

Email: htaylor@rrulaw.com 

Jeffrey M. Eilender (admitted pro hac vice)

Bradley J. Nash (admitted pro hac vice)

Joshua Wurtzel (admitted pro hac vice)

SCHLAM STONE & DOLAN LLP

26 Broadway

New York, New York 10004

Telephone: (212) 344-5400

Facsimile: (212) 344-7677

E-Mail: jeilender@schlamstone.com 

E-Mail: bnash@schlamstone.com 

E-Mail: jwurtzel@schlamstone.com 

Attorneys for Defendants CWT Canada II Limited

Partnership, Resource Recovery Corporation, and

Jean Noelting

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Wells Fargo Bank, N.A.

Plaintiff,

v.

Wyo Tech Investment Group, LLC, CWT 

Canada II Limited Partnership, Resources 

Recovery Corporation, and Jean Noelting,

Defendants.

Case No.: 2:17-CV-04140-DWL

CWT PARTIES’ AMENDED 

MOTION FOR AN ORDER TO

SHOW CAUSE

Oral Argument Requested

And related claims.

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-iTABLE OF CONTENTS

Page

INTRODUCTION................................................................................................................ 1

BACKGROUND.................................................................................................................. 2

ARGUMENT........................................................................................................................ 9

CONCLUSION .................................................................................................................. 11

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Defendants CWT Canada II Limited Partnership, Resource Recovery Corporation, 

and Jean Noelting (collectively, the “CWT Parties”) move the Court for entry of an order 

to show cause why nonparties Wilenchik & Bartness, P.C. (“Wilenchik”) and Beus 

Gilbert PLLC (“Beus Gilbert”)—counsel for Defendant Wyo Tech Investment Group, 

LLC—should not be held in contempt for their failure to produce all the documents 

requested in the CWT Parties’ February 11, 2019 subpoenas in accordance with this 

Court’s April 9, 2019 order (Dkt. No. 119). This amended motion is supported by the 

following memorandum of points and authorities and the Declaration of Joshua Wurtzel.

MEMORANDUM OF POINTS AND AUTHORITIES

INTRODUCTION

This is an amended motion for an order to show cause to hold Wilenchik and Beus 

Gilbert in contempt for their knowing violations of this Court’s April 9 order. In our 

original motion for an order to show cause, we showed that Wilenchik and Beus Gilbert 

failed to produce documents responsive to the subpoenas served on them in accordance 

with this Court’s April 9 order. Since filing that motion two days ago, Wilenchik and 

Beus Gilbert admitted that they never served documents or written responses, but claim 

that they thought they served written responses (not documents)—and that their failure to 

serve these responses was merely “excusable neglect.” We accept Wilenchik and Beus

Gilbert at their word when they say they thought they served these written responses. But 

service of these written responses—which we first got on May 13, 2019—does not cure 

Wilenchik’s and Beus Gilbert’s contempt. 

As explained below, Wilenchik and Beus Gilbert improperly and unilaterally 

purported to narrow the requests in the subpoenas—to which they were ordered, without 

qualification, to produce responsive documents—to a narrower time period than what the 

subpoenas requested, and then conveniently stated that they had no documents responsive 

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to the improperly-narrowed time period. And when we objected to these responses, Beus 

Gilbert stated that it still had no responsive documents even for the full time period 

requested by the subpoena, and Wilenchik produced 14 pages of documents showing 

some payments to it from Wyo Tech and Inductance—showing that it knew it was 

excluding responsive documents by improperly narrowing the time period required by the 

subpoena.

Beus Gilbert’s representation that it never got paid by Wyo Tech or Inductance is 

false. Indeed, we submit with this motion a copy of check from Inductance to Beus 

Gilbert showing that Inductance did pay Beus Gilbert. And we believe Beus Gilbert 

continues to withhold other responsive documents.

And Wilenchik’s production of 14 pages—two weeks late, and only after the CWT 

Parties insisted Wilenchik fully comply with this Court’s April 9 order—doesn’t show 

which payments were for which clients or which matter, nor do they show the “account 

source” of the payments, all of which were required by the subpoena. And critically, 

Wilenchik continues to withhold documents related to other payments we know it got 

from Wyo Tech and Inductance. Indeed, we submit with this motion several checks from 

Wyo Tech and Inductance to Wilenchik showing payments that Wilenchik did not 

disclose in its production. And we believe Wilenchik continues to withhold other 

responsive documents too.

Thus, Wilenchik and Beus continue to violate this Court’s April 9 order even after 

Wilenchik’s late, begrudging production, and despite their false representations in their 

opposition to our original motion for an order to show cause. 

BACKGROUND

On February 11, 2019, the CWT Parties served Wilenchik and Beus Gilbert with 

identical subpoenas seeking documents sufficient to show all payments—including date, 

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amount, and “source account”—made to Wilenchik and Beus Gilbert by Wyo Tech and 

Inductance Energy Corporation (another Danzik-related entity formed using Wyo Tech 

money), as well as documents sufficient to show the clients on whose behalf and matters 

for which these payments were made. Dkt. No. 101 at 7-16; Wurtzel Decl. ¶ 2, Exs. A-C.

Wilenchik objected to this subpoena on relevance grounds, and as this Court 

knows, on February 25, 2019, the CWT Parties and Wilenchik submitted a joint letter 

requesting a hearing to resolve this dispute. Dkt. No. 101. In this joint letter, the CWT 

Parties argued that both Wilenchik and Beus Gilbert should be ordered to produce 

documents in accordance with the subpoenas. Id. at 2.

On February 27, 2019, this Court held a phone hearing on this issue, and took the 

CWT Parties’ motion under advisement. Dkt. No. 103. And on March 5, 2019, this Court 

ordered the parties to submit supplemental briefs regarding three legal issues that this 

Court held were critical to this discovery dispute and which were “intertwined with 

broader unresolved issues in the case.” Dkt. No. 109 at 1.

On March 25, 2019, the parties submitted supplemental briefing regarding these 

three issues. Dkt. Nos. 113-14. On April 8, 2019, this Court heard oral argument on, 

among other things, these three issues. Dkt. No. 118. And at the end of this oral argument, 

this Court asked Wilenchik, “If I end up ruling against you and agreeing to enforce the 

subpoenas, will two weeks be enough to comply?”—to which the attorney arguing this 

motion for Wilenchik stated: “As I stated earlier, Mr. Wilenchik, the partner, is returning 

on Thursday. If two-and-a-half weeks or pushing back to the end of the third week, I think 

that would be better, because he’s been gone for the better part of a month now and 

there’s 1,000 things on the partner’s desk that are going to have to be dealt 

with. . . . That’s if you see it in your wisdom to do that, then three weeks would be 

preferable.” Wurtzel Decl. Ex. D at 41:19-42:5.

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On April 9, 2019, this Court ruled for the CWT Parties on the three issues that were 

the subject of the supplemental briefing, overruled Wilenchik’s and Beus Gilbert’s 

objections to the subpoenas served on them, and ordered Wilenchik and Beus Gilbert to 

“produce the documents requested by the subpoenas by April 26, 2019.” Dkt. No. 119 at 

19.

Despite this order and Wilenchik’s agreement to comply with an order to produce 

these documents by this deadline, Wilenchik and Beus Gilbert failed to produce any 

documents in response to the subpoenas by April 26. Wurtzel Decl. ¶ 5. Nor did they ask 

for additional time to do so. Id. And so, as this Court knows, on May 13, 2019, the CWT 

Parties moved for entry of an order to show cause why Wilenchik and Beus Gilbert should 

not be held in contempt. Dkt. No. 131.

Later on May 13, Wilenchik wrote to the Court asking for an opportunity to 

respond to this motion for an order to show cause because it “believe[d] it was wrongfully 

filed.” Wurtzel Decl. Ex. E. Wilenchik then wrote to us stating that it sent us written 

responses to these subpoenas from it and Beus Gilbert on April 26, and attached those 

responses and threatened sanctions against us if we did not withdraw our motion. Id. Ex. 

F.

But we never received these written responses before May 13—either by mail or email (despite the affidavit of service attached to the responses stating that these responses 

were mailed and e-mailed)—and Wilenchik later admitted that it could not locate an email transmittal of these responses to us. Id.

After reviewing the responses, we told Wilenchik that we would take it at its word 

that it believed it served these responses on April 26 (though it concedes it hadn’t). Id. But 

we also explained that these responses still did not satisfy the Court’s April 9 order. Id.

Specifically, the Court’s April 9 order required Wilenchik and Beus Gilbert to “produce 

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the documents requested by the subpoenas by April 26, 2019,” (Dkt. No. 119), and the 

subpoenas stated that the “relevant time period to which each request refers is January 1, 

2016 through the date of production” (Dkt. No. 101 at 2; Ex. A at 2). But in their

responses, Wilenchik and Beus Gilbert purported to limit each request to “January 1, 2016 

through October 18, 2017,” and then said that they have “no documents in [their] 

possession responsive to [each] request” for this narrowed time period. Id. Exs. G, H.

The CWT Parties explained to Wilenchik that its and Beus Gilbert’s attempt to 

unilaterally limit the scope of the subpoenas was improper, since in its April 9 order, the 

Court rejected Wyo Tech’s argument that only information the CWT Parties knew before

they served the restraining notice on October 18, 2017 is relevant, and that one of the 

CWT Parties’ theories in this case is that Danzik started using Inductance (which was 

formed using Wyo Tech funds) to pay his personal expenses after the CWT Parties served 

the restraining notice on Wyo Tech—which shows that Danzik has an interest in Wyo 

Tech’s funds, since Inductance was merely a continuation of Wyo Tech set up or used to 

avoid the restraining notice. Wurtzel Decl. Ex. F; see also Dkt. No. 119 at 13 (The Court: 

“[B]ecause some of Wyo Tech’s funds were transferred to Inductance for the ‘opening’ of 

an Inductance account immediately before the restraining notice was issued on the Wyo 

Tech account, whether Inductance paid Danzik’s legal bills also bears on whether Danzik 

has an interest in the interpleaded funds.”). The CWT Parties then asked Wilenchik to 

confirm that neither it nor Beus Gilbert “has any documents responsive to any of the 

requests in the subpoenas in its possession, custody, or control for the full time period

requested in the subpoenas—January 1, 2016 through the date of production (April 26, 

2019).” Wurtzel Decl. Ex. F.

In response, on May 14, 2019, Wilenchik wrote back: “I can confirm that Beus 

Gilbert has not received any payments from either Wyo Tech or Inductance at any time. It 

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is also my understanding that W&B did not receive any payments from either Inductance 

or WYO Tech prior to October 2017, as stated in the Response to SDT. W&B has 

obviously received payments from Wyo Tech to pay for our representation of it in this 

lawsuit and W&B may have also received some payments from Wyo Tech or Inductance 

related to other matters since October 2017.” Id. We then demanded that Wilenchik 

immediately produce documents related to these payments, and later on May 14, 

Wilenchik produced 11 pages of documents showing payments it got from Wyo Tech and 

Inductance. Id. ¶ 14, Ex. I. 

But later on May 14, after reviewing this production, we responded to Wilenchik, 

explaining that it was insufficient and incomplete because it was missing documents we 

knew Wilenchik had. Id. Ex. F. So on May 15, 2019—after claiming it had already 

produced documents showing “all payments” from Wyo Tech or Inductance to 

Wilenchik—Wilenchik made a supplemental production of another three pages (id. Exs. 

F, J), and then filed an opposition to the CWT Parties’ initial motion for an order to show 

cause (Dkt. No. 134). 

But these late productions still do not comply with this Court’s April 9 order. And 

Wilenchik’s and Beus Gilberts’s opposition to the CWT Parties’ initial motion for an 

order to show cause includes false representations to the Court, and shows that Wilenchik 

and Beus Gilbert continue to intentionally withhold responsive documents.

First, on April 26, when Wilenchik claims to have (unsuccessfully) attempted to 

serve its written responses, Wilenchik intentionally withheld concededly-responsive, 

court-ordered documents—and produced those documents only on May 14 and 15 in 

response to the CWT Parties’ follow-up demand. Instead, Wilenchik purported to 

unilaterally—and in violation of this Court’s April 9 order—limit the scope of the 

subpoenas to a time period that it believed would allow it to say it had no responsive 

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documents, even though it knew it had responsive documents from outside this time 

period. This was an intentionally-duplicitous attempt to avoid producing documents this 

Court ordered produced.

Indeed, in its opposition to the CWT Parties’ original motion for an order to show 

cause, Wilenchik and Beus Gilbert concede that this Court “unfortunately rejected” Wyo 

Tech’s argument that “the only relevant events or acts related to the interpleaded funds are 

those that occurred up to, but not beyond, the point in time when the restraining notice 

was issued.” Dkt. No. 134 at 5. So Wilenchik and Beus Gilbert knew that their purported 

limitation of the subpoenas was improper, and they even admit that they dropped this 

improper limitation solely because they got caught. See id. (“once the issue about the 

temporal scope of responsive documents was raised by CWT’s counsel,” Wilenchik 

“chose to concede on that point and produce all documents responsive to the subpoena for 

the entire time period defined therein”). This shows their bad faith.

Second, as we explained to Wilenchik in a follow-up e-mail on May 14 (Wurtzel 

Decl. Ex. F), most of the documents Wilenchik produced do not show the clients on 

whose behalf each payment was made or the matter for which each payment was made—

as required by the subpoenas. Further, none of the documents Wilenchik produced show 

the “source account” of the payments—as also required by the subpoenas. Indeed, 

Wilenchik could have produced the checks or wire confirmations for these payments—

which it could have gotten from its bank—but chose instead to produce documents that 

did not comply with this Court’s April 9 order. Indeed, it is critical for the CWT Parties to 

know which payments from Wyo Tech and Inductance were to pay for services for Dennis 

Danzik, his family members, and his cronies—and that is why the Court granted the CWT 

Parties’ motion to compel responses to the subpoenas. The documents Wilenchik 

produced do not show this information.

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Third, and most critically, Wilenchik and Beus Gilbert continue to withhold 

documents responsive to the subpoenas. 

Concerning Beus Gilbert, Beus Gilbert (through its co-counsel, Wilenchik) 

“confirm[ed]” that it has “not received any payments from either Wyo Tech or 

Inductance at any time.” Id. Ex. G. And in its opposition to the CWT Parties’ original 

motion for an order to show cause, Beus Gilbert doubles down on this statement—

representing to this Court that “it has no responsive documents whatsoever.” Dkt. No. 

134 at 4; see also id. at 5 n.2 (Beus Gilbert “has never received any funds from either 

Wyo Tech or Inductance and therefore has no documents in its possession responsive 

to the CWT subpoena whatsoever”). 

But these representations are not true. Indeed, documents we received in postjudgment discovery show that Inductance paid Beus Gilbert $20,000 on March 15, 

2018. A copy of this check is attached to the Wurtzel Declaration as Exhibit K. Beus 

Gilbert did not produce this check, or any documents showing this payment, and instead 

falsely “confirm[ed]” that this document did not exist. Thus, we believe Beus Gilbert 

continues to withhold documents responsive to the subpoena.

Concerning Wilenchik, Wilenchik stated in its written responses to the subpoena 

that it “has no documents in its possession responsive to” any of the requests “for the 

period from January 1, 2016 through October 18, 2017.” Id. Ex. H. But this is not true 

either. To the contrary, a document we received in post-judgment discovery shows that 

Wyo Tech paid Wilenchik $10,000 on May 22, 2017. A copy of this check is attached to 

the Wurtzel Declaration as Exhibit L. Wilenchik did not produce this check, or any 

documents showing this payment, in response to the subpoena here, and instead tried to 

hide this document by claiming that it did not exist.

Further, though Wilenchik represented that its May 14 production includes “all 

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payments received by W&B from Inductance and Wyo Tech” at any time, this is not 

true either. To the contrary, documents we received in post-judgment discovery from 

banks show that Inductance paid Wilenchik $100,000 on April 9, 2018 and $100,000 

on August 21, 2018. Copies of these checks are attached to the Wurtzel Declaration as 

Exhibits M. But Wilenchik did not produce these checks, or any documents showing 

these payments, and instead falsely represented that its May 14 production—which did 

not include documents showing these payments—included “all payments” it received 

from Inductance and Wyo Tech at any time. Thus, we believe Wilenchik continues to 

withhold documents responsive to the subpoena.

ARGUMENT

Civil contempt “‘consists of a party’s disobedience to a specific and definite court 

order by failure to take all reasonable steps within the party’s power to comply.” Inst. of 

Cetacean Research v. Sea Shepherd Conservation Soc’y, 774 F.3d 935, 945 (9th Cir. 

2014) (citation omitted). Indeed, civil contempt is “‘characterized by the court’s desire to 

compel obedience to a court order or to compensate the contemnor’s adversary for the 

injuries which result from the noncompliance.’” United States v. Bright, 596 F.3d 683, 

695-96 (9th Cir. 2010) (citation omitted).

The party alleging civil contempt must show that the alleged contemnor violated 

the court’s order by clear and convincing evidence. Inst. of Cetacean Research, 774 F.3d 

at 945. And “[g]iven the remedial purpose of the sanction, a finding of contempt must be 

accompanied by conditions by which contempt may be purged, spelled out in either the 

original order or the contempt order.” Bright, 596 F.3d at 696. And “although the district 

court generally must impose the minimum sanction necessary to secure compliance, the 

district court retains discretion to establish appropriate sanctions.” Id. (citation omitted).

Further, this Court may hold a nonparty in contempt for failure, without “adequate 

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excuse,” to obey a subpoena or an order related to it. Fed. R. Civ. P. 45(g). See Sali v. 

Corona Reg’l Med. Ctr., 884 F.3d 1218, 1224 (9th Cir. 2018) (court may hold deponent in 

contempt under Rule 45(g) for “fail[ure] without adequate excuse to obey the subpoena or 

an order related to it”) (citation omitted).

Here, Wilenchik and Beus Gilbert indisputably failed to comply with this Court’s 

April 9 order by initially trying to limit the subpoenas to a narrower time period than what 

this Court ordered and then claiming that they had no responsive documents in that time 

period; and then, after the CWT Parties’ filed their initial contempt motion, producing 

documents that failed to show the client or matter to which each payment related and also 

failed to show the source account of each payment; and then, most critically, intentionally 

withholding responsive documents and falsely stating that they do not exist.

Further, the prejudice to the CWT Parties is obvious: though we know that 

Wilenchik and Beus Gilbert withheld responsive documents because we got those 

documents from other sources in other actions, we don’t fully know what else Wilenchik 

and Beus Gilbert are withholding. And any claim by either Wilenchik or Beus Gilbert that 

they have nothing else falls short, since Wilenchik and Beus Gilbert have shown that they 

are willing to make false representations to evade this Court’s April 9 order and to avoid 

producing responsive documents.

Given Wilenchik’s and Beus Gilbert’s disregard of this Court’s April 9 order, and 

their continued, intentional withholding of responsive documents and false statements 

intended to conceal the existence of these documents, this Court should hold Wilenchik 

and Beus Gilbert in civil contempt, order them to pay the CWT Parties’ legal fees incurred 

in making this motion and the original contempt motion, and further order them to pay the 

CWT Parties $500 per day from April 27 through the date they fully comply with this 

Court’s April 9 order by producing all documents requested by the subpoenas. See Bright, 

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596 F.3d at 696 (upholding $500 daily fine and payment of party’s costs as contempt 

sanction).1

CONCLUSION

This Court should issue an order to show cause why Wilenchik and Beus Gilbert 

should not be held in civil contempt, ordered to pay the CWT Parties’ legal fees incurred 

in making this motion and the original contempt motion, and further ordered to pay the 

CWT Parties $500 per day from April 27 through the date they fully comply with this 

Court’s April 9 order by producing all documents requested by the subpoenas.

 

1 Contrary to Wilenchik’s and Beus Gilbert’s argument (Dkt. No. 134 at 3-4), this is a 

motion for an order to show cause to hold Wilenchik and Beus Gilbert in contempt. It is 

not a discovery motion. Indeed, the CWT Parties already made their discovery motion on 

this issue when they moved to compel Wilenchik’s and Beus Gilbert’s responses to the 

subpoenas, which this Court granted.

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Dated:May 15, 2019

Phoenix, Arizona

Respectfully submitted,

RYAN RAPP & UNDERWOOD, P.L.C.

By: /s/ Henk Taylor (016321)

J. Henk Taylor (016321)

3200 N. Central Ave., Suite 1600

Phoenix, Arizona 85012

Telephone: (602) 280-1000

Facsimile: (602) 265-1495

E-Mail: htaylor@rrulaw.com

SCHLAM STONE & DOLAN LLP

Jeffrey M. Eilender (admitted pro hac 

 vice)

Bradley J. Nash (admitted pro hac vice)

Joshua Wurtzel (admitted pro hac vice)

26 Broadway

New York, New York 10004

Telephone: (212) 344-5400

Facsimile: (212) 34407677

E-Mail: jeilender@schlamstone.com

E-Mail: bnash@schlamstone.com

E-Mail: jwurtzel@schlamstone.com 

Attorneys for Defendants CWT Canada II 

Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting

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ORIGINAL e-filed and COPIES

e-mailed this 15th day of May

2019 as follows:

Dennis I. Wilenchik

WILENCHIK & BARTNESS P.C.

2810 North Third Street

Phoenix, AZ 85004

E-Mail: diw@wb-law.com

Leo R. Beus

BEUS GILBERT PLLC

701 North 44th Street

Phoenix, AZ 85008

E-Mail: lbeus@beusgilbert.com

Attorneys for Wyo Tech Investment 

Group, LLC

_______________________

 Joshua Wurtzel

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