EXHIBIT F 

Case 2:17-cv-04140-DWL Document 174-6 Filed 07/08/19 Page 1 of 5
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Dennis I. Wilenchik, #005350 

WILENCHIK & BARTNESS PC 

The Wilenchik & Bartness Building 

2810 North Third Street

Phoenix, Arizona 85004 

admin@wb-law.com

Leo R. Beus, #002687 

BEUS GILBERT PLLC 

701 North 44th Street 

Phoenix, Arizona 85008 

lbeus@beusgilbert.com

Attorneys for Wyo Tech Investment Group, LLC 

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. 

WYO TECH Investment Group, LLC, 

 Cross-Claimant, 

v. 

CWT Canada II Limited Partnership, 

Resources Recovery Corporation, and Jean 

Noelting, 

 Cross-Claim Defendants. 

WYO TECH Investment Group, LLC, 

 Third Party Plaintiff, 

v. 

Schlam Stone & Dolan, LLC, a New York 

Limited Liability Partnership; and Jeffrey M. 

Eilender, 

Third Party Defendants.

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

WYO TECH INVESTMENT GROUP, 

LLC’S SUPPLEMENT TO ITS 

RESPONSES TO THE MANDATORY 

INITIAL DISCOVERY PILOT 

PROJECT REQUESTS 

(Assigned to the 

Honorable Dominic W. Lanza) 

Case 2:17-cv-04140-DWL Document 174-6 Filed 07/08/19 Page 2 of 5
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Wyo Tech Investment Group, LLC (“Wyo Tech”), hereby supplements its Responses to 

the Mandatory Initial Discovery Pilot Project Requests as follows: 

Wyo Tech amends/supplements its Response to Mandatory Initial Discovery Request No. 

1 at Section (b) as follows (additions underlined and deletions struck through): 

Dennis M. Danzik, one of the Judgment Debtors (c/o Dennis I. Wilenchik, Wilenchik & 

Bartness, P.C., 2810 N. Third Street, Phoenix, Arizona 85004, 602-202-2810Wyo Tech is 

currently unware of Dennis Danzik’s physical residential address, this information will be 

supplemented upon if it is later discovery or obtained), is expected to have discoverable 

information including the facts that: (i) WYO TECH is not, and never has been, a party and has 

not otherwise participated in GEM HOLDCO, LLC, et al. v. CWT Canada II Limited Partnership, 

et al., Case Index No. 650841/2013, in the Supreme Court of the State of New York, County of 

New York (“the GEM HOLDCO case”); (ii) neither he nor RDX have ever deposited funds in 

WYO TECH’s Account No. – 2809, and neither of them claim any right, title, or interest in any 

of the funds currently held in said account (or thereafter interplead into the Court); (iii) neither he 

nor RDX hold, or have ever held, any membership or other equity interest in WYO TECH; and 

(iv) WYO TECH does not currently owe any money to him or to RDX. 

. . . 

. . . 

. . . 

. . . 

. . . 

. . . 

. . . 

. . . 

. . . 

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DATED March 4, 2019. 

WILENCHIK & BARTNESS, P.C. 

 /s/ Dennis I. Wilenchik, Esq. 

Dennis I. Wilenchik, Esq. 

The Wilenchik & Bartness Building 

2810 North Third Street 

Phoenix, Arizona 85004 

admin@wb-law.com

BEUS GILBERT PLLC 

Leo R. Beus, Esq. 

 701 North 44th Street 

 Phoenix, Arizona 85008 

 lbeus@beusgilbert.com

Attorneys for Wyo Tech Investment Group, LLC 

CERTIFICATE OF SERVICE 

I hereby certify that on March 4, 2019, I mailed and emailed the attached document to the 

following individuals: 

J. Henk Taylor 

Ryan Rapp & Underwood, P.L.C. 

3200 N. Central Ave., Ste. 2250 

Phoenix, Arizona 85012

htaylor@rrulaw.com

Jeffrey M. Eilender 

Bradley J. Nash 

Joshua Wurtzel

Schlam Stone & Dolan LLP 

26 Broadway 

New York, New York 10004 

jeilender@schlamstone.com

bnash@schlamstone.com

jwurtzel@schlamstone.com

Attorneys for Defendants CWT Canada II Limited Partnership, Resource Recovery Corporation, 

and Jean Noelting 

/s/ Hilary Myers 

Case 2:17-cv-04140-DWL Document 174-6 Filed 07/08/19 Page 4 of 5
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VERIFICATION OF WILLIAM J. HINZ 

I, Willaim J. Hinz, the CEO of Wyo Tech, and am authorized to make this verification on 

3 its behalf. 

4 I have reviewed Wyo Tech's Supplement/Amendment to its Responses to the Mandatory 

5 

Initial Discovery Pilot Project Requests and know the contents thereof. The matters stated in the 

forgoing document are true of my own personal knowledge, except as to those matters which are 

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stated on information and belief, and as to those matters, I believe them to be true. 

7 

I declare under penalty of perjury that the foregoing is true and correct to the best of my 

8 

knowledge. 

· 

9 Dated this (~ day of March, 2019. 

10 (i) MOHICAGARCIA 11 Nota,y Pubic • S1118 at Arlzala 

MARICOPA COUNTY 

My Commlaalon Explrae 

12 June 03, 2022 

13 ~/AA__' 

Its: C tEO 

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