EXHIBIT C 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 1 of 19
26 Broadway, New York, NY 10004

Main: 212 344-5400 Fax: 212 344-7677

schlamstone.com

Joshua Wurtzel 

Associate 

jwurtzel@schlamstone.com 

July 8, 2019 

BY OVERNIGHT FEDEX 

Mr. Ali M. Mosharrafa 

Ms. Kristin Joiner Mosharrafa 

5346 East Royal Palm Road 

Paradise Valley, Arizona 85253 

Mosharrafa Plastic Surgery 

4611 East Shea Boulevard, Suite 230 

Phoenix, Arizona 85028 

5115 North 34th Way 

Phoenix, Arizona 85018 

Re: Wells Fargo Bank, N.A. v. Wyo Tech Inv. Grp., LLC, et al., Case No. 17-cv-4140-

DWL

Dear Mr. and Ms. Mosharrafa:

This firm represents Defendants CWT Canada II Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting in this action.

As you know, on or about February 11, 2019, we served you with a subpoena in this action, 

which seeks your production of documents. Your document production was due on March 18, 

2019, but we did not get any response to the subpoena from you.

On April 16, 2019, we sent you a letter following up on this subpoena, but again did not get a 

response.

On June 20, 2019, the court in this action granted our motion for an order to show cause why 

you, among others, should not be held in civil contempt for your failure to respond to the 

subpoena we served on you. Also on June 20, we served this order to show cause on you by 

overnight courier.

Under this order to show cause, your deadline to oppose our motion to hold you in civil 

contempt was June 25, 2019. But you did not file any opposition papers.

SCH LAM STONE & DOLAN LLP 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 2 of 19
Mr. Ali M. Mosharrafa 

Ms. Kristin Joiner Mosharrafa

July 8, 2019

Page 2 of 2

In accordance with this order to show cause, on June 27, 2019, the court held a show-cause 

hearing. You did not appear, either personally or through counsel, at this hearing. The court 

then held you, among others, in civil contempt, ordered you to pay our attorneys’ fees 

incurred in making this motion, and fined you $250 per day beginning on June 27 and lasting 

until you fully comply with the subpoena we served on you. We served this order on you on 

June 28, 2019, and attach a copy of this order to this letter as well.

But despite this order, you have failed to comply with this subpoena, or even reach out to us 

to discuss your response. We thus demand that you immediately produce all documents in 

your possession, custody, or control that are responsive to the subpoena we served on you, 

and also immediately reach out to us to make arrangements to pay our attorneys’ fees and the 

daily fine the court imposed on you. If you fail to take these steps by July 10, 2019, we will 

seek additional relief from the court—including asking the court to issue a warrant for your 

arrest.

Sincerely,

Joshua Wurtzel

cc: Jeffrey M. Eilender, Esq. (by e-mail)

Bradley J. Nash, Esq. (by e-mail)

J. Henk Taylor, Esq. (by e-mail)

Dennis Wilenchik, Esq. (by e-mail)

Tyler Swensen, Esq. (by e-mail)

Chase Turrentine, Esq. (by e-mail)

Victoria Stevens (by e-mail)

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 3 of 19
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WO

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

Wells Fargo Bank NA, 

Plaintiff, 

v. 

Wyo Tech Investment Group LLC, et al., 

Defendants. 

No. CV-17-04140-PHX-DWL 

ORDER 

 On June 19, 2019, Defendants CWT Canada II Limited Partnership, Resource 

Recovery Corporation, and Jean Noelting (collectively, the “CWT Parties”) filed a motion 

seeking an order to show cause (“OSC”) why seven nonparties—(1) Danzik Applied 

Sciences, LLC, (2) Charles J. Davis, (3) Richard W. Davis, (4) Ashley Mosharrafa, (5) 

Tamir Mosharrafa, (6) Ali M. Mosharrafa, and (7) Kristin Joiner Mosharrafa—should not 

be held in contempt for their failure to respond to the subpoenas served on them. (Doc. 

159.) 

On June 20, 2019, the Court issued an order granting the motion (“the Order”). 

(Doc. 161.) The Order also (1) set an OSC hearing date of June 27, 2019, (2) required the 

non-parties to file any written response by June 25, 2019, and (3) authorized the CWT 

parties to serve the non-parties with a copy of the Order “by overnight courier” by June 21, 

2019. (Id.) 

Later that day, the CWT parties filed an affidavit establishing that a copy of the 

Order had been sent via “Federal Express-Priority Overnight Delivery” to all seven nonCase 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 4 of 19 Case 2:17-cv-04140-DWL Document 167 Filed 06/27/19 Page 1 of 2
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parties. (Doc. 163.) 

The June 25, 2019 deadline for the non-parties to address the OSC order came and 

went without any of them filing a response. 

On June 27, 2019, the Court held the OSC hearing as scheduled. None of the nonparties appeared. The only attorneys present were (1) two of the CWT parties’ attorneys 

and (2) an attorney for Wyo Tech Investment Group LLC (“Wyo Tech”), who made clear 

that he does not represent any of the non-parties. 

Accordingly, and for the reasons more fully stated on the record during the June 27, 

2019 hearing, IT IS ORDERED that: 

(1) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa are held in civil contempt; 

(2) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa must pay the legal fees incurred by the CWT Parties in connection with 

bringing the motion for an OSC and the OSC hearing; and 

(3) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa are each assessed a daily fine of $250 beginning on June 27, 2019 and lasting 

until the non-party fully complies with the subpoena(s) at issue. 

 Dated this 27th day of June, 2019. 

Case 2:17-cv-04140-DWL Document 167 Filed 06/27/19 Page 2 of 2

United tates District Judge 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 5 of 19
26 Broadway, New York, NY 10004

Main: 212 344-5400 Fax: 212 344-7677

schlamstone.com

Joshua Wurtzel

Associate

jwurtzel@schlamstone.com

July 8, 2019

BY OVERNIGHT FEDEX

Ms. Elizabeth J. Danzik

Danzik Applied Sciences, LLC

c/o Resident Agents Inc.

8 The Green, Suite R

Dover, Delaware 19901

12142 East San Victor Drive

Scottsdale, Arizona 85259

Re: Wells Fargo Bank, N.A. v. Wyo Tech Inv. Grp., LLC, et al., Case No. 17-cv-4140-

DWL

Dear Ms. Danzik:

This firm represents Defendants CWT Canada II Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting in this action. We write to you in your capacity as purported 

managing member of Danzik Applied Sciences, LLC (“DAS”).

As you know, on or about February 4, 2019, we served DAS with a subpoena in this action, 

which seeks the production of documents. Your document production was due on February 

28, 2019, but we did not get any response to the subpoena from you.

On April 16, 2019, we sent you a letter following up on this subpoena, but again did not get a 

response.

On June 20, 2019, the court in this action granted our motion for an order to show cause why 

DAS, among others, should not be held in civil contempt for your failure to respond to the 

subpoena we served on you. Also on June 20, we served this order to show cause on you by 

overnight courier.

Under this order to show cause, your deadline to oppose our motion to hold you in civil 

contempt was June 25, 2019. But you did not file any opposition papers.

In accordance with this order to show cause, on June 27, 2019, the court held a show-cause 

hearing. You did not appear at this hearing. The court then held DAS, among others, in civil 

contempt, ordered it to pay our attorneys’ fees incurred in making this motion, and fined it

SCH LAM STONE & DOLAN LLP 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 6 of 19
Ms. Elizabeth J. Danzik

Danzik Applied Sciences, LLC

July 8, 2019

Page 2 of 2

$250 per day beginning on June 27 and lasting until you fully comply with the subpoena we 

served on you. We served this order on you on June 28, 2019, and attach a copy of this order 

to this letter as well.

But despite this order, you have failed to comply with this subpoena, or even reach out to us 

to discuss your response. We thus demand that you immediately produce all documents in 

your possession, custody, or control that are responsive to the subpoena we served on you, 

and also immediately reach out to us to make arrangements to pay our attorneys’ fees and the 

daily fine the court imposed on you. If you fail to take these steps by July 10, 2019, we will 

seek additional relief from the court—including asking the court to issue a warrant for your 

arrest, since you are the purported managing member of DAS and thus control whether it 

complies with the court’s order

Sincerely,

Joshua Wurtzel

cc: Jeffrey M. Eilender, Esq. (by e-mail)

Bradley J. Nash, Esq. (by e-mail)

J. Henk Taylor, Esq. (by e-mail)

Dennis Wilenchik, Esq. (by e-mail)

Tyler Swensen, Esq. (by e-mail)

Chase Turrentine, Esq. (by e-mail)

Victoria Stevens (by e-mail)

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 7 of 19
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WO

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

Wells Fargo Bank NA, 

Plaintiff, 

v. 

Wyo Tech Investment Group LLC, et al., 

Defendants. 

No. CV-17-04140-PHX-DWL 

ORDER 

 On June 19, 2019, Defendants CWT Canada II Limited Partnership, Resource 

Recovery Corporation, and Jean Noelting (collectively, the “CWT Parties”) filed a motion 

seeking an order to show cause (“OSC”) why seven nonparties—(1) Danzik Applied 

Sciences, LLC, (2) Charles J. Davis, (3) Richard W. Davis, (4) Ashley Mosharrafa, (5) 

Tamir Mosharrafa, (6) Ali M. Mosharrafa, and (7) Kristin Joiner Mosharrafa—should not 

be held in contempt for their failure to respond to the subpoenas served on them. (Doc. 

159.) 

On June 20, 2019, the Court issued an order granting the motion (“the Order”). 

(Doc. 161.) The Order also (1) set an OSC hearing date of June 27, 2019, (2) required the 

non-parties to file any written response by June 25, 2019, and (3) authorized the CWT 

parties to serve the non-parties with a copy of the Order “by overnight courier” by June 21, 

2019. (Id.) 

Later that day, the CWT parties filed an affidavit establishing that a copy of the 

Order had been sent via “Federal Express-Priority Overnight Delivery” to all seven nonCase 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 8 of 19 Case 2:17-cv-04140-DWL Document 167 Filed 06/27/19 Page 1 of 2
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parties. (Doc. 163.) 

The June 25, 2019 deadline for the non-parties to address the OSC order came and 

went without any of them filing a response. 

On June 27, 2019, the Court held the OSC hearing as scheduled. None of the nonparties appeared. The only attorneys present were (1) two of the CWT parties’ attorneys 

and (2) an attorney for Wyo Tech Investment Group LLC (“Wyo Tech”), who made clear 

that he does not represent any of the non-parties. 

Accordingly, and for the reasons more fully stated on the record during the June 27, 

2019 hearing, IT IS ORDERED that: 

(1) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa are held in civil contempt; 

(2) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa must pay the legal fees incurred by the CWT Parties in connection with 

bringing the motion for an OSC and the OSC hearing; and 

(3) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa are each assessed a daily fine of $250 beginning on June 27, 2019 and lasting 

until the non-party fully complies with the subpoena(s) at issue. 

 Dated this 27th day of June, 2019. 

Case 2:17-cv-04140-DWL Document 167 Filed 06/27/19 Page 2 of 2

United tates District Judge 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 9 of 19
26 Broadway, New York, NY 10004

Main: 212 344-5400 Fax: 212 344-7677

schlamstone.com

Joshua Wurtzel

Associate

jwurtzel@schlamstone.com

July 8, 2019

BY OVERNIGHT FEDEX

Mr. Richard W. Davis

2552 East Los Alamos Street

Gilbert, Arizona 85295

Re: Wells Fargo Bank, N.A. v. Wyo Tech Inv. Grp., LLC, et al., Case No. 17-cv-4140-

DWL

Dear Mr. Davis:

This firm represents Defendants CWT Canada II Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting in this action.

As you know, on or about February 4, 2019, we served you with a subpoena in this action, 

which seeks your production of documents. Your document production was due on February 

28, 2019, but we did not get any response to the subpoena from you. 

On April 16, 2019, we sent you a letter following up on this subpoena, but again did not get a 

response.

On June 20, 2019, the court in this action granted our motion for an order to show cause why 

you, among others, should not be held in civil contempt for your failure to respond to the 

subpoena we served on you. Also on June 20, we served this order to show cause on you by 

overnight courier.

Under this order to show cause, your deadline to oppose our motion to hold you in civil 

contempt was June 25, 2019. But you did not file any opposition papers.

In accordance with this order to show cause, on June 27, 2019, the court held a show-cause 

hearing. You did not appear, either personally or through counsel, at this hearing. The court 

then held you, among others, in civil contempt, ordered you to pay our attorneys’ fees 

incurred in making this motion, and fined you $250 per day beginning on June 27 and lasting 

until you fully comply with the subpoena we served on you. We served this order on you on 

June 29, 2019, and attach a copy of this order to this letter as well.

But despite this order, you have failed to comply with this subpoena, or even reach out to us 

to discuss your response. We thus demand that you immediately produce all documents in 

SCH LAM STONE & DOLAN LLP 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 10 of 19
Mr. Richard W. Davis

July 8, 2019

Page 2 of 2

your possession, custody, or control that are responsive to the subpoena we served on you, 

and also immediately reach out to us to make arrangements to pay our attorneys’ fees and the 

daily fine the court imposed on you. If you fail to take these steps by July 10, 2019, we will 

seek additional relief from the court—including asking the court to issue a warrant for your 

arrest.

Sincerely,

Joshua Wurtzel

cc: Jeffrey M. Eilender, Esq. (by e-mail)

Bradley J. Nash, Esq. (by e-mail)

J. Henk Taylor, Esq. (by e-mail)

Dennis Wilenchik, Esq. (by e-mail)

Tyler Swensen, Esq. (by e-mail)

Chase Turrentine, Esq. (by e-mail)

Victoria Stevens (by e-mail)

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 11 of 19
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WO

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

Wells Fargo Bank NA, 

Plaintiff, 

v. 

Wyo Tech Investment Group LLC, et al., 

Defendants. 

No. CV-17-04140-PHX-DWL 

ORDER 

 On June 19, 2019, Defendants CWT Canada II Limited Partnership, Resource 

Recovery Corporation, and Jean Noelting (collectively, the “CWT Parties”) filed a motion 

seeking an order to show cause (“OSC”) why seven nonparties—(1) Danzik Applied 

Sciences, LLC, (2) Charles J. Davis, (3) Richard W. Davis, (4) Ashley Mosharrafa, (5) 

Tamir Mosharrafa, (6) Ali M. Mosharrafa, and (7) Kristin Joiner Mosharrafa—should not 

be held in contempt for their failure to respond to the subpoenas served on them. (Doc. 

159.) 

On June 20, 2019, the Court issued an order granting the motion (“the Order”). 

(Doc. 161.) The Order also (1) set an OSC hearing date of June 27, 2019, (2) required the 

non-parties to file any written response by June 25, 2019, and (3) authorized the CWT 

parties to serve the non-parties with a copy of the Order “by overnight courier” by June 21, 

2019. (Id.) 

Later that day, the CWT parties filed an affidavit establishing that a copy of the 

Order had been sent via “Federal Express-Priority Overnight Delivery” to all seven nonCase 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 12 of 19 Case 2:17-cv-04140-DWL Document 167 Filed 06/27/19 Page 1 of 2
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parties. (Doc. 163.) 

The June 25, 2019 deadline for the non-parties to address the OSC order came and 

went without any of them filing a response. 

On June 27, 2019, the Court held the OSC hearing as scheduled. None of the nonparties appeared. The only attorneys present were (1) two of the CWT parties’ attorneys 

and (2) an attorney for Wyo Tech Investment Group LLC (“Wyo Tech”), who made clear 

that he does not represent any of the non-parties. 

Accordingly, and for the reasons more fully stated on the record during the June 27, 

2019 hearing, IT IS ORDERED that: 

(1) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa are held in civil contempt; 

(2) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa must pay the legal fees incurred by the CWT Parties in connection with 

bringing the motion for an OSC and the OSC hearing; and 

(3) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa are each assessed a daily fine of $250 beginning on June 27, 2019 and lasting 

until the non-party fully complies with the subpoena(s) at issue. 

 Dated this 27th day of June, 2019. 

Case 2:17-cv-04140-DWL Document 167 Filed 06/27/19 Page 2 of 2

United tates District Judge 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 13 of 19
26 Broadway, New York, NY 10004

Main: 212 344-5400 Fax: 212 344-7677

schlamstone.com

Joshua Wurtzel

Associate

jwurtzel@schlamstone.com

July 8, 2019

BY OVERNIGHT FEDEX

Mr. Tamir Mosharrafa 

Ms. Ashley Mosharrafa

11206 North Saint Andrews Way

Scottsdale, Arizona 85254

Mosharrafa Plastic Surgery

4611 East Shea Boulevard, Suite 230

Phoenix, Arizona 85028

6211 East Huntress Drive

Paradise Valley, Arizona 85253

Re: Wells Fargo Bank, N.A. v. Wyo Tech Inv. Grp., LLC, et al., Case No. 17-cv-4140-

DWL

Dear Mr. and Ms. Mosharrafa:

This firm represents Defendants CWT Canada II Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting in this action.

As you know, on or about February 11, 2019, we served you with a subpoena in this action, 

which seeks your production of documents. Your document production was due on March 18, 

2019, but we did not get any response to the subpoena from you. 

On April 16, 2019, we sent you a letter following up on this subpoena, but again did not get a 

response.

On June 20, 2019, the court in this action granted our motion for an order to show cause why 

you, among others, should not be held in civil contempt for your failure to respond to the 

subpoena we served on you. Also on June 20, we served this order to show cause on you by 

overnight courier.

SCH LAM STONE & DOLAN LLP 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 14 of 19
Mr. Tamir Mosharrafa 

Ms. Ashley Mosharrafa

July 8, 2019

Page 2 of 2

Under this order to show cause, your deadline to oppose our motion to hold you in civil 

contempt was June 25, 2019. But you did not file any opposition papers.

In accordance with this order to show cause, on June 27, 2019, the court held a show-cause 

hearing. You did not appear, either personally or through counsel, at this hearing. The court 

then held you, among others, in civil contempt, ordered you to pay our attorneys’ fees 

incurred in making this motion, and fined you $250 per day beginning on June 27 and lasting 

until you fully comply with the subpoena we served on you. We served this order on you on 

June 28, 2019, and attach a copy of this order to this letter as well.

But despite this order, you have failed to comply with this subpoena, or even reach out to us 

to discuss your response. We thus demand that you immediately produce all documents in 

your possession, custody, or control that are responsive to the subpoena we served on you, 

and also immediately reach out to us to make arrangements to pay our attorneys’ fees and the 

daily fine the court imposed on you. If you fail to take these steps by July 10, 2019, we will 

seek additional relief from the court—including asking the court to issue a warrant for your 

arrest.

Sincerely,

Joshua Wurtzel

cc: Jeffrey M. Eilender, Esq. (by e-mail)

Bradley J. Nash, Esq. (by e-mail)

J. Henk Taylor, Esq. (by e-mail)

Dennis Wilenchik, Esq. (by e-mail)

Tyler Swensen, Esq. (by e-mail)

Chase Turrentine, Esq. (by e-mail)

Victoria Stevens (by e-mail)

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IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

Wells Fargo Bank NA, 

Plaintiff, 

v. 

Wyo Tech Investment Group LLC, et al., 

Defendants. 

No. CV-17-04140-PHX-DWL 

ORDER 

 On June 19, 2019, Defendants CWT Canada II Limited Partnership, Resource 

Recovery Corporation, and Jean Noelting (collectively, the “CWT Parties”) filed a motion 

seeking an order to show cause (“OSC”) why seven nonparties—(1) Danzik Applied 

Sciences, LLC, (2) Charles J. Davis, (3) Richard W. Davis, (4) Ashley Mosharrafa, (5) 

Tamir Mosharrafa, (6) Ali M. Mosharrafa, and (7) Kristin Joiner Mosharrafa—should not 

be held in contempt for their failure to respond to the subpoenas served on them. (Doc. 

159.) 

On June 20, 2019, the Court issued an order granting the motion (“the Order”). 

(Doc. 161.) The Order also (1) set an OSC hearing date of June 27, 2019, (2) required the 

non-parties to file any written response by June 25, 2019, and (3) authorized the CWT 

parties to serve the non-parties with a copy of the Order “by overnight courier” by June 21, 

2019. (Id.) 

Later that day, the CWT parties filed an affidavit establishing that a copy of the 

Order had been sent via “Federal Express-Priority Overnight Delivery” to all seven nonCase 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 16 of 19 Case 2:17-cv-04140-DWL Document 167 Filed 06/27/19 Page 1 of 2
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parties. (Doc. 163.) 

The June 25, 2019 deadline for the non-parties to address the OSC order came and 

went without any of them filing a response. 

On June 27, 2019, the Court held the OSC hearing as scheduled. None of the nonparties appeared. The only attorneys present were (1) two of the CWT parties’ attorneys 

and (2) an attorney for Wyo Tech Investment Group LLC (“Wyo Tech”), who made clear 

that he does not represent any of the non-parties. 

Accordingly, and for the reasons more fully stated on the record during the June 27, 

2019 hearing, IT IS ORDERED that: 

(1) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa are held in civil contempt; 

(2) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa must pay the legal fees incurred by the CWT Parties in connection with 

bringing the motion for an OSC and the OSC hearing; and 

(3) Nonparties Danzik Applied Sciences, LLC, Charles J. Davis, Richard W. 

Davis, Ashley Mosharrafa, Tamir Mosharrafa, Ali M. Mosharrafa, and Kristin Joiner 

Mosharrafa are each assessed a daily fine of $250 beginning on June 27, 2019 and lasting 

until the non-party fully complies with the subpoena(s) at issue. 

 Dated this 27th day of June, 2019. 

Case 2:17-cv-04140-DWL Document 167 Filed 06/27/19 Page 2 of 2

United tates District Judge 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 17 of 19
26 Broadway, New York, NY 10004

Main: 212 344-5400 Fax: 212 344-7677

schlamstone.com

Joshua Wurtzel

Associate

jwurtzel@schlamstone.com

July 8, 2019

BY E-MAIL AND OVERNIGHT FEDEX

Mr. Charles J. Davis

2552 East Los Alamos Street

Gilbert, Arizona 85295

Re: Wells Fargo Bank, N.A. v. Wyo Tech Inv. Grp., LLC, et al., Case No. 17-cv-4140-

DWL

Dear Mr. Davis:

This firm represents Defendants CWT Canada II Limited Partnership, Resource Recovery 

Corporation, and Jean Noelting in this action.

On July 2, 2019, we received your document production in response to the subpoena we 

served on you in this action. According to the FedEx label in which you sent your production, 

you served your production on July 1, 2019.

As you know, because of your failure to respond to this subpoena and your failure to respond 

to or appear for the show-cause hearing the court in this action held on June 27, 2019, the 

court held you, among others, in civil contempt, ordered you to pay our attorneys’ fees 

incurred in making this motion, and fined you $250 per day beginning on June 27 and lasting 

until you fully comply with the subpoena we served on you.

Since you sent your production on July 1, you are liable for four days’ worth of $250 daily 

fines (June 27-30), for a total of $1,000. Please overnight a check for this amount to my 

attention at the address above. The check should be made payable to “Schlam Stone & Dolan 

LLP.” If we do not receive this check by July 12, 2019, we will seek additional relief from the 

court—including asking the court to issue a warrant for your arrest to compel your 

compliance.

Sincerely,

Joshua Wurtzel

SCH LAM STONE & DOLAN LLP 

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 18 of 19
Mr. Charles J. Davis

July 8, 2019

Page 2 of 2

cc: Jeffrey M. Eilender, Esq. (by e-mail)

Bradley J. Nash, Esq. (by e-mail)

J. Henk Taylor, Esq. (by e-mail)

Dennis Wilenchik, Esq. (by e-mail)

Tyler Swensen, Esq. (by e-mail)

Chase Turrentine, Esq. (by e-mail)

Victoria Stevens (by e-mail)

Case 2:17-cv-04140-DWL Document 182-3 Filed 07/26/19 Page 19 of 19